LPL Financial LLC: investment adviser

Item 11 questions answered Yes

These questions cover the firm and its advisory affiliates.

• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have made a false statement or omission?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: entered an order against you or any advisory affiliate in connection with investment-related activity?
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever:
• Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
• Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have made a false statement or omission?
• Has any self-regulatory organization or commodities exchange ever: found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?

Actions about the firm (192)

1. Sep 21, 2026
   Regulatory Action: District of Columbia - Department of Insurance, Securities and Banking FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Sep 21, 2026 · Resolved Sep 21, 2026 · Consent · Docket SB-CO-08-25

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the District of Columbia department of insurance, securities and banking (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of D.C. Official code § 31­5602.07(a)(12) of the District of Columbia uniform Securities Act.

   On September 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of D.C. Official code § 31­5602.07(a)(12) of the District of Columbia uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of D.C. Official code § 31­5602.07(a)(12) to provide restitution to affected District of Columbia customers in an amount of no less than $2,980.13, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

2. Sep 3, 2026
   Regulatory Action: Kansas Department of Insurance Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Sep 3, 2026 · Resolved Sep 3, 2026 · Consent · Docket 27E018

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Kansas department of insurance, securities division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) of the Kansas uniform Securities Act.

   On September 3, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) of the Kansas uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of K.A.R. 81-3-7(a)(4) and K.S.A. 17-12A412(d)(9) to provide restitution to affected Kansas customers in an amount of no less than $23,441.71, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

3. Jul 9, 2026
   Regulatory Action: Louisiana Office of Financial Institutions FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jul 9, 2026 · Resolved Jul 9, 2026 · Consent · Docket OFI-2025-06

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Louisiana Office of Financial Institutions (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of lac 10:XIII.1901 and 704(a)(9) of the Louisiana securities law.

   On July 9, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in lac 10:XIII.1901 and 704(a)(9) of the Louisiana securities law. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of lac 10:XIII.1901 and 704(a)(9), to provide restitution to affected Louisiana customers in an amount of no less than $47,947.14, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

4. Jun 26, 2026
   Regulatory Action: Colorado Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jun 26, 2026 · Resolved Jun 26, 2026 · Consent · Docket 2025-CDS-036

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Colorado Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 11-51-410(1)(I), C.R.S. Of the Colorado Securities Act.

   On June 26, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 11-51-410(1)(I), C.R.S. Of the Colorado Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 11-51-410(1)(I), C.R.S. To provide restitution to affected Colorado customers in an amount of no less than $58,176.12, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

5. Jun 5, 2026
   Regulatory Action: California Department of Financial Protection and Innovation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jun 5, 2026 · Resolved Jun 5, 2026 · Consent · Docket NA

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the California Department of Financial Protection and Innovation (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of California corporations code section 25218 and code regulations, title 10 section 260.218.4.

   On June 5, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation code of regulations, title 10 section 260.218.4. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of code of regulations, title 10 section 260.218.4, to provide restitution to affected California customers in an amount of no less than $217,067.99, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

6. Jun 4, 2026
   Regulatory Action: Michigan Department of Licensing and Regulatory Affairs; Corporations, Securities, and Commercial Licensing Bureau FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jun 4, 2026 · Resolved Jun 4, 2026 · Consent · Docket ENF-25-020115

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Michigan department of licensing and regulatory affairs (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of MCL 451.2412(4)(I) of the Michigan uniform Securities Act.

   On June 4, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of MCL 451.2412(4)(I) Michigan uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed tothe imposition of a censure, to cease and desist from conduct in violation of MCL 451.2412(4)(I)of the Michigan uniform Securities Act, to provide restitution to affected Michigan customers in an amount of no less than $61,870.64, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

7. Apr 23, 2026
   Regulatory Action: Securities Division of the Office of the Attorney General of the State of South Carolina FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Apr 23, 2026 · Resolved Apr 23, 2026 · Consent · Docket 20252028

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Securities Division of the Office of the Attorney General of the State of South Carolina (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of S.C. Code ann. Section 35-1-412(d)(9).

   On April 23, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of S.C. Code ann. Section 35-1-412(d)(9). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of S.C. Code ann. Section 35-1-412(d)(9), to provide restitution to affected South Carolina customers in an amount of no less than $37,905.65, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

8. Apr 22, 2026
   Regulatory Action: Kentucky Department of Financial Institutions FinalSanctions: p; Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Apr 22, 2026 · Resolved Apr 22, 2026 · Consent · Docket 2025-DFI-0142

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Kentucky department of finance institutions (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b) of the Kentucky Securities Act.

   On April 22, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b) of the Kentucky Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of KRS 292.337(2)(k) and 808 kar 10:030, section 3(1)(b), to provide restitution to affected Kentucky customers in an amount of no less than $37,092.78, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

9. Apr 21, 2026
   Regulatory Action: Idaho Department of Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Apr 21, 2026 · Resolved Apr 21, 2026 · Consent · Docket SB-2025-106

   In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Idaho Department of Finance (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of rule 105.01 and rule 105.03(d) of the Idaho uniform Securities Act.

   On April 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of rule 105.01 and rule 105.03(d) of the Idaho uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of rule 105.01 and rule 105.03(d), to provide restitution to affected Idaho customers in an amount of no less than $13,237.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

10. Apr 7, 2026
    Regulatory Action: Puerto Rico Office of the Commissioner of Financial Institutions FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Apr 7, 2026 · Resolved Apr 7, 2026 · Consent · Docket NA

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Puerto Rico Office of the Commissioner of Financial Institutions (OCFI) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 204(a)(2)(j) of the Puerto Rico uniform Securities Act.

    On April 7, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the ocfi regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 204(a)(2)(j) of the Puerto Rico uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 204(a)(2)(j), to provide restitution to affected Puerto Rico customers in an amount of no less than $477.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

11. Apr 2, 2026
    Regulatory Action: Maine Office of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Apr 2, 2026 · Resolved Apr 2, 2026 · Consent · Docket 2026-05

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Maine Office of Securities (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 32 M.R.S. 16412(4)(I) of the Maine uniform Securities Act.

    On April 2, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 32 M.R.S. 16412(4)(I) of the Maine uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 32 M.R.S. 16412(4)(I), to provide restitution to affected Maine customers in an amount of no less than $18,847.50, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

12. Mar 27, 2026
    Regulatory Action: Florida Office of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Mar 27, 2026 · Resolved Mar 27, 2026 · Consent · Docket 130178-S

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Florida Office of Financial Regulation (office) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 69W-600.013(1)(h)1 of the Florida administrative code.

    On March 27, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the office regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 69W-600.013(1)(h)1 of the Florida administrative code. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 9W-600.013(1)(h)1, to provide restitution to affected Florida customers in an amount of no less than $136,409.89, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

13. Mar 17, 2026
    Regulatory Action: Washington Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $25,000 · Begun Mar 17, 2026 · Resolved Mar 17, 2026 · Consent · Docket S-25-3997-26-CO01

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Washington Securities Division (securities division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wac 460-20C-150 of the Washington Securities Act.

    On March 17, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the securities division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wac 460-20C-150 of the Washington Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of wac 460-20C-150, to provide restitution to affected Washington customers in an amount of no less than $61,456.75, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

14. Mar 13, 2026
    Regulatory Action: Illinois Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Mar 13, 2026 · Resolved Mar 13, 2026 · Consent · Docket 2500302

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Illinois Securities Department (securities department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8.E.1.EIV of the Illinois Securities Act.

    On March 13, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the securities department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8.E.1.EIV of the Illinois Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 8.E.1.EIV, to provide restitution to affected Illinois customers in an amount of no less than $124,665.76, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

15. Mar 9, 2026
    Regulatory Action: Nevada Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Mar 9, 2026 · Resolved Mar 9, 2026 · Consent · Docket INV25-164

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Nevada Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of NRS 90.420(1)(1) of the Nevada uniform Securities Act.

    On March 9, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of NRS 90.420(1)(1) of the Nevada uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of NRS 90.420(1)(1), to provide restitution to affected Nevada customers in an amount of no less than $21,656.39, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

16. Mar 6, 2026
    Regulatory Action: North Carolina Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Mar 6, 2026 · Resolved Mar 6, 2026 · Consent · Docket 25ADM006

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the North Carolina Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.C.G.S. 78a of the North Carolina Securities Act.

    On March 6, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.C.G.S. 78a of the North Carolina Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation ofn.c.g.s. 78a, to provide restitution to affected North Carolina customers in an amount of no less than $62,646.37, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

17. Feb 24, 2026
    Regulatory Action: North Dakota Insurance & Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Feb 24, 2026 · Resolved Feb 24, 2026 · Consent · Docket SO-25-910-25-2018

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the North Dakota Insurance & Securities Department (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.D.C.C. 10-04-11(1)(m).

    On February 24, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.D.C.C. 10-04-11(1)(m). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of N.D.C.C. 10-04-11(1) (m), to provide restitution to affected North Dakota customers in an amount of no less than $17,500.09, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

18. Feb 18, 2026
    Regulatory Action: Vermont Department of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $17,000 · Begun Feb 18, 2026 · Resolved Feb 18, 2026 · Consent · Docket 25-020-S

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Vermont Department of Financial Regulation (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the V.S.R. Section 2-2(b)(2) of the Vermont uniform Securities Act.

    On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of V.S.R. Section 2-2(b)(2)of the Vermont uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of V.S.R. Section 2-2(b)(2), to provide restitution to affected Vermont customers in an amount of no less than $3,000.00, to pay an administrative fine in the amount of $17,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

19. Feb 18, 2026
    Regulatory Action: Wisconsin Department of Financial Institutions FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Feb 18, 2026 · Resolved Feb 18, 2026 · Consent · Docket S-251173 (LX)

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the division of securities of the Wisconsin department of financial institution (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wis. Admin code dfi-SEC 4.05(2).

    On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of wis. Admin code dfi-SEC 4.05(2). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of wis. Admin code dfi-SEC 4.05(2), to provide restitution to affected Wisconsin customers in an amount of no less than $86,040.81, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

20. Feb 18, 2026
    Regulatory Action: Oklahoma Department of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Feb 18, 2026 · Resolved Feb 18, 2026 · Consent · Docket ODS FILE 25-230

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Oklahoma Department of Securities (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount oncertain small principal equity transactions, in violation of 1-411(d)(9) of the Oklahoma uniform Securities Act.

    On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 1-411(d)(9) of the Oklahoma uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 1-411(d)(9), to provide restitution to affected Oklahoma customers in an amount of no less than $23,304.180, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

21. Feb 18, 2026
    Regulatory Action: Hawaii Department of Commerce and Consumer Affairs FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Feb 18, 2026 · Resolved Feb 18, 2026 · Consent · Docket SEB20250012

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the commissioner of securities of the state of Hawaii Department of Commerce and Consumer Affairs (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 485A-412(d)(9) of the Hawaii uniform Securities Act.

    On February 18, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 485A-412(d)(9) of the Hawaii uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of 485A-412(d)(9), to provide restitution to affected Hawaii customers in an amount of no lessthan $13,43.05, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

22. Jan 28, 2026
    Regulatory Action: Indiana Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jan 28, 2026 · Resolved Jan 28, 2026 · Consent

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Indiana Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d) of the Indiana uniform Securities Act.

    On January 28, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissionsto retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d) of the Indiana uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of acensure, to cease and desist from conduct in violation of I.C. 23-19-4-12(d)(9) and 710 iac 4-7-6(d), to provide restitution to affected Indiana customers in an amount of no less than $54,428.90, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

23. Jan 21, 2026
    Regulatory Action: Delaware Department of Justice FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jan 21, 2026 · Resolved Jan 21, 2026 · Consent · Docket NA

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the investor protection unit of the Delaware Department of Justice (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC(LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 6 del

    On January 21, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 6 del. C 73-304(a)(10) of the Securities Act of Delaware. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of acensure, to cease and desist from conduct in violation of 6 del. C 73-304(a)(10), to provide restitution to affected Delaware customers in an amount of no less than $13,791.58, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

24. Jan 13, 2026
    Regulatory Action: Nebraska Department of Banking & Finance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $20,000 · Begun Jan 13, 2026 · Resolved Jan 13, 2026 · Consent · Docket NA

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Nebraska department of banking and finance (department) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8-1103(9)(a)(XI) of the Securities Act of Nebraska.

    On January 13, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 8-1103(9)(a)(XI) of the Securities Act of Nebraska. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 8-1103(9)(a)(XI), to provide restitution to affected Nebraska customers in an amount of no less than $21,431.97, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

25. Jan 12, 2026
    Regulatory Action: Missouri Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $25,000 · Begun Jan 12, 2026 · Resolved Jan 12, 2026 · Consent · Docket AP-25-04

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Missouri Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 409.6-604 of the Missouri Securities Act of 2003 (Securities Act) and the regulations promulgated thereunder 15 CSR 30-51.010 to 15CSR 30-51.180 (regulations).

    On January 12, 2026, in connection with a investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Securities Act, to provide restitution to affected Missouri customers in an amount of no less than $73,920.98, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

26. Jan 7, 2026
    Regulatory Action: State of New Hampshire Department of State Bureau of Securities Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution, and undertaking · Fine: $20,000 · Begun Jan 7, 2026 · Resolved Jan 7, 2026 · Consent · Docket I-2025000057

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the state of New Hampshire department of state , BUREAU of securities regulation (BUREAU) alleged that, from April 30, 2020 to April 30,2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act.

    On January 7, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the bureau regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of N.H. Rev. Stat. Ann. 421-b of the New Hampshire uniform Securities Act,to provide restitution to affected New Hampshire customers in an amount of no less than $14,755.02, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

27. Jan 5, 2026
    Regulatory Action: Securities Division of the Mississippi Secretary of State Office FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution, and undertaking · Fine: $20,000 · Begun Jan 5, 2026 · Resolved Jan 5, 2026 · Consent

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the securities division of the office of the Mississippi secretary of state (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 75-71-412(d)(9) of the Mississippi Securities Act

    On January 5, 2026, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 75-71-412(d)(9) of the Mississippi Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 75-71-412(d)(9) of the Mississippi Securities Act, to provide restitution to affected Mississippi customers in an amount of no less than $25,095.18, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

28. Dec 24, 2025
    Regulatory Action: Minnesota Department of Commerce FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution, and undertaking · Fine: $20,000 · Begun Dec 24, 2025 · Resolved Dec 24, 2025 · Consent · Docket 99067

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Minnesota Department of Commerce (department) alleged that, from April 30, 2020 to April 30,2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act.

    On December 24,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of minn. State. CH 80a and minn state. 45.027 (2024) Minnesota Securities Act, to provide restitution to affected Minnesota customers in an amount of no less than $51,658.27, to pay an administrative fine in the amount of $20,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

29. Dec 19, 2025
    Regulatory Action: Texas State Securities Board FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, censure, restitution and undertaking · Fine: $25,000 · Begun Dec 19, 2025 · Resolved Dec 19, 2025 · Consent · Docket ORDER NO. LID-25-CAF-02

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Texas State Securities Board (board) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Texas Securities Act, tex. Gov't code 4001.001-4008.105.

    On December 19,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the board regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Texas Securities Act, tex. Gov't code 4001.001-4008.105. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 115.10(a) the Texas Securities Act, to provide restitution to affected Texas customers in an amount of no less than $146,235.88, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

30. Nov 12, 2025
    Regulatory Action: Ohio Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Nov 12, 2025 · Resolved Nov 12, 2025 · Consent · Docket 25-016

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Ohio Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL)charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of Ohio revised code 1707.19(a)(1)(I)('the act") and the regulations promulgated thereunder at O.A.C. 1301:6-3 (the regulations).

    On November 12, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of Ohio revised code 1707.19(a)(1)(I). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of Ohio revised code 1707.19(a)(1)(I), to provide restitution to affected Ohio customers in an amount of no less than $83,284.52, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

31. Nov 10, 2025
    Regulatory Action: Alabama Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,000 · Begun Nov 10, 2025 · Resolved Nov 10, 2025 · Consent · Docket CO-2025-0028

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Alabama Securities Commission (commission) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation title 8, chapter 6, code of 1975, the Alabama Securities Act (the act) and the regulations promulgated thereunder at chapter 830-X1, et seq. (The regulations).

    On November 10, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the commission regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the act and regulations, to provide restitution to affected Alabama customers in an amount of no less than $32,983.40, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

32. Nov 6, 2025
    Regulatory Action: Securities Division of the New Mexico Regulation and Licensing Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Nov 6, 2025 · Resolved Nov 6, 2025 · Consent · Docket MX23-7-10-3

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Securities Division of the New Mexico Regulation and Licensing Department (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL)charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the New Mexico uniform Securities Act, (nmsa 1978 58-13C-412(c)(9)(the act).

    On November 6, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 58-13C-412(c)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the act, to provide restitution to affected New Mexico customers in an amount of no less than $7,923.15, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

33. Nov 5, 2025
    Regulatory Action: Commissioner of Securities and Office of the Insurance, Montana State Auditor FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $25,000 · Begun Nov 5, 2025 · Resolved Nov 5, 2025 · Consent · Docket SEC-2025-58B

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Montana Commissioner of securities and insurance (Commissioner) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation the Securities Act of Montana, mon. Code ann. Title 30, chapter 10 parts 1-3 (Securities Act) and the regulations promulgated thereunder at admin rules of Montana, chapter 6.10, subchapters 1-7 (regulations).

    On November 5, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Securities Act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Securities Act, to provide restitution to affected Montana customers in an amount of no less than $16,711.73, to pay an administrative fine in the amount of $25,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

34. Oct 27, 2025
    Regulatory Action: Alaska Division of Banking and Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Oct 27, 2025 · Resolved Oct 27, 2025 · Consent · Docket 25-69-S

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Alaska Division of Banking and Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Alaska Securities Act, Alaska statue 45.56 et seq. (The act).

    On October 23, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 45.56.440(d)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desistfrom conduct in violation of section 45.56.440(d)(9) of the act, to provide restitution to affected Alaska customers in an amount of no less than $3,298.02, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

35. Oct 23, 2025
    Regulatory Action: Utah Division of Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Oct 23, 2025 · Resolved Oct 23, 2025 · Stipulation and Consent · Docket SD-25-0025

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Utah Division of Securities (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the Utah uniform Securities Act, Utah code ann. Section 61-1-1 et seq (the act) and the regulations promulgated thereunder.

    On October 23, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desistfrom conduct in violation of section 61-1-6(2)(a)(II)(j) of the act, to provide restitution to affected Utah customers in an amount of no less than $18,174.47, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

36. Oct 21, 2025
    Regulatory Action: West Virginia Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Oct 21, 2025 · Resolved Oct 21, 2025 · Consent · Docket 25-0058

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the West Virginia Securities Commission (commission) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the West Virginia uniform Securities Act, w.va. Code section 32-1-101 et seq. (The act) and the regulations promulgated thereunder.

    On October 21,2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the commission regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of w.va. Code section 3-2-204(a)(2)(j) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of w.va. Code section 3-2-204(a)(2)(j) of the act, to provide restitution to affected West Virginia customers in an amount of no less than $10,306.73, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

37. Oct 16, 2025
    Regulatory Action: South Dakota Division of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $20,000 · Begun Oct 16, 2025 · Resolved Oct 16, 2025 · Consent · Docket SD 25-30384

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the South Dakota Division of Insurance (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of the South Dakota uniform Securities Act of 2022,SDLC CH.47-31B('the act") and the regulations promulgated thereunder at ARSD20:08.

    On October 16, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of section 47-31B-412(d)(9) of the act. Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of section 47-31B-412(d)(9) of the act, to provide restitution to affected South Dakota customers in an amount of no less than $9,779.75, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. The administrative fine and restitution will be paid inaccordance with the terms of the consent order.

38. Oct 13, 2025
    Regulatory Action: Arkansas Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; censure; cease and desist; and undertakings. · Fine: $20,000 · Begun Oct 13, 2025 · Resolved Oct 13, 2025 · Consent · Docket S-25-0019

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Arkansas Securities Department (department) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ark. Code ann. Section 23-42-301(f)(1).

    On October 13, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ark. Code ann. Section 23-42-301(f)(1). Without admitting or denying the statement of facts or violation of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of the Arkansas Securities Act's supervision requirement for broker-dealers, to provide restitution to affected Arkansas customers in an amount of no less than $30,825.89, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.

39. Oct 7, 2025
    Regulatory Action: Pennsylvania Department of Banking and Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; censure; cease and desist; and undertakings. · Fine: $20,000 · Begun Oct 7, 2025 · Resolved Oct 7, 2025 · Consent · Docket 250033(SEC-CAO)

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Pennsylvania Department of Banking and Securities (department) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 70 P.S. Section 1- 305(a)(VII).

    On October 7, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the department regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of 70 P.S. Section 1-305(a)(VII). Without admitting or denying the statement of facts or violation of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of the Pennsylvania Securities Act of 1972, to provide restitution to affected Pennsylvania customers in an amount of no less than $111,354.16, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.

40. Oct 6, 2025
    Regulatory Action: Oregon Division of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; censure; cease and desist; and undertakings. · Fine: $20,000 · Begun Oct 6, 2025 · Resolved Oct 6, 2025 · Consent · Docket S-25-0036

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Oregon Division of Financial Regulation (division) alleged that, from April 30, 2020, to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ors section 59.205(13) and oar section 441-205-0210(1).

    On October 6, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020, to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of ors section 59.205(13) and oar section 441-205-0210(1). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from further conduct in violation of ors 59.205(13), to provide restitution to affected Oregon customers in an amount of no less than $31,526.08, to pay an administrative fine in the amount of $20,000, and to comply with certain undertakings. LPL will pay the administrative fine and restitution in accordance with the terms of the consent order.

41. Jun 5, 2025
    Regulatory Action: Massachusetts Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Restitution; censure; cease and desist; and undertakings. · Fine: $25,000 · Begun Jun 5, 2025 · Resolved Jun 5, 2025 · Consent · Docket E-2025-0189

    In connection with an investigation conducted by a multistate task force coordinated among certain members of the north american securities administrators association (NASAA), the Massachusetts Securities Division (division) alleged that, from April 30, 2020 to April 30, 2025, LPL Financial LLC (LPL) charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of mass. Gen. Laws c. 110a, section 204(a)(2) (j).

    On June 5, 2025, in connection with an investigation conducted by a multistate task force coordinated among certain members of nasaa, LPL entered into a consent order with the division regarding allegations that, from April 30, 2020 to April 30, 2025, LPL charged unreasonable commissions to retail customers in excess of five percent of the principal amount on certain small principal equity transactions, in violation of mass. Gen. Laws c. 110a, section 204(a)(2)(j). Without admitting or denying the statement of facts or violations of law, LPL agreed to the imposition of a censure, to cease and desist from conduct in violation of the Massachusetts uniform Securities Act and the regulations thereunder, to provide restitution to affected Massachusetts customers in an amount of no less than $47,422.32, to pay an administrative fine in the amount of $25,000 and to comply with certain undertakings. The administrative fine and restitution will be paid in accordance with the terms of the consent order.

42. Apr 29, 2025
    Regulatory Action: South Dakota Division of Insurance, Department of Labor and Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $35,000 · Begun Apr 29, 2025 · Resolved Apr 29, 2025 · Consent · Docket 1019070

    The South Dakota Division of Insurance, Department of Labor and Regulation (the "division") alleged that LPL Financial LLC ("LPL") violated: SDCL 47-31B-411 and FINRA rule 4511 in connection with an alleged failure by LPL and its agents to maintain accurate books and records; arsd 20:08:03:08 and FINRA rule 3110(a) and (b) in connection with its alleged failure to establish, maintain, and enforce an adequate supervisory system; and arsd 20:08:03:08 and FINRA rule 2010 in connection with its agents' alleged use of their own e-mail addresses in place of the clients' and signing client documents on the clients' behalf.

    On April 29, 2025, LPL entered into a consent order with the division regarding allegations that it violated SDCL 47-31B-411 and FINRA rule 4511 in connection with an alleged failure by LPL and its agents to maintain accurate books and records; arsd 20:08:03:08 and FINRA rule 3110(a) and (b) in connection with its alleged failure to establish, maintain, and enforce an adequate supervisory system; and arsd 20:08:03:08 and FINRA rule 2010 in connection with its agents' alleged use of their own e-mail addresses in place of the clients' and signing client documents on the clients' behalf. LPL agreed to a monetary penalty in the amount of $35,000. The monetary penalty will be paid in accordance with the terms of the consent order.

43. Mar 20, 2025
    Regulatory Action: State of New Hampshire, Department of State, Bureau of Securities Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist, undertaking, investigation costs · Fine: $325,000 · Begun Mar 20, 2025 · Resolved Mar 20, 2025 · Order · Docket C2024-00025

    The State of New Hampshire, Department of State, Bureau of Securities Regulation (the "bureau") alleged that LPL Financial LLC ("LPL") violated N.H. Rsa 421-b:4-406(k) in connection with allegations that from December 2018 to August 2021, a registered representative at LPL used an unapproved messaging platform to communicate with clients and prospective clients relating to his securities business.

    On March 20, 2025, LPL entered into a consent order with the bureau regarding allegations that it violated N.H. Rsa 421-b:4-406(k) in connection with allegations that from December 2018 to August 2021, a registered representative at LPL used an unapproved messaging platform to communicate with clients and prospective clients relating to his securities business. Without admitting or denying the facts or allegations, LPL agreed to (1) cease and desist from violating the rules and laws regarding preservation of records of customer communications as required by FINRA rule 4511 and SEC rule 240.17A-4, pursuant to N.H. Rsa 421-b:4-406(k), (2) comply with certain undertakings, and (3) payment of an administrative fine in the amount of $325,000 plus investigation costs in the amount of $25,000. The administrative fine and investigation costs were paid in accordance with the terms of the consent order.

44. Mar 6, 2025
    Regulatory Action: Commonwealth of Pennsylvania, Department of Banking and Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $55,000 · Begun Mar 6, 2025 · Resolved Mar 6, 2025 · Order · Docket 250007

    The Pennsylvania department of banking and securities (the "department") alleged that LPL Financial LLC ("LPL") violated section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972 in connection with allegations that from June 2023 to September 2024, LPL did not register one of its representatives as an investment adviser representative in Pennsylvania.

    On March 6, 2025, LPL entered into a consent agreement and order with the department regarding allegations that LPL violated section 301(C.1)(1)(II) of the Pennsylvania Securities Act of 1972 in connection with allegations that from June 2023 to September 2024, LPL did not register one of its representatives as an investment adviser representative in Pennsylvania. Without admitting or denying the allegations, LPL agreed to (1) comply with the Pennsylvania Securities Act of 1972, including section 301(C.1)(1)(II), and (2) pay an administrative assessment in the amount of $55,000.

45. Jan 17, 2025
    Regulatory Action: SEC FinalSanctions: Cease and Desist; Censure, monetary fine, undertaking · Fine: $18.0M · Begun Jan 17, 2025 · Resolved Jan 17, 2025 · Decision & Order of Offer of Settlement · Docket 3-22422

    On January 17, 2025, the U.S. Securities and Exchange Commission ("SEC") issued a settled administrative order in which it found that LPL Financial LLC ("LPL") willfully violated section 17(a) of the Securities Exchange Act of 1934 (the "Exchange Act") and rule 17A-8 thereunder. Specifically, the order found that from at least May 2019 to December 2023 (the "relevant period"), LPL did not follow its anti-money laundering ("AML") policies and procedures regarding its customer identification program ("CIP") and ongoing customer due diligence obligations by, among other things, not properly verifying new accounts; not timely closing accounts that did not pass its CIP screening measures; and not closing or restricting certain accounts that were prohibited under LPL's AML policies. In determining to accept LPL's offer of settlement, the SEC considered remedial acts promptly undertaken by LPL, including LPL's engagement of a compliance consultant and proactive implementation of the consultant's recommendations.

    The allegations, disposition, findings, and sanctions of the order are described in items 7 and 12. Paid fine on January 23, 2025.

46. Dec 20, 2024
    Regulatory Action: SEC FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Cease and desist and censure · Fine: $900,000 · Begun Dec 20, 2024 · Resolved Dec 20, 2024 · Order · Docket 3-22374

    The Securities and Exchange Commission alleged that LPL (1) willfully violated section 17(a)(1) of the Securities Exchange Act of 1934 (the "Exchange Act") and rule 17A-4(j) by failing to furnish promptly true and complete electronic blue sheet ("EBS") information as requested by the SEC staff from at least July 2018 through May 2021, and (2) willfully violated Exchange Act rule 17A-25 by failing to submit electronically certain securities transaction information to the SEC through the EBS systems in response to requests made by the SEC.

    On December 20, 2024, LPL entered into a settlement order with the SEC settling an administrative action which found that LPL (1) willfully violated section 17(a)(1) of the Exchange Act and rule 17A-4(j) by failing to furnish promptly true and complete electronic blue sheet ("EBS") information as requested by the SEC staff from at least July 2018 through May 2021, and (2) willfully violated Exchange Act rule 17A-25 by failing to submit electronically certain securities transaction information to the SEC through the EBS systems in response to requests made by the SEC. LPL engaged in voluntary remedial efforts concerning its EBS systems and control environment. In determining to accept LPL's offer of settlement, the SEC considered remedial acts promptly undertaken by LPL and cooperation afforded the SEC staff. LPL admitted to the facts set forth in the order, acknowledged that its conduct violated the federal securities laws and agreed to the imposition of a censure, a cease and desist from committing or causing any violations and future violations of these rules and to pay a civil monetary penalty in the amount of $900,000. The civil monetary penalty was paid in accordance with the terms of the settlement order.

47. Dec 20, 2024
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure · Fine: $900,000 · Begun Dec 20, 2024 · Resolved Dec 20, 2024 · Acceptance, Waiver & Consent(AWC) · Docket 2020067449801

    The Financial Industry Regulatory Authority ("FINRA") alleged that LPL submitted certain blue sheets to FINRA that inaccurately reported one or more of 12 types of transaction information in violation of FINRA rules 8211, 8213 and 2010.

    On December 20, 2024, LPL entered into an AWC with FINRA which alleged that LPL submitted certain blue sheets to FINRA that inaccurately reported one or more of 12 types of transaction information in violation of FINRA rules 8211, 8213 and 2010. Without admitting or denying the findings, LPL agreed to the imposition of a censure and to pay a fine in the amount of $900,000. The fine was paid in accordance with the terms of the AWC.

48. Aug 14, 2024
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $50.0M · Begun Aug 14, 2024 · Resolved Aug 14, 2024 · Order · Docket 3-22006

    The Securities and Exchange Commission ("commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted against LPL Financial LLC ("LPL" or "respondent"). In anticipation of the institutionof these proceedings, respondent has submitted an OFFER of settlement ("OFFER") that the commission has determined to accept. The commission finds that from at least June 2019 (the"relevant period"), LPL personnel sent and received off-channel communications that were records required to be maintained under Exchange Act rule 17A-4(b)(4) and/or advisers actrule 204-2(a)(7). Respondent did not maintain or preserve the substantial majority of these written communications. Respondent's failures were firm-wide, including financial advisors who, together with other personnel they supervised, were responsible for generating some of the highest levels of revenue for LPL during a time period within the relevant period. LPL'SWIDESPREAD failure to implement a system reasonably expected to determine whether personnel were following its policies and procedures that prohibit off-channel communications led to its failure to reasonably supervise its personnel. During the relevant period, LPL received and responded to commission subpoenas for documents and/or records requests in a number of commission investigations. As a result, LPL's recordkeeping failures likely impacted the commission's ability to carry out its regulatory functions and investigate violations of the federal securities laws across these investigations. Commission staff found LPL's misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at investment advisers. LPL has initiated a review of its recordkeeping failures and begun a program of remediation. As a result of its conduct, the firm willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7) thereunder; failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons'aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act.

    As a result of its conduct, the firm willfully violated section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder and section 204 of the Advisers Act and rule 204-2(a)(7)there under; failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 17(a) of the Exchange Act and rule 17A-4(b)(4) thereunder, within the meaning of section 15(b)(4)(e) of the Exchange Act; and failed reasonably to supervise its personnel, with a view to preventing or detecting certain of its supervised persons' aiding and abetting violations of section 204 of the Advisers Act and rule 204-2(a)(7) thereunder, within the meaning of section 203(e)(6) of the Advisers Act. Accordingly, it is hereby ordered that the firm cease and desist from committing or causing any violations and any future violations of section 17(a) of the Exchange Act and rule 17A-4 thereunder and section 204 of the Advisers Act and rule 204-2 thereunder; is censured; shall comply with the undertakings enumerated in the order; and shall pay a civil money penalty in the amount of $50,000,000 to the SEC. the firm paid the fine in full on 08/27/2024.

49. Dec 27, 2023
    Regulatory Action: FINRA FinalFine: $5.5M · Begun Dec 27, 2023 · Resolved Dec 27, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2017052494701

    The Financial Industry Regulatory Authority (FINRA) alleged that LPL Financial LLC (the firm) failed to supervise the activities of its representatives that was reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to transactions its representatives placed directly with product sponsors (direct business transactions) on behalf of firm customers, in violation of FINRA rules 3110, 4511 and 2010, NASD rule 3010(a), section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and Exchange Act rules 15I-1 and 17A-3. The findings stated that from January 2012 to August 2019, the firm did not have a reasonable system to ensure direct business transactions appeared on the daily trade blotter in order for those transactions to be ingested into the firm's exception reports to identify potential sales practice violations and that its representatives collected relevant information regarding direct business customers' investment profiles for making suitability determinations. In addition, the findings stated that from February 2016 through June 2020, the firm sent to certain customers switch letters that contained inaccurate information about sales charges associated with switching from one security to another and a certain supervisory tool utilized in reviewing the suitability of switch transactions did not include sales charge information for certain products. The findings also stated that from May 2017 to November 2022, an electronic tool utilized by supervisors in the review of transactions in listed business development companies (BDCS) did not reasonably alert supervisors of potentially overconcentrated investments in listed BDCS to certain customers.

    Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm consented to the imposition of a censure, a monetary fine in the amount of $5,500,000, payment of customer restitution in the amount of $651,374.51, plus interest, and an undertaking related to the issues contained in the AWC involving listed BDCS

50. Oct 3, 2023
    Regulatory Action: Massachusetts Securities Division FinalSanctions: Censure; Compliance; administrative fine · Fine: $250,000 · Begun Oct 3, 2023 · Resolved Oct 3, 2023 · Consent · Docket E-2022-0055

    Improper use of electronic signatures and failure to exercise appropriate supervision of an LPL branch office.

51. Aug 10, 2023
    Regulatory Action: Pennsylvania Department of Banking and Securities FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $190,000 · Begun Aug 10, 2023 · Resolved Aug 10, 2023 · Order · Docket 230028

    Without admitting or denying the allegations, the firm consented to the sanctions and to the entry of findings that from January 2018 until June 2023, LPL failed to register at least one of its representatives as an investment adviser representative in Pennsylvania

52. Jul 25, 2023
    Regulatory Action: FINRA FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Censure, restitution, undertaking · Fine: $3.0M · Begun Jul 25, 2023 · Resolved Jul 25, 2023 · Acceptance, Waiver & Consent(AWC) · Docket 2020067897601

    The Financial Industry Regulatory Authority (FINRA) alleged that LPL Financial LLC (the firm) failed to establish and maintain a system to supervise the activities of its representatives that was reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to the transmittal of customer funds by wire or check to third parties, responding reasonably to red flags of potential conversion and detecting possible instances of forgery or falsification of electronic signatures, in violation of FINRA rules 3110, 4511 and 2010, section 17(a) of the Securities Exchange Act of 1934 (Exchange Act) and Exchange Act rule 17A-3.

    From May 2018 to August 2020, FINRA alleged that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with applicable securities laws and regulations, and with applicable FINRA rules, related to the transmittal of customer funds by wire or check to third parties and responding reasonably to red flags of potential conversion by two former representatives, in violation of FINRA rules 3110 and 2010. In addition, from January 2018 to January 2022, the firm failed to have a supervisory system reasonably designed to detect possible instances of forgery or falsification by its representatives related to electronic signatures, in violation of FINRA rules 3110, 4511 and 2010, section 17(a) of the Exchange Act" and Exchange Act rule 17A-3. Without admitting or denying the findings and without adjudication of any issue of law or fact, the firm consented to the imposition of a censure, a monetary fine in the amount of $3,000,000, payment of customer restitution in the amount of $100,000, plus interest, and an undertaking.

53. Dec 7, 2022
    Regulatory Action: FINRA FinalFine: $150,000 · Begun Dec 7, 2022 · Resolved Dec 7, 2022 · Acceptance, Waiver & Consent(AWC) · Docket 2020067764002

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to investigate red flags related to a registered representative's undisclosed outside business activities (OBAS). The findings stated that the firm failed to reasonably supervise transfers of funds by the representative's firm customers to third parties. In total, the representative caused five firm customers to transfer over $650,000 to a purported investment advisory firm or to accounts held at a third-party custodian for which the purported investment advisory firm was the advisor, after which the funds were converted by a third party.

54. Sep 28, 2022
    Regulatory Action: State of Texas FinalSanctions: Other; Consent order, fine, and restitution offer · Fine: $125,000 · Begun Sep 28, 2022 · Resolved Sep 28, 2022 · Settled · Docket IC22-CAF-02

    During the period 2016 through 2019, respondent failed to enforce its written supervisory procedures relating to its prohibition on retail communications regarding structured notes because respondent's e-mail surveillance tool was not designed to flag e-mails sent to more than twenty-five individuals in a thirty-day period when those individuals were included only by blind carbon copy (BCC). Accordingly, a former agent of respondent solicited sales of over $65,000,000 in structured notes using blast e-mails to generate interest in the product. Respondent also failed to enforce its written supervisory procedures that sales of products be suitable, since certain investors had limited investment experience and invested over 40% of their investable assets in the notes.

55. Aug 11, 2022
    Regulatory Action: FINRA FinalFine: $300,000 · Begun Aug 11, 2022 · Resolved Aug 11, 2022 · Acceptance, Waiver & Consent(AWC) · Docket 2020068870301

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to accurately calculate its customer reserve requirement and failed to maintain a sufficient customer reserve. The findings stated that the firm's customer reserve calculations excluded customer checks that the firm had received but not yet processed for deposit. As a result, the firm failed to make sufficient deposits in its customer reserve account, causing two hindsight deficiencies that totaled approximately $162 million. The findings also stated that the firm failed to establish and maintain a supervisory system reasonably designed to achieve compliance with the Securities Exchange Act of 1934 and FINRA rules concerning the customer reserve requirement. First, the firm's written procedures were not reasonably designed to ensure that undeposited customer checks would be included in the firm's customer reserve calculations. The procedures failed to specify how to handle customer checks that had been received but had not yet been processed for deposit. They also lacked any information about the requirement to include undeposited customer checks in the reserve calculation on the date the checks are received. Second, the firm's supervision of its employees' handling of undeposited customer checks was unreasonably designed to exclude undeposited customer checks from its customer reserve calculation on the date the checks were received. The business unit within the firm that received and processed customer checks prepared a daily report that the firm used to calculate its customer reserve requirement. However, that report did not include customer checks that the firm had received but not yet processed for deposit. The firm did not take any other steps to ensure that those checks were included in the customer reserve calculation on the date they were received. Two months after the firm discovered the hindsight deficiencies, it commenced steps to revise its relevant supervisory procedures. The findings also included that the firm failed to maintain accurate books and records and filed inaccurate financial and operational combined uniform single (FOCUS) reports. By improperly calculating its customer reserve requirements, the firm created and maintained inaccurate books and records concerning its customer reserve. In addition, the firm filed at least 17 monthly FOCUS reports that did not accurately reflect the amount of the firm's customer reserve obligation.

56. Dec 20, 2021
    Regulatory Action: FINRA FinalSanctions: Other · Begun Dec 20, 2021 · Resolved Dec 20, 2021 · Acceptance, Waiver & Consent(AWC) · Docket 2019062530101

    Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise registered representatives' recommendations to customers that they rollover 529 savings plan investments from one state plan to another. The findings stated that the firm sold 529 plans that offered sales charge waivers or class ar shares when a customer held class a shares in one state-sponsored 529 plan but decided to roll over the shares into another state's 529 plan. However, the firm did not establish and maintain a system to determine that the waivers were applied to each eligible transaction or that eligible customers received class ar shares. Specifically, the firm had no policies or procedures to identify those 529 plans that offered rollover sales charge waivers or class ar shares. The firm failed to adequately notify and train its representatives regarding the availability of sales charge waivers and class ar shares. Likewise, the firm failed to adopt any controls to detect instances in which it did not provide customers with available waivers or class ar shares in connection with eligible rollovers. As a result, the firm failed to apply available sales charge waivers or recommend class ar shares to thousands of transactions with an aggregate principal value of approximately $28 million, which resulted in the firm overcharging customers $982,354 in front-end sales charges.

    On October 8, 2021, without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system reasonably designed to supervise registered representatives' recommendations to customers that they rollover 529 savings plan investments from one state plan to another. As a result, the firm failed to apply available sales charge waivers or recommend class ar shares to thousands of transactions with an aggregate principal value of approximately $28 million, which resulted in the firm overcharging customers $982,354 in front-end sales charges. The firm was censured and ordered to pay $982,354, plus interest, in restitution to customers. The firm voluntarily self-reported potential issues with its supervisory system to FINRA. Accordingly, no monetary sanction has been imposed.

57. Dec 3, 2021
    Regulatory Action: Connecticut FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $350,000 · Begun Dec 3, 2021 · Resolved Dec 3, 2021 · Consent · Docket CO-21-201911026-S

    The consent order alleged that the firm violated section 36B-31-6F of the regulations under the Connecticut uniform Securities Act by failing to enforce its supervisory procedures with regard to two former agents of the firm, Connecticut residents james thomas booth (CRD number 1906145) and matthew o. Clason (CRD number 4692266). Booth allegedly misappropriated approximately $1.1 million from his LPL Financial LLC clients, and plead guilty to one count of securities fraud in federal court (United States v. james t. Booth, crim. No. 19-CR-00699-JGK (S.D.N.Y.)). On November 17, 2020, booth was sentenced to a 42-month prison term. Booth's conduct also involved generating consolidated client account statements with fictitious investments and sending those statements to clients in an effort to deceive clients about the value of their accounts. Booth had been the subject of a June 18, 2020 order issued by the commissioner revoking booth's registration as a broker-dealer agent and investment adviser agent and fining booth $100,000, a penalty amount that remains unpaid. The revocation was uncontested. The consent order acknowledged that LPL Financial LLC had entered into settlements with those firm clients who were affected by booth's scheme, and that the firm had repaid those clients a total of $1,636,347.07. Clason purportedly opened a joint bank account with an LPL Financial, LLC customer without the firm's knowledge, then transferred approximately $668,000 from the customer's investment accounts (approx $365,000 from her outside RIA investment account, and $253,000 from her brokerage annuity contracts) to the joint account. Clason then proceeded to withdraw at least $620,000 from the joint account for his personal use without the customer's knowledge or consent. On May 12, 2021, in connection with the foregoing conduct, clason plead guilty to one count of wire fraud in federal court (United States v. matthew o. Clason, crim. No. 3:21-CR-00066 (d. Conn)). Clason was sentenced on December 6, 2021, to 30 months imprisonment. The LPL Financial LLC customer affected by clason's conduct has since been fully compensated through a February 25, 2021 settlement involving the firm and other parties. LPL Financial, LLC contributed $500,000 to that settlement.

58. Sep 30, 2021
    Regulatory Action: SEC FinalSanctions: Cease and Desist · Fine: $750,000 · Begun Sep 30, 2021 · Resolved Sep 30, 2021 · Order · Docket 3-20612

    The Securities and Exchange Commission ("commission") deems it appropriate and in the public interest that public administrative and cease-and-desist proceedings be, and hereby are, instituted pursuant to section 8a of the Securities Act of 1933 ("Securities Act"), sections 15(b) and 21c of the Securities Exchange Act of 1934 ("Exchange Act"), and sections 203(e) and 203(k) of the Investment Advisers Act of 1940 ("Advisers Act") against LPL Financial LLC ("respondent" or "LPL"). The commission finds that these proceedings arise out of respondent's failure to verify and respond to conflicting information when it opened a customer account and processed wire transfers at the request of eugenio GARCIA jimenez, JR. ("GARCIA"). As alleged in the commission's December 1, 2020 complaint against GARCIA, he acted as an unregistered investment adviser and misappropriated $7.1 million of taxpayer funds from the municipio autÓnomo de mayagÜez, Puerto Rico ("the city") over the course of seven months in 2016. The city entrusted GARCIA to provide advice and carry out his promised strategy to invest $9 million of city funds such that they had principal protection and 8-10% returns. After misappropriating $4.1 million of the city's funds through an account at brokerage firm 1, GARCIA approached LPL in April 2016 to open an investment account. During its review before opening the account, LPL failed to comply with its customer identification program procedures and, despite various individuals in different departments questioning the account's beneficial ownership, source of funds, and reason for transfer from the brokerage firm 1, GARCIA opened an account controlled by him at LPL in June 2016. LPL subsequently processed wire transfers that GARCIA requested. In the less than one month before LPL froze (and later liquidated) the account, GARCIA was able to misappropriate an additional $3.1 million of city funds. Through certain failures, LPL was a cause of GARCIA's violations of Securities Act sections 17(a)(2) and (3) and Advisers Act section 206(2), which prohibit fraudulent conduct in the offer or sale of securities and upon any client or prospective investment advisory client. Further, LPL willfully violated Exchange Act section 17(a) and rule 17A-8 thereunder, which require broker-dealers to comply with reporting, record keeping and record retention requirements in regulations implemented under the Bank Secrecy Act, including the customer identification program rule (31 C.F.R. § 1023.22, the "cip rule").

    Respondent has submitted an offer of settlement, which the commission has determined to accept. Respondent willfully violated section 17(a) of the Exchange Act and rule 17A-8 thereunder and was a cause of garcia's violations of sections 17(a)(2) and (3) of the Securities Act and section 206(2) of the Advisers Act. Accordingly, it is hereby ordered that the respondent cease and desist from committing or causing any violations, and any future violations, of section 17(a) of the Exchange Act and rule 17A-8 thereunder, sections 17(a)(2) and (3) of the Securities Act, and section 206(2) of the Advisers Act; is censured; and shall pay disgorgement of $114,318, prejudgment interest of $26,884, and a civil money penalty of $750,000 to the commission. LPL has paid $4.1m restitution and have completed everything required.

59. Dec 31, 2020
    Regulatory Action: FINRA FinalFine: $6.5M · Begun Dec 31, 2020 · Resolved Dec 31, 2020 · Acceptance, Waiver & Consent(AWC) · Docket 2018059192701

    Without admitting or denying the findings, LPL Financial LLC ("the firm") consented to the sanctions and to the entry of findings that it failed to establish and maintain a supervisory system, including written procedures, reasonably designed to achieve compliance with regulatory obligations including record retention, fingerprinting and screening of associated persons, and supervision of consolidated reports. The findings stated that, among other things, the firm failed to retain electronic records in the required format, preserve certain electronic records, and notify FINRA prior to employing electronic storagemedia, in violation of section 17(a) and rule 17A-4 of the Securities Exchange Act of 1934. The firm's failure affected at least 87 million records and led to the permanent deletion of over 1.5 million customer communications maintained by a third-party data vendor. Further, the firm failed to send account notices that are required to be sent to customers at 36-month intervals for each account in which a suitability determination had been made. The findings also stated that the firm failed to fingerprint non- registered associated persons and thus failed to screen these persons for statutory disqualification based on criminal convictions. This failure arose from the firm's failure to maintain a reasonable supervisory system and procedures to identify and properly screen all persons who became associated with the firm in a non-registered capacity. The firm has not created or maintained required fingerprint records for the persons that it failed to fingerprint. Separately, the firm permitted a non- registered associated person, who was subject to statutory disqualification, to remain associated with the firm. The firm obtained fingerprints for the person, submitted them to FINRA for processing and received a notice from FINRA stating that the person had been convicted of a misdemeanor for possession of a forged instrument, and was therefore subject to disqualification. The findings also included that the firm failed to establish and maintain a supervisory system reasonably designed to supervise certain consolidated reports. The firm was not aware of, and therefore failed to reasonably supervise, certain tools that its approved third-party vendors provided to the firm's registered representatives to create and disseminate consolidated reports. In particular, the firm's vendors created non-finalized consolidated reports, which, although intended for internal use, could be sent to customers. Nonetheless, the vendors did not send such reports to the firm and it therefore did not review them. The firm's vendors also allowed representatives and customers to directly access consolidated reports on the vendors' websites, and the firm did not receive or review consolidate dreports that its representatives disseminated in this manner. The firm also failed to review assets that were manually entered by representatives on consolidated reports when the representatives categorized them as non-securities related, even when the manually entered assets were evidently securities related. A former registered representative of the firm exploited these supervisory deficiencies in perpetrating a ponzi scheme through which he converted at least $1,000,000 of the firm's customers' money. The former representative provided some of his customers with direct access to the website of one of the approved third-party vendors, where they were able to access consolidated reports that contained fictitious, manually added assets. The former representative also directly accessed the

60. Nov 23, 2020
    Regulatory Action: South Dakota Division of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,000 · Begun Nov 23, 2020 · Resolved Nov 23, 2020 · Order · Docket N/A

    The South Dakota Division of Insurance ("division") alleged LPL Financial LLC ("LPL") established two accounts in restricted status without adequate permission, in violation of SDCL 47-31B-412(d)(9).

61. Jul 30, 2020
    Regulatory Action: New Hampshire Bureau of Securities Regulation FinalSanctions: Cease and Desist; Restitution and cost of investigation. · Fine: $400,000 · Begun Jul 30, 2020 · Resolved Jul 30, 2020 · Order · Docket I-2019000029

    The New Hampshire Bureau of Securities Regulation ("BUREAU") conducted an investigation against representative, daniel stokes, involving solicitation of unsecured promissory notes from LPL clients for a purported investment opportunity, which did not occur on LPL systems. The BUREAU concluded MR. stokes defrauded investors in furtherance of the false investment opportunity. In connection with this investigation, the BUREAU determined LPL Financial LLC failed to reasonably supervise MR. stokes, in violation of N.H. Rsa 421-b:4-412(d)(9).

62. Jan 8, 2020
    Regulatory Action: Ohio Department of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $3,000 · Begun Jan 8, 2020 · Resolved Jan 8, 2020 · Order · Docket N/A

    The Ohio Department of Insurance ("department") found LPL Financial LLC failed to timely report administrative actions to the department, in violation of section 3905.22(a) pursuant to title 39 of the revised code.

63. Dec 26, 2019
    Regulatory Action: FINRA FinalSanctions: Censure; Undertakings · Fine: $300,000 · Begun Dec 26, 2019 · Resolved Dec 26, 2019 · Acceptance, Waiver & Consent(AWC) · Docket 2018058621001

    During the relevant time periods of January 1, 2014 through September 30, 2018, LPL Financial LLC ("firm") did not establish reasonable systems or procedures related to the obligation to timely transfer control over the custodial property to the beneficiary of uniform transfers to minors act ("UTMA") accounts. As a result, UTMA account custodians authorized transactions in at least 5,249 UTMA accounts held at LPL in which the beneficiaries had reached the age of trust termination. Accordingly, the firm failed to establish and maintain a system, and establish, maintain, and enforce written supervisory procedures with respect to its uniform gift to minors act and/or UTMA accounts.

64. Aug 6, 2019
    Regulatory Action: Georgia Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Aug 6, 2019 · Resolved Aug 6, 2019 · Consent · Docket ENSC-190782

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Georgia Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Georgia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Georgia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

65. Jul 22, 2019
    Regulatory Action: West Virginia Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jul 22, 2019 · Resolved Jul 22, 2019 · Consent · Docket 18-0018

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the West Virginia Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in West Virginia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any West Virginia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

66. Jul 10, 2019
    Regulatory Action: Tennessee Department of Commerce and Insurance FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jul 10, 2019 · Resolved Jul 10, 2019 · Consent · Docket 19-016

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Tennessee Department of Commerce and Insurance (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Tennessee; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Tennessee statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

67. Jun 28, 2019
    Regulatory Action: Office of the Attorney General of the State of New York FinalSanctions: Other; Assurance of discontinuance; civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jun 28, 2019 · Resolved Jun 28, 2019 · Settled · Docket 19-067

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Attorney General of the State of New York (OAG) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; and certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the oag and LPL agreed that the assurance would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the oag and LPL agreed that nothing in the assurance is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the assurance is not intended to be a final order based upon violations of any jurisdiction's statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

68. Jun 26, 2019
    Regulatory Action: Massachusetts Securities Division FinalSanctions: Undertaking; Cease and desist, censure, civil and administrative fine · Fine: $1.1M · Begun Jun 26, 2019 · Resolved Jun 26, 2019 · Order · Docket E-2019-0041

    During the relevant time period of March 1, 2013 to April 4, 2019, the Massachusetts Securities Division found LPL failed to timely register with the division certain agents required to be registered in Massachusetts. LPL also failed to properly and timely amend forms U4 and U5 for agents who were registered in Massachusetts that subsequently became materially inaccurate or in complete.

69. Jun 13, 2019
    Regulatory Action: Iowa Insurance Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jun 13, 2019 · Resolved Jun 13, 2019 · Consent · Docket 98196

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Iowa Insurance Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Iowa; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Iowa statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

70. May 23, 2019
    Regulatory Action: Ohio Division of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun May 23, 2019 · Resolved May 23, 2019 · Consent · Docket 19-014

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Ohio Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Ohio; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Ohio statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

71. May 20, 2019
    Regulatory Action: Wyoming Secretary of State FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun May 20, 2019 · Resolved May 20, 2019 · Consent · Docket 18-04

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Wyoming Secretary of State alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Wyoming; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the Wyoming Secretary of State and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the Wyoming Secretary of State and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Wyoming statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

72. Apr 30, 2019
    Regulatory Action: New Jersey Bureau of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 30, 2019 · Resolved Apr 30, 2019 · Consent · Docket N/A

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the New Jersey Bureau of Securities (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Jersey; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Jersey statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

73. Apr 22, 2019
    Regulatory Action: Virginia State Corporation Commission FinalSanctions: Cease and Desist; Offers of restitution; undertakings · Fine: $499,000 · Begun Apr 22, 2019 · Resolved Apr 22, 2019 · Consent · Docket SEC-2018-00027

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Virginia State Corporation Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Virginia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Virginia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

74. Apr 16, 2019
    Regulatory Action: Alaska Division of Banking and Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 16, 2019 · Resolved Apr 16, 2019 · Consent · Docket 17-170-S

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Alaska Division of Banking and Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alaska statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

75. Apr 10, 2019
    Regulatory Action: Nebraska Department of Banking & Finance FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 10, 2019 · Resolved Apr 10, 2019 · Consent · Docket N/A

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Nebraska Department of Banking & Finance (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Nebraska; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Nebraska statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

76. Apr 10, 2019
    Regulatory Action: Texas State Securities Board FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 10, 2019 · Resolved Apr 10, 2019 · Consent · Docket IC19-CAF-01

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Texas State Securities Board (board) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Texas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the board and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the board and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Texas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

77. Apr 8, 2019
    Regulatory Action: Maine Office of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 8, 2019 · Resolved Apr 8, 2019 · Consent · Docket 2019-10/19-15384

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Maine Office of Securities (office) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Maine; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the office and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Maine statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

78. Apr 8, 2019
    Regulatory Action: North Carolina Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 8, 2019 · Resolved Apr 8, 2019 · Consent · Docket 17 SEC 053

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the North Carolina Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in North Carolina; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any North Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

79. Apr 5, 2019
    Regulatory Action: Office of the Commissioner of Securities and Insurance, Montana State Auditor FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 5, 2019 · Resolved Apr 5, 2019 · Consent · Docket SEC-2018-147

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Commissioner of Securities and Insurance, Montana State Auditor (CSI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Montana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the csi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the csi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Montana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

80. Apr 2, 2019
    Regulatory Action: Office of the Kansas Securities Commissioner FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Apr 2, 2019 · Resolved Apr 2, 2019 · Consent · Docket 19E079/2018-6509

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Office of the Kansas Securities Commissioner (KSC) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Kansas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the KSC and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the KSC and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Kansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

81. Mar 21, 2019
    Regulatory Action: Securities Division of the Office of the Attorney General of South Carolina FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Mar 21, 2019 · Resolved Mar 21, 2019 · Consent · Docket MATTER NO. 20181123

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the Office of the Attorney General of South Carolina (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in South Carolina; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

82. Mar 20, 2019
    Regulatory Action: Oregon Division of Financial Regulation FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 31, 2019 · Resolved Mar 20, 2019 · Consent · Docket CASE NO. S-18-0034

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Oregon Division of Financial Regulation (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Oregon; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Oregon statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

83. Mar 18, 2019
    Regulatory Action: Oklahoma Department of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Mar 18, 2019 · Resolved Mar 18, 2019 · Consent · Docket ODS FILE NO. 18-094

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Oklahoma Department of Securities (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Oklahoma; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Oklahoma statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

84. Mar 11, 2019
    Regulatory Action: SEC FinalSanctions: Other; N/a · Begun Mar 11, 2019 · Resolved Mar 11, 2019 · Order · Docket 3-19039

    The securities exchange commission ("commission") found that at times during the relevant period, LPL Financial LLC ("LPL") purchased, recommended, or held for advisory clients mutual fund share classes that charged 12B-1 fees instead of lower-cost share classes of the same funds for which the clients were eligible. LPL also failed to disclose in its form ADV or otherwise the conflicts of interest related to (a) its receipt of 12B-1 fees, and/or (b) its selection of mutual fund share classes that pay such fees. As a result of this aforementioned conduct, it was determined LPL willfully violated sections 206(2) and 207 of the Advisers Act.

    LPL submitted an offer of settlement which the commission accepted. In view of the foregoing, the commission deemed it appropriate in the public interest to impose the sanctions agreed to in LPL's offer. LPL 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, the order and LPL's offer are based on the information LPL self-reported.

85. Mar 11, 2019
    Regulatory Action: Minnesota Department of Commerce FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Mar 11, 2019 · Resolved Mar 11, 2019 · Consent · Docket FILE NO. 52367

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Minnesota Department of Commerce (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Minnesota; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Minnesota statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

86. Mar 4, 2019
    Regulatory Action: Washington State Department of Financial Institutions, Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Mar 4, 2019 · Resolved Mar 4, 2019 · Consent · Docket S-18-2474-18-CO01

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Washington State Department of Financial Institutions, Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Washington; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Washington statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

87. Mar 4, 2019
    Regulatory Action: New Hampshire Bureau of Securities Regulation FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Mar 4, 2019 · Resolved Mar 4, 2019 · Consent · Docket INV2018-000222

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the New Hampshire Bureau of Securities Regulation (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Hampshire; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Hampshire statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

88. Feb 18, 2019
    Regulatory Action: Rhode Island Division of Business Regulation Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Feb 18, 2019 · Resolved Feb 18, 2019 · Consent · Docket 18-SC-002

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Rhode Island Division of Business Regulation Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Rhode Island; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Rhode Island statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

89. Feb 14, 2019
    Regulatory Action: Securities Division of the Office of the Attorney General of South Carolina FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $40,000 · Begun Feb 14, 2019 · Resolved Feb 14, 2019 · Consent · Docket 20167652

    The Securities Division of the Office of the Attorney General of South Carolina (division) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of S.C. Code ann. Section 35-1-411(c)(1) and S.C. Code of regulations section 13-405(a)(1).

    Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Carolina statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

90. Feb 1, 2019
    Regulatory Action: Government of the District of Columbia, Department of Insurance, Securities and Banking FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Feb 1, 2019 · Resolved Feb 1, 2019 · Consent · Docket SB-CO-10-18

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Government of the District of Columbia, Department of Insurance, Securities and Banking (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in the District of Columbia; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any District of Columbia statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

91. Feb 1, 2019
    Regulatory Action: North Dakota Securities Department FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Feb 1, 2019 · Resolved Feb 1, 2019 · Consent · Docket N/A

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the North Dakota Securities Department (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in North Dakota; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any North Dakota statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

92. Feb 1, 2019
    Regulatory Action: Hawaii Department of Commerce and Consumer Affairs FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Feb 1, 2019 · Resolved Feb 1, 2019 · Consent · Docket SEU-2018-014

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Hawaii Department of Commerce and Consumer Affairs (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Hawaii; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Hawaii statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

93. Jan 31, 2019
    Regulatory Action: Maryland Division of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 31, 2019 · Resolved Jan 31, 2019 · Consent · Docket 2017-0591

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Maryland Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Maryland; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Maryland statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

94. Jan 28, 2019
    Regulatory Action: U.S. Virgin Islands Division of Banking, Insurance and Financial Regulation FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 28, 2019 · Resolved Jan 28, 2019 · Consent · Docket N/A

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the U.S. Virgin Islands Division of Banking, Insurance and Financial Regulation (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in the U.S. virgin islands; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any U.S. virgin islands statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

95. Jan 24, 2019
    Regulatory Action: Utah Division of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Resolved Jan 24, 2019 · Consent · Docket SD-18-0041

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Utah Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Utah; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Utah statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

96. Jan 22, 2019
    Regulatory Action: Wisconsin Division of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 22, 2019 · Resolved Jan 22, 2019 · Consent · Docket S-238691(LX)

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Wisconsin Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Wisconsin; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Wisconsin statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

97. Jan 22, 2019
    Regulatory Action: Arkansas Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $40,000 · Begun Jan 22, 2019 · Resolved Jan 22, 2019 · Consent · Docket S-16-0069-OR02

    The Arkansas Securities Department (department) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements, in violation of rule 306.01 of the Arkansas securities commissioner.

    Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arkansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

98. Jan 11, 2019
    Regulatory Action: Arizona Corporation Commission FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 11, 2019 · Resolved Jan 11, 2019 · Consent · Docket S-21062A-18-0365

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Arizona Corporation Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Arizona; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arizona statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

99. Jan 10, 2019
    Regulatory Action: Colorado Division of Securities FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jan 10, 2019 · Resolved Jan 10, 2019 · Consent · Docket 2018-CDS-062

    In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Colorado Division of Securities (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Colorado; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

    This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Colorado statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

100. Dec 31, 2018
     Regulatory Action: Idaho Department of Finance FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Dec 31, 2018 · Resolved Dec 31, 2018 · Consent · Docket 2018-7-03

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Idaho Department of Finance (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Idaho; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Idaho statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

101. Dec 12, 2018
     Regulatory Action: Mississippi Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $40,000 · Begun Dec 12, 2018 · Resolved Dec 12, 2018 · Consent · Docket LS-17-2288

     The Mississippi Securities Division (division) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of miss. Code. Ann. Section 75-71-411(c)(1) and Mississippi Securities Act rules 5.15.

     Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Mississippi statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

102. Dec 6, 2018
     Regulatory Action: Illinois Securities Department FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $499,000 · Begun Dec 6, 2018 · Consent · Docket 1800307

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Illinois Securities Department (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Illinois statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

103. Dec 3, 2018
     Regulatory Action: Alabama Securities Commission FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $40,000 · Begun Dec 3, 2018 · Resolved Dec 3, 2018 · Consent · Docket N/A

     The Alabama Securities Commission (commission) alleged that during the period approximately January 2012 to March 2016 (relevant period), certain non-traded real estate investment trusts and non-traded business development companies were inaccurately classified as equities on certain client account statements in violation of rule 830-X-3-.14(1)(a) of the Alabama Securities Commission's administrative code.

     Without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alabama statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

104. Dec 3, 2018
     Regulatory Action: Indiana Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Undertaking · Fine: $450,000 · Begun Dec 3, 2018 · Resolved Dec 3, 2018 · Consent · Docket 18-0082 CA

     The Indiana Securities Division (division) alleged that during the period of approximately 2013 through September 2017 (relevant period) LPL Financial LLC (LPL) failed to review certain emails of its Indiana agents and failed to conduct annual examinations for certain branch offices located in Indiana in contravention of 710 iac 4-7-6(d)(1) (2017) and 710 iac 4-7-6(d)(9) (2017).

     LPL and the division agreed that the agreement does not constitute a finding of fact or determination against LPL for any violations of the Indiana uniform Securities Act or the rules and regulations promulgated thereunder. In addition, the division and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions. Furthermore, the division and LPL agreed that nothing in the agreement is intended to form the basis for disqualification under the rules and regulations of any self-regulatory organizations.

105. Nov 20, 2018
     Regulatory Action: Vermont Department of Financial Regulation FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Nov 20, 2018 · Resolved Nov 20, 2018 · Consent · Docket 18-032-S

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Vermont Department of Financial Regulation (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Vermont; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Vermont residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Vermont statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

106. Nov 19, 2018
     Regulatory Action: California Department of Business Oversight FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Offers of restitution; undertakings · Fine: $499,000 · Begun Nov 19, 2018 · Resolved Nov 19, 2018 · Consent · Docket N/A

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the California Department of Business Oversight (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in California; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to California residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any California statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

107. Nov 16, 2018
     Regulatory Action: State of Florida, Office of Financial Regulation FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Nov 16, 2018 · Resolved Nov 16, 2018 · Stipulation and Consent · Docket 90555-S/OFR2018-535

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Florida, Office of Financial Regulation (office) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Florida; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Florida residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the office and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the office and LPL agreed that nothing in the agreement is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the agreement is not intended to be a final order based upon violations of any Florida statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

108. Nov 15, 2018
     Regulatory Action: State of Connecticut Department of Banking FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Nov 15, 2018 · Resolved Nov 15, 2018 · Consent · Docket CO-18-8453-S

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Connecticut Department of Banking (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Connecticut; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Connecticut residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Connecticut statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

109. Nov 13, 2018
     Regulatory Action: Nevada Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Nov 13, 2018 · Resolved Nov 13, 2018 · Consent · Docket INV 18-104

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Nevada Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Nevada; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Nevada residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Nevada statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

110. Nov 8, 2018
     Regulatory Action: Commonwealth of Pennsylvania Department of Banking and Securities, Bureau of Securities Compliance and Examinations FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s); Offers of restitution; undertakings · Fine: $499,000 · Begun Nov 8, 2018 · Resolved Nov 8, 2018 · Consent · Docket 180091

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Commonwealth of Pennsylvania Department of Banking and Securities, Bureau of Securities Compliance and Examinations (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise its agents and employees regarding the sale of unregistered, non-exempt securities.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Pennsylvania statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

111. Nov 7, 2018
     Regulatory Action: Missouri Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Nov 7, 2018 · Resolved Nov 7, 2018 · Consent · Docket AP-18-12

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Missouri Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Missouri; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Missouri residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Missouri statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

112. Oct 29, 2018
     Regulatory Action: FINRA FinalSanctions: Other · Fine: $2.8M · Begun Oct 29, 2018 · Resolved Oct 29, 2018 · Acceptance, Waiver & Consent(AWC) · Docket 2016050751901

     Through three distinct investigations, FINRA found that LPL Financial (1) failed to establish and implement an AML program reasonably designed to detect and cause the reporting of potentially suspicious activity, in violation of FINRA rules 3310(a) and 2010, (2) failed to amend forms U4 and U5 violating article v, section 2 and 3 of FINRA's by-laws and FINRA rule 2010, and (3) failed to establish, maintain and enforce a supervisory system and written supervisory procedures reasonably designed to achieve compliance with Form U4 and U5 reporting requirements, in violation of FINRA rules 3110 and 2010.

     In determining the appropriate monetary sanction, FINRA considered the firm's cooperation and undertaking to remedy its' violations. Specifically, in resolving this matter, FINRA recognized LPL's extraordinary cooperation in having: (1) initiated, on its own, an investigation to identify the scope and extent of its AML program failures regarding sar filings; (2) retained an outside law firm to conduct an extensive internal investigation, which included interviewing firm employees and re-evaluating reporting determinations; (3) promptly remediated certain of the problems by filing 418 sars that it determined should have been filed earlier, and agreeing to amend 31 forms U4 and U5 to add customer complaint information; (4) initiated a review of its procedures regarding complaint reporting, AML investigations and sar reporting, and a restructuring of its AML investigations unit; and (5) provided substantial assistance to FINRA in its investigation, including providing detailed presentations concerning the results of the firm's internal investigations.

113. Oct 24, 2018
     Regulatory Action: Arkansas Securities Department FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Oct 24, 2018 · Resolved Oct 24, 2018 · Consent · Docket S-17-0078-18-OR-01

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Arkansas Securities Department (department) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Arkansas; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Arkansas residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the department and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Arkansas statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

114. Oct 11, 2018
     Regulatory Action: Securities Division of the Mississippi Secretary of State's Office FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Oct 11, 2018 · Resolved Oct 11, 2018 · Consent · Docket LS-17-2768

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the Mississippi Secretary of State's Office (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Mississippi; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Mississippi residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Mississippi statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

115. Oct 3, 2018
     Regulatory Action: State of Michigan, Department of Licensing & Regulatory Affairs, Corporations, Securities & Commercial Licensing Bureau FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Oct 3, 2018 · Resolved Oct 3, 2018 · Consent · Docket 336330

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the State of Michigan, Department of Licensing & Regulatory Affairs, Corporations, Securities & Commercial Licensing Bureau (BUREAU) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Michigan; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Michigan residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the bureau and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Michigan statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

116. Oct 2, 2018
     Regulatory Action: Securities Division of the New Mexico Regulation and Licensing Department FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Oct 2, 2018 · Resolved Oct 2, 2018 · Consent · Docket 15-099-0049

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Securities Division of the New Mexico Regulation and Licensing Department (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in New Mexico; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to New Mexico residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any New Mexico statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

117. Oct 1, 2018
     Regulatory Action: South Dakota Division of Insurance FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Oct 1, 2018 · Resolved Oct 1, 2018 · Consent · Docket 3006

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the South Dakota Division of Insurance (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in South Dakota; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to South Dakota residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multi-state task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any South Dakota statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

118. Sep 28, 2018
     Regulatory Action: Utah Division of Securities FinalSanctions: Censure; Fine · Fine: $200,000 · Begun Apr 4, 2018 · Resolved Sep 28, 2018 · Order · Docket SD-18-0013

     The Utah Division of Securities ("division") alleged LPL Financial failed to comply with the regulatory requirements governing networking arrangements between broker-dealers and credit unions, approve the use of misleading sales and advertising materials, and other information provided to customers and the public, failed to follow and enforce its policies and procedures, and failed to reasonably supervise the business run through the credit union.

119. Sep 13, 2018
     Regulatory Action: Kentucky Department of Financial Institutions FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Sep 13, 2018 · Resolved Sep 13, 2018 · Consent · Docket 2018-AH-00040

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Kentucky Department of Financial Institutions (DFI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Kentucky; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Kentucky residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the dfi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the dfi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Kentucky statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

120. Sep 13, 2018
     Regulatory Action: Investor Protection Unit of the Delaware Department of Justice FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Sep 13, 2018 · Resolved Sep 13, 2018 · Consent · Docket 18-0027

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the investor protection unit (IPU) of the Delaware Department of Justice alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to reasonably supervise and maintain adequate systems to comply with state securities registration requirements, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ipu and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ipu and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Delaware statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

121. Sep 11, 2018
     Regulatory Action: Louisiana Office of Financial Institutions FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Sep 11, 2018 · Resolved Sep 11, 2018 · Consent · Docket OFI-2018-04

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Louisiana Office of Financial Institutions (OFI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non- exempt securities in Louisiana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Louisiana residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ofi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ofi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Louisiana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

122. Aug 27, 2018
     Regulatory Action: Puerto Rico Office of the Commissioner of Financial Institutions FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Aug 27, 2018 · Resolved Aug 27, 2018 · Consent · Docket N/A

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Puerto Rico Office of the Commissioner of Financial Institutions (OCFI) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Puerto Rico; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non-exempt securities by LPL to Puerto Rico residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the ocfi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the ocfi and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Puerto Rico statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

123. Aug 15, 2018
     Regulatory Action: Indiana Securities Division FinalSanctions: Cease and Desist · Fine: $499,000 · Resolved Aug 15, 2018 · Consent · Docket 18-0069 CO

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Indiana Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) sold unregistered, non-exempt securities in Indiana; failed to reasonably supervise and maintain adequate systems to prevent the sale of unregistered, non- exempt securities by LPL to Indiana residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Indiana statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

124. Jun 22, 2018
     Regulatory Action: Alabama Securities Commission FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jun 22, 2018 · Resolved Jun 22, 2018 · Consent · Docket CO-2018-0012

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Alabama Securities Commission (commission) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to establish and maintain reasonable policies and procedures to prevent the sale of unregistered, non-exempt securities by LPL to Alabama residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the commission and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Alabama statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

125. Jun 12, 2018
     Regulatory Action: Massachusetts Securities Division FinalSanctions: Cease and Desist; Civil and administrative penalty; offers of restitution; undertakings · Fine: $499,000 · Begun Jun 12, 2018 · Resolved Jun 12, 2018 · Consent · Docket E-2017-0067

     In connection with an investigation conducted by a multistate task force coordinated among members of the north american securities administrators association inc. (NASAA), the Massachusetts Securities Division (division) alleged that during the period of approximately October 1, 2006 through May 1, 2018 (relevant period), LPL Financial LLC (LPL) failed to establish and maintain reasonable policies and procedures to prevent the sale of unregistered, non-exempt securities by LPL to Massachusetts residents, including with respect to LPL's retention, use, and subsequent cancellation of certain third-party services utilized for compliance with state securities registration requirements; certain other deficiencies within LPL's compliance structure related to LPL's controls, monitoring and reporting tools, and escalation protocols in relation to LPL's response to compliance issues resulting from such failure; and LPL's failure to maintain certain books and records to ensure full and proper compliance for state securities registration requirements.

     This action is part of a settlement regarding the sale of unregistered, non-exempt securities by LPL during the relevant period resulting from an investigation conducted by a multistate task force composed of members of nasaa. In connection with the resolution, each of the participating individual jurisdictions may enter consent orders against LPL, in which LPL neither admits nor denies the allegations. In this instance, without admitting or denying the allegations, LPL agreed to the above described sanctions. In addition, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, and including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa. Furthermore, the division and LPL agreed that nothing in the order is intended to form the basis for disqualification under FINRA or other sro rules prohibiting continuance in membership. Finally, the order is not intended to be a final order based upon violations of any Massachusetts statute, rule, or regulation that prohibits fraudulent, manipulative or deceptive conduct.

126. Mar 26, 2018
     Regulatory Action: North Carolina Securities Division FinalSanctions: Cease and Desist · Fine: $2,500 · Begun Mar 26, 2018 · Resolved Mar 26, 2018 · Consent · Docket FILE NO. 14 SEC 035

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the North Carolina Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its North Carolina representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to North Carolina residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to North Carolina residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a sum in the amount of $24,342.35. The sum represents a civil penalty of $2,500 plus $21,842.35 for investigative costs. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

127. Mar 19, 2018
     Regulatory Action: District of Columbia Department of Insurance, Securities and Banking FinalSanctions: Cease and Desist · Fine: $10,934 · Begun Mar 19, 2018 · Resolved Mar 19, 2018 · Consent · Docket SB-03-18

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the District of Columbia Department of Insurance, Securities and Banking (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its District of Columbia representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to District of Columbia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to District of Columbia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $10,934.13. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, or the United States territories, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

128. Feb 6, 2018
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $375,000 · Begun Feb 6, 2018 · Resolved Feb 6, 2018 · Acceptance, Waiver & Consent(AWC) · Docket 2015045703001

     From January 2010 through at least December 2016, FINRA alleged that LPL Financial failed to reasonably supervise the sale of certain brokered certificates of deposit ("brokered CDS"), which the firm characterized as non-security CDS because they were FDIC insured instruments. The firm allegedly failed to ensure that (1) its registered representatives were trained on all material risks and features of brokered CDS and (2) adequately disclose all material risks and features of brokered CDS to customers.

     As a result of the firm's alleged inadequate supervisory system, five customers of one of the firm's registered representatives suffered losses of approximately $75,000. The firm subsequently remediated these customers' losses.

129. Oct 24, 2017
     Regulatory Action: New Jersey Bureau of Securities FinalSanctions: Cease and Desist · Fine: $975,000 · Begun Oct 24, 2017 · Resolved Oct 24, 2017 · Consent · Docket 2016-502

     The New Jersey Bureau of Securities (BUREAU) alleged that LPL Financial LLC (LPL) failed to supervise its representatives' sales of certain alternative investments to New Jersey residents and failed to make and maintain accurate books and records relating to the sale of certain alternative investment transactions.

     The bureau alleged that during the period January 1, 2008 through December 31, 2015 (relevant period) LPL failed to adequately supervise its representatives' sales of certain alternative investments to New Jersey residents and failed to make and maintain accurate books and records relating to the sale of certain alternative investment transactions. Without admitting or denying the allegations, LPL agreed to (1) review its sales of certain non-traded alternative investment transactions and offer to repurchase products that were sold to New Jersey residents in violation of LPL's alternative investment guidelines and/or New Jersey prospectus requirements during the relevant period, and (2) to pay the bureau a civil penalty of $950,000 and remit $25,000 to New Jersey's investor education fund. Finally, the bureau and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions.

130. Sep 24, 2017
     Regulatory Action: The Secretary of State of North Carolina FinalSanctions: Cease and Desist; Civil penalty and reimbursement of investigative costs. · Fine: $25,000 · Begun Sep 24, 2017 · Resolved Sep 24, 2017 · Order · Docket 16 ADM 001

     The Secretary of State of North Carolina and securities administrator, alleged that LPL failed to reasonably supervise charles fackrell, one of its registered representatives, who, unbeknownst to LPL, operated a ponzi scheme in which he encouraged individuals to invest money in fictitious entities. Fackrell generally diverted the funds for personal expenses, although some funds were paid to investors to perpetuate the appearance of returns. After LPL was alerted to fackrell's criminal and unapproved activities, it immediately investigated and terminated him.

131. May 26, 2017
     Regulatory Action: Virginia Division of Securities and Retail Franchising FinalSanctions: Cease and Desist · Fine: $28,095 · Begun May 26, 2017 · Resolved May 26, 2017 · Consent · Docket SEC-2015-00052

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Virginia Division of Securities and Retail Franchising (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Virginia representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Virginia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Virginia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,095.38. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

132. May 4, 2017
     Regulatory Action: Massachusetts Securities Division FinalSanctions: Cease and Desist · Fine: $1.0M · Begun May 4, 2017 · Resolved May 4, 2017 · Order · Docket R-2016-0095

     The Massachusetts Securities Division alleged that LPL Financial failed to supervise financial advisors located on credit union premises, including the supervision of certain compensation and certain aspects of disclosures related to its business conducted on the credit union premises.

     On May 2, 2017, LPL submitted an offer of settlement to the division. LPL neither admitted nor denied the statement of facts and violations of law contained in the consent order related to an ongoing investigation by the division's registration, inspections, compliance and examinations section during the time period of December 27, 2011 to May 2, 2017.

133. May 1, 2017
     Regulatory Action: Vermont Securities Division FinalSanctions: Cease and Desist · Fine: $11,075 · Begun May 1, 2017 · Resolved May 1, 2017 · Consent · Docket 16-038-S

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Vermont Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Vermont representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Vermont residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Vermont residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $11,074.81. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

134. Apr 26, 2017
     Regulatory Action: Maine Office of Securities FinalSanctions: Cease and Desist · Fine: $11,939 · Begun Apr 26, 2017 · Resolved Apr 26, 2017 · Consent · Docket 16-12553

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the state of Maine Office of Securities (the office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Maine representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Maine residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Maine residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $11,939.46. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

135. Jan 27, 2017
     Regulatory Action: Massachusetts Securities Division FinalSanctions: Restitution; Cease and desist, censure, monetary fine, disgorgement, internal investigation · Fine: $975,000 · Begun Dec 1, 2016 · Resolved Jan 27, 2017 · Consent · Docket E-2016-0039

     The enforcement section alleges that LPL advisor, roger s. Zullo, fabricated the suitability profiles of numerous LPL clients, selling them scores of large, illiquid, unsuitable, high commission variable annuities, at substantial upfront profits to himself and LPL, in violation of sections 101, 102, and 204(a)(2)(g) of the act. The enforcement section further alleges that LPL failed in its responsibility to supervise roger s. Zullo, in violation of section 204(a)(2)(j).

136. Dec 21, 2016
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $900,000 · Begun Dec 21, 2016 · Resolved Dec 21, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2015045887301

     Without admitting or denying the findings, LPL Financial LLC ("the firm") consented to the sanctions and to the entry of findings that it failed to send and create records that it had sent to customers, more than 1.6 million account notices required under rule 17A-3(a)(17) of the Exchange Act. The firm is required to send these account notices to customers at 36 month intervals for each account in which a suitability determination was made. Over a seven-year period, the firm failed to send over 25 percent of the required notices. In addition, the firm failed to establish, maintain, and enforce a supervisory system and written supervisory procedures reasonably designed to achieve compliance with applicable laws and regulations in relation to the creation and distribution of such account records.

137. Dec 21, 2016
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $750,000 · Begun Dec 21, 2016 · Resolved Dec 21, 2016 · Acceptance, Waiver & Consent(AWC) · Docket 2014043539001

     Without admitting or denying the findings, LPL Financial LLC ("the firm") consented to the sanctions and to the entry of findings that it failed to maintain over 18.3 million electronic communications in non-erasable and no re-writable format, known as worm ("write once, read many") format. The findings stated that the worm format is intended to prevent the alteration or destruction of broker dealer records maintained on electronic storage media. In addition, the firm failed to retain check registers in worm format. The findings also stated that the firm's written supervisory procedures failed to have an adequate supervisory process concerning worm compliance.

138. Aug 25, 2016
     Regulatory Action: Hawaii Department of Commerce and Consumer Affairs FinalSanctions: Cease and Desist · Fine: $19,825 · Begun Aug 25, 2016 · Resolved Aug 25, 2016 · Consent · Docket SEU-2015-044

     In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Hawaii Department of Commerce and Consumer Affairs (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Hawaii representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Hawaii residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Hawaii residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $19,825.37. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

139. Jul 27, 2016
     Regulatory Action: Maryland Securities Division FinalSanctions: Cease and Desist · Fine: $28,172 · Begun Jul 27, 2016 · Resolved Jul 27, 2016 · Consent · Docket 2015-0464

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Maryland Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Maryland representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Maryland residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Maryland residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,172.31. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

140. Jul 20, 2016
     Regulatory Action: Louisiana Office of Financial Institutions FinalSanctions: Cease and Desist · Fine: $64,364 · Begun Jul 20, 2016 · Resolved Jul 20, 2016 · Consent · Docket OFI-2016-003

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Louisiana Office of Financial Institutions (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Louisiana representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Louisiana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Louisiana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $64,363.95. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

141. Jul 18, 2016
     Regulatory Action: Montana Securities Department FinalSanctions: Cease and Desist · Fine: $11,398 · Begun Jul 18, 2016 · Resolved Jul 18, 2016 · Consent · Docket SEC 2013-59

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Montana Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Montana representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Montana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Montana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $11,397.81 and investigative costs in the amount of $29,112.18. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

142. Jul 5, 2016
     Regulatory Action: Wyoming Secretary of State Compliance Division FinalSanctions: Cease and Desist · Fine: $12,345 · Begun Jul 5, 2016 · Resolved Jul 5, 2016 · Consent · Docket 15-03

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Wyoming Secretary of State Compliance Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Wyoming representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Wyoming residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Wyoming residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $12,344.55. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

143. Jun 30, 2016
     Regulatory Action: Massachusetts Securities Division FinalSanctions: Restitution; Cease and desist, censure, fine, changes to policies and procedures, employee training. · Fine: $100,000 · Begun Jun 30, 2016 · Resolved Jun 30, 2016 · Consent · Docket E-2015-0112

     The enforcement section alleged that during the time period of January 1, 2014 to June 30, 2016, LPL Financial LLC failed to supervise its agents when it failed to review those agents' misleading communications with the public in connection with the purchase and sale of an agents' book of business. The enforcement section also alleged that LPL Financial LLC failed to supervise its agent when such agent borrowed money from a client and lost that money in speculative trading for his own account.

144. May 3, 2016
     Regulatory Action: Oklahoma Department of Securities FinalSanctions: Cease and Desist · Fine: $21,245 · Begun May 3, 2016 · Resolved May 3, 2016 · Consent · Docket 16-017

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Oklahoma Department of Securities (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Oklahoma representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Oklahoma residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Oklahoma residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $21,245.14. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

145. Apr 29, 2016
     Regulatory Action: Oregon Division of Financial Regulation FinalSanctions: Cease and Desist · Fine: $24,642 · Begun Apr 29, 2016 · Resolved Apr 29, 2016 · Consent · Docket S-15-0126

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Oregon Division of Financial Regulation (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Oregon representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Oregon residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Oregon residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $24,642.20. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

146. Apr 26, 2016
     Regulatory Action: Arkansas Securities Department FinalSanctions: Cease and Desist · Fine: $19,348 · Begun Apr 26, 2016 · Resolved Apr 26, 2016 · Consent · Docket S-15-0038

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Arkansas Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Arkansas representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Arkansas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Arkansas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $19,347.74. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

147. Mar 30, 2016
     Regulatory Action: South Carolina Securities Commission FinalSanctions: Cease and Desist · Fine: $80,000 · Begun Mar 30, 2016 · Resolved Mar 30, 2016 · Consent · Docket 15037

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the South Carolina Securities Commission (securities commission) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its South Carolina representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the securities commission alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to South Carolina residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to South Carolina residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the securities commission a civil penalty in the amount of $80,000. Finally, the securities commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

148. Mar 14, 2016
     Regulatory Action: Ohio Division of Securities FinalSanctions: Cease and Desist · Fine: $32,522 · Begun Mar 14, 2016 · Resolved Mar 14, 2016 · Consent · Docket 16-008

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Ohio Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Ohio representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Ohio residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Ohio residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $32,522.13. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

149. Mar 11, 2016
     Regulatory Action: U.S. Virgin Islands Division of Banking and Insurance FinalSanctions: Cease and Desist · Fine: $10,013 · Begun Mar 11, 2016 · Resolved Mar 11, 2016 · Consent · Docket 6

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the U.S. Virgin Islands Division of Banking and Insurance (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its U.S. virgin islands representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to U.S. virgin islands residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to U.S. virgin islands residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $10,013.22. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

150. Mar 4, 2016
     Regulatory Action: Tennessee Securities Division FinalSanctions: Cease and Desist · Fine: $33,714 · Begun Mar 4, 2016 · Resolved Mar 4, 2016 · Consent · Docket 15002

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Tennessee Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Tennessee representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Tennessee residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Tennessee residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $33,714.11. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

151. Mar 2, 2016
     Regulatory Action: Wisconsin Division of Securities FinalSanctions: Cease and Desist · Fine: $25,929 · Begun Mar 2, 2016 · Resolved Mar 2, 2016 · Consent · Docket S-233431(LX)

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Wisconsin Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Wisconsin representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Wisconsin residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Wisconsin residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $25,928.70. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

152. Feb 29, 2016
     Regulatory Action: Kentucky Department of Financial Institutions FinalSanctions: Cease and Desist · Fine: $22,842 · Begun Feb 29, 2016 · Resolved Feb 29, 2016 · Consent · Docket 2016-AH-0010

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Kentucky Department of Financial Institutions (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Kentucky representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Kentucky residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Kentucky residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $22,841.84. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

153. Feb 26, 2016
     Regulatory Action: Office of the Kansas Securities Commissioner FinalSanctions: Cease and Desist · Fine: $16,183 · Begun Feb 26, 2016 · Resolved Feb 26, 2016 · Consent · Docket 16E002/2016-6358

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Office of the Kansas Securities Commissioner (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Kansas representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Kansas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Kansas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $16,182.86. Finally, the office and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

154. Feb 19, 2016
     Regulatory Action: Washington Insurance Commissioner FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,000 · Begun Feb 19, 2016 · Resolved Feb 19, 2016 · Order · Docket 15-0242

     LPL consented to the entry of a consent order with the insurance commissioner of the state of Washington, after its investigation into the conduct of a non-resident insurance producer after receiving a complaint from an insured alleging that he misrepresented the benefits and suitability of an annuity. More than one of the insurance producers' violations were known or should have been known by one or more individuals acting on behalf of LPL, and LPL neither reported the violations nor took corrective action. The insurance commissioner levied a fine in the amount of $2,000.00.

155. Feb 18, 2016
     Regulatory Action: Texas State Securities Board FinalSanctions: Other; Order · Fine: $95,000 · Begun Feb 18, 2016 · Resolved Feb 18, 2016 · Order · Docket IC16-CAF-02

     In May 2015, the staff of the Texas State Securities Board initiated an investigation into LPL's financial statement reviews for agents registered with the Texas securities commissioner. In certain instances, during the relevant periods of January 2011 through September 2011 and June 2014 through December 2014, the financial statement reviews were not conducted in accordance with respondent's written supervisory procedures.

     LPL has undertaken a number of enhancements to its policies and procedures relating to financial statement reviews. The enhancements included, among other things, manager escalation meetings, as well as creating an escalation review committee, additional quality control reviews, centralization of review documentation, and a requirement for dba owners to keep at least the most recent six months of all dba statements and check copies on file. In addition, pursuant to the undertakings, LPL will be implementing further enhancements to its procedures, focused primarily on creating monetary thresholds that define escalation criteria and the requirement, in certain circumstances, to obtain additional supporting documentation from the advisor. LPL rendered substantial cooperation in the staff's investigation.

156. Feb 9, 2016
     Regulatory Action: Alabama Securities Commission FinalSanctions: Cease and Desist · Fine: $18,268 · Begun Feb 9, 2016 · Resolved Feb 9, 2016 · Consent · Docket CO-2016-0002

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Alabama Securities Commission (commission) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Alabama representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the commission alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Alabama residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Alabama residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the commission a civil penalty in the amount of $18,267.52, of which $8,267.52 represents partial reimbursement for the commission's cost for investigating this matter. Finally, the commission and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

157. Feb 9, 2016
     Regulatory Action: North Dakota Securities Department FinalSanctions: Cease and Desist · Fine: $11,012 · Begun Feb 9, 2016 · Resolved Feb 9, 2016 · Consent · Docket N/A

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the North Dakota Securities Department (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its North Dakota representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to North Dakota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to North Dakota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $11,012.50, North Dakota's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

158. Jan 29, 2016
     Regulatory Action: California Department of Business Oversight FinalSanctions: Cease and Desist · Fine: $140,220 · Resolved Jan 29, 2016 · Consent · Docket N/A

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the California Department of Business Oversight (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its California representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to California residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to California residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $140,220.11, California's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

159. Jan 15, 2016
     Regulatory Action: Washington Department of Financial Institutions Securities Division FinalSanctions: Cease and Desist · Fine: $65,766 · Begun Jan 15, 2016 · Resolved Jan 15, 2016 · Consent · Docket S-15-1795-15-C001

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Washington Department of Financial Institutions Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Washington representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Washington residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Washington residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $65,766.07, Washington's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

160. Jan 8, 2016
     Regulatory Action: Georgia Securities Division FinalSanctions: Cease and Desist · Fine: $28,022 · Begun Jan 8, 2016 · Resolved Jan 8, 2016 · Consent · Docket ENSC-160589

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Georgia Securities Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Georgia representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Georgia residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Georgia residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $28,021.63, Georgia's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

161. Jan 5, 2016
     Regulatory Action: Iowa Insurance Division FinalSanctions: Cease and Desist · Fine: $16,639 · Begun Jan 5, 2016 · Resolved Jan 5, 2016 · Consent · Docket 88827

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Iowa Insurance Division (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Iowa representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Iowa residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Iowa residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $16,638.57, Iowa's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

162. Dec 30, 2015
     Regulatory Action: Colorado Division of Securities FinalSanctions: Cease and Desist · Fine: $40,184 · Begun Dec 30, 2015 · Resolved Dec 30, 2015 · Consent · Docket 2016-L-09

     In connection with coordinated investigations by a multistate task force with the north american securities administrators association inc. (NASAA), the Colorado Division of Securities (division) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Colorado representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Colorado residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Colorado residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $40,183.94, Colorado's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

163. Dec 30, 2015
     Regulatory Action: Florida Office of Financial Regulation FinalSanctions: Cease and Desist · Fine: $50,555 · Begun Dec 30, 2015 · Resolved Dec 30, 2015 · Stipulation and Consent · Docket 62466-S

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the state of Florida Office of Financial Regulation (office) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Florida representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the office alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Florida residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Florida residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the office a civil penalty in the amount of $50,555.39, Florida's allocated portion of the amount agreed to with nasaa. Finally, the office and LPL agreed that the agreement would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

164. Dec 29, 2015
     Regulatory Action: Nebraska Department of Banking & Finance FinalSanctions: Cease and Desist · Fine: $16,736 · Begun Dec 29, 2015 · Resolved Dec 29, 2015 · Consent · Docket N/A

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Nebraska Department of Banking & Finance (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Nebraska representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Nebraska residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Nebraska residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $16,736.07, Nebraska's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

165. Dec 21, 2015
     Regulatory Action: Idaho Department of Finance FinalSanctions: Cease and Desist · Fine: $17,738 · Begun Dec 21, 2015 · Resolved Dec 21, 2015 · Consent · Docket 2015-7-10

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Idaho Department of Finance (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Idaho representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Idaho residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Idaho residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $17,738.18, Idaho's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

166. Dec 21, 2015
     Regulatory Action: Michigan Department of Licensing and Regulatory Affairs FinalSanctions: Cease and Desist · Fine: $38,134 · Begun Dec 21, 2015 · Resolved Dec 21, 2015 · Consent · Docket 327800

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Michigan Department of Licensing and Regulatory Affairs (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Michigan representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Michigan residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Michigan residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $38,133.80, Michigan's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

167. Dec 16, 2015
     Regulatory Action: Minnesota Department of Commerce FinalSanctions: Cease and Desist · Fine: $41,210 · Begun Dec 16, 2015 · Resolved Dec 16, 2015 · Consent · Docket 39265

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. (NASAA), the Minnesota Department of Commerce (department) alleged that LPL Financial LLC (LPL) failed to implement an adequate supervisory system and enforce its procedures to supervise its Minnesota representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (relevant period) reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Minnesota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Minnesota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $41,209.74, Minnesota's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

168. Dec 15, 2015
     Regulatory Action: State of New Hampshire Bureau of Securities Regulation FinalSanctions: Other; N/a · Fine: $750,000 · Begun Apr 6, 2015 · Resolved Dec 15, 2015 · Consent · Docket C-2013-000005

     The State of New Hampshire Bureau of Securities Regulation commenced an adjudicative proceeding based on allegations of inadequate supervision of non-traded REIT sales.

     Without admitting or denying the facts or allegations, LPL consented to the findings that LPL failed to implement an adequate supervisory system and enforce its written procedures regarding the sale of non-traded reits to New Hampshire residents.

169. Dec 3, 2015
     Regulatory Action: Utah Division of Securities FinalSanctions: Cease and Desist · Fine: $18,293 · Begun Dec 3, 2015 · Resolved Dec 3, 2015 · Stipulation and Consent · Docket SD-15-0064

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Utah Division of Securities (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Utah representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Utah residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Utah residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $18,293.16, Utah's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

170. Dec 3, 2015
     Regulatory Action: Missouri Securities Division FinalSanctions: Cease and Desist · Fine: $38,523 · Begun Dec 3, 2015 · Resolved Dec 3, 2015 · Consent · Docket AP-15-42

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Missouri Securities Division (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Missouri representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Missouri residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Missouri residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $38,522.75, Missouri's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

171. Dec 3, 2015
     Regulatory Action: Alaska Division of Banking and Securities FinalSanctions: Cease and Desist · Fine: $10,570 · Begun Dec 3, 2015 · Resolved Dec 3, 2015 · Consent · Docket 15-1804-S

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Alaska division of banking and of securities (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Alaska representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Alaska residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Alaska residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $10,570.45, Alaska's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

172. Dec 1, 2015
     Regulatory Action: Texas State Securities Board FinalSanctions: Cease and Desist · Fine: $110,855 · Begun Dec 1, 2015 · Resolved Dec 1, 2015 · Consent · Docket IC15-CDO-04

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Texas State Securities Board (the "board") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Texas representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the board alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Texas residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Texas residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the board a civil penalty in the amount of $110,855.07 Texas' allocated portion of the amount agreed to with nasaa. Finally, the board and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

173. Nov 30, 2015
     Regulatory Action: Pennsylvania Department of Banking and Securities FinalSanctions: Cease and Desist · Fine: $26,111 · Begun Nov 30, 2015 · Resolved Nov 30, 2015 · Consent · Docket 150046

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Pennsylvania Department of Banking and Securities (the "department") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Pennsylvania representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the department alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Pennsylvania residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Pennsylvania residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the department a civil penalty in the amount of $26,110.92, Pennsylvania's allocated portion of the amount agreed to with nasaa. Finally, the department and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

174. Nov 30, 2015
     Regulatory Action: South Dakota Division of Securities FinalSanctions: Cease and Desist · Fine: $12,501 · Begun Nov 30, 2015 · Resolved Nov 30, 2015 · Consent · Docket 2816

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the South Dakota Division of Securities (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its South Dakota representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to South Dakota residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to South Dakota residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $12,500.70, South Dakota's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

175. Nov 24, 2015
     Regulatory Action: Mississippi Securities Division FinalSanctions: Cease and Desist · Fine: $19,253 · Begun Nov 24, 2015 · Resolved Nov 24, 2015 · Consent · Docket LS-15-1497

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Mississippi Securities Division (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Mississippi representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multi-state task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Mississippi residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Mississippi residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $19,253.45, Mississippi's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

176. Nov 24, 2015
     Regulatory Action: New Mexico Securities Division FinalSanctions: Cease and Desist · Fine: $11,528 · Begun Nov 24, 2015 · Resolved Nov 24, 2015 · Consent · Docket 15-09-0049

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the New Mexico Securities Division (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its New Mexico representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to New Mexico residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to New Mexico residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $11,528.48, New Mexico's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

177. Nov 24, 2015
     Regulatory Action: Indiana Securities Division FinalSanctions: Cease and Desist · Fine: $19,042 · Begun Nov 24, 2015 · Resolved Nov 24, 2015 · Consent · Docket 15-0022 CA

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), the Indiana Securities Division (the "division") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Indiana representatives regarding the sale of non- traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the division alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Indiana residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Indiana residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the division a civil penalty in the amount of $19,041.63, Indiana's allocated portion of the amount agreed to with nasaa. Finally, the division and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

178. Nov 23, 2015
     Regulatory Action: The Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico FinalSanctions: Cease and Desist · Fine: $10,125 · Begun Nov 23, 2015 · Resolved Nov 23, 2015 · Consent · Docket N/A

     In connection with coordinated investigations by a multi-state task force with the north american securities administrators association inc. ("NASAA"), The Office of the Commissioner of Financial Institutions of the Commonwealth of Puerto Rico (the "ocfi") alleged that LPL Financial LLC ("LPL") failed to implement an adequate supervisory system and enforce its procedures to supervise its Puerto Rico representatives regarding the sale of non-traded reits.

     This action is part of a global settlement regarding the sales of non-traded reits by LPL representatives during the period January 1, 2008 through December 31, 2013 (the "relevant period") reached by LPL with a multistate task force composed of members of nasaa. As part of the global settlement, individual jurisdictions may enter consent orders, in which LPL neither admits nor denies the allegations. In this instance, the ocfi alleged that during the relevant period LPL failed to implement an adequate supervisory system regarding its sales of non-traded reits and failed to enforce its written procedures regarding the sale of non-traded reits to Puerto Rico residents. Without admitting or denying the allegations, LPL agreed to (1) offer to remediate losses for non-traded reits sold to Puerto Rico residents in violation of guidelines during the relevant period, (2) retain an independent consultant to review its sales of non-traded reits during the relevant period, and (3) to pay the ocfi a civil penalty in the amount of $10,125.11, Puerto Rico's allocated portion of the amount agreed to with nasaa. Finally, the ocfi and LPL agreed that the order would not subject LPL to any disqualifications under the laws of the United States, any state, the District of Columbia, Puerto Rico, or the U.S. virgin islands, including without limitation, any disqualification from relying upon the state or federal registration exemptions or safe harbor provisions, which was also part of the agreement with nasaa.

179. Nov 4, 2015
     Regulatory Action: State of Ohio Department of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $2,000 · Begun Nov 4, 2015 · Resolved Nov 4, 2015 · Consent · Docket NONE

     LPL consented to the allegations that it violated Ohio statute 3905.22 by failing to timely report a regulatory action taken by the state of New Hampshire dated April 6, 2015.

180. Oct 1, 2015
     Regulatory Action: State of Nevada Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $56,202 · Begun Oct 1, 2015 · Resolved Oct 1, 2015 · Consent · Docket I14-083

     Without admitting or denying the findings of fact and conclusions of law, LPL entered into a consent order with the office of the secretary of state securities division after a multiple-jurisdiction investigation into LPL's sales transactions of non-traded reits, a form of alternative investments. During the time period beginning January 1, 2008 through December 31, 2013, LPL offered multiple non-traded reits through its branch offices in Nevada that were sold in excess of the REIT's prospectus standards, various state concentrations limits, or its own alternative investment guidelines. LPL failed to implement an adequate supervisory system that was reasonably designed to achieve compliance with nac 90.321. LPL also failed to enforce its written procedures to supervise the activities of its registered representatives in violation of nac 90.321.

181. Sep 22, 2015
     Regulatory Action: State of Delaware Investor Protection Unit FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $200,000 · Begun Sep 22, 2015 · Resolved Sep 22, 2015 · Consent · Docket 13-5-1

     Without admitting or denying the conclusions of law, LPL entered into a consent order with the Delaware investor protection unit after their investigation into LPL's use of leveraged and inverse leveraged exchange-traded funds (ETFS). LPL offered leveraged ETFS to certain retail clients in Delaware that were unsuitable, and/or without adequate disclosure of the specialized risks of leveraged ETFS, which constitutes a dishonest or unethical practice. LPL failed to ensure that its financial advisors understood and explained the unique risks, failed to enforce its warning and fine system with regard to its leveraged ETFS concentration limits, and failed to adequately monitor and ensure the monitoring of client holding periods, all of which constitute a failure to supervise.

182. Sep 15, 2015
     Regulatory Action: Commonwealth of Massachusetts FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $1.8M · Begun Sep 15, 2015 · Resolved Sep 15, 2015 · Consent · Docket 15-2854E

     Without admitting or denying the findings of fact and conclusions of law, LPL entered into an assurance of discontinuance with the Commonwealth of Massachusetts, after an investigation into LPL's use of leveraged and inverse leveraged exchange-traded funds (ETFS). LPL offered leveraged ETFS to certain retail clients in Massachusetts without monitoring or systematically reviewing the length of time its clients held leveraged ETFS. LPL provided insufficient training materials that, in parts, suggested that leveraged ETFS were appropriate for conservative accounts, and in some instances recommended buying and holding, without reminding financial advisors of the specific risks associated with holding leveraged ETFS. LPL failed to identify and examine potential issues concerning the suitability of leveraged ETF exposure for those of LPL's financial advisors who caused clients to hold leveraged ETFS for extended periods of time. Moreover, LPL did not consistently adhere to its policy of imposing fines on LPL Financial advisors who exceeded this concentration limit, sometimes issuing multiple warnings unaccompanied by any sanctions.

183. Aug 3, 2015
     Regulatory Action: State of Florida Office of Financial Regulation FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $10,000 · Begun Jul 31, 2015 · Resolved Aug 3, 2015 · Stipulation and Consent · Docket 51792-S

     LPL consented to the sanctions and the entry of the findings that from September 2009 to September 2013, LPL allowed one of its registered representatives to engage in investment advisory business from an office in the state of Florida without being lawfully registered in Florida.

184. Jul 14, 2015
     Regulatory Action: Massachusetts Securities Division FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $250,000 · Begun Jul 10, 2015 · Resolved Jul 14, 2015 · Order · Docket 2015-0033

     LPL consented to the findings that it did not establish, maintain, or enforce adequate procedures to review senior-specific titles for compliance with the commonwealth's senior designations regulations adopted June 1, 2007. As a result, LPL allowed its broker-dealer agents and investment adviser representatives to use prohibited senior-specific designations.

185. Jul 6, 2015
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Begun Jul 6, 2015 · Resolved Jul 6, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2015045270901

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it disadvantaged certain retirement plan and charitable organization customers who were eligible to purchase class a shares in certain mutual funds without a front-end sales charge. The findings stated that these customers were instead sold class a shares with a front-end sales charge or class b or c shares with back-end sales charges and higher ongoing fees and expenses. These sales disadvantaged customers by causing them to pay higher fees than they were actually required to pay. The findings also stated that the firm has failed to establish and maintain a supervisory system and procedures reasonably designed to ensure that customers who purchased mutual fund shares received the benefit of applicable sales charge waivers. The firm also failed to adopt any controls to detect instances in which the firm did not provide sales charge waivers to customers in connection with their mutual fund purchases.

186. May 6, 2015
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $10.0M · Begun May 6, 2015 · Resolved May 6, 2015 · Acceptance, Waiver & Consent(AWC) · Docket 2013035109701

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to enforce its supervisory procedures for the sales of complex non-traditional exchange traded funds (ETFS), certain variable annuity contracts, non-traded real estate investment trusts (REITS) and other complex products, as well as its failure to monitor and report trades and deliver to customers more than 14 million trade confirmations. The findings stated that with regard to non-traditional ETFS, the firm did not have a system to monitor the length of time that customers held these securities in their accounts, did not enforce its limits on the concentration of those products in customer accounts, and failed to ensure that all of its registered representatives were adequately trained on the risks of the products. The findings also stated that the firm failed to supervise its sales of variable annuities, in some instances permitting sales without disclosing surrender fees, and in connection with certain mutual fund "switch" transactions, it used an automated surveillance system that excluded these trades from supervisory review. The firm also failed to supervise non-traded REITS by, among other things, failing to identify accounts eligible for volume sales charge discounts. FINRA found that the firm failed to implement adequate systems for the review and accurate reporting of trades and for the accurate delivery of trade confirmations. The firm failed to review low priced equity trades, concentrated positions, actively traded accounts, and potential front running by employees. The findings also stated that the firm failed to accurately report to the options clearing corporation (OCC) options data using the large options positions report (LOPR) and failed to report its correct capacity to the real-time transaction reporting system (RTRS) and to the trade reporting and compliance engine (TRACE). The findings also included that the firm further failed to establish and maintain supervisory procedures reasonably designed to ensure compliance with its reporting requirements for options, municipal securities, and TRACE eligible securities. FINRA found that the firm failed to deliver contemporaneous trade confirmations and failed to establish and maintain a supervisory system, reasonably designed to ensure delivery of contemporaneous trade confirmations. FINRA also found that the firm's anti-money laundering (AML) surveillance system failed to generate alerts for excessive atm withdrawals and atm withdrawals in foreign jurisdictions. In addition, FINRA determined that the firm failed to ensure it provided complete and accurate information to FINRA and to federal and state regulators concerning certain variable annuity transactions. Moreover, FINRA found that the firm failed to reasonably supervise its advertising and other communications, including its registered representatives' use of consolidated reports, the creation or use of consolidated reports, and failed to ensure that these reports reflected complete and accurate information. Furthermore, FINRA found that the firm failed to comply with certain registration requirements such as verifying prior employment of certain of its registered representatives and failing to timely file Form U4 amendments and forms U5. The findings also stated that the firm had a fail to deliver position at a registered clearing agency in an equity security resulting from a long sale trade and did not close-out the position by purchasing or borrowing securities of like kind and quantity within the time frame. The findings also

187. Feb 13, 2015
     Regulatory Action: State of Ohio Department of Insurance FinalSanctions: Revocation · Begun Feb 13, 2015 · Resolved Feb 13, 2015 · Order · Docket N/A

     On or about September 4, 2014, LPL entered into a consent agreement with the Ohio department of insurance regarding the reporting of various administrative actions on its license. Pursuant to the agreement, LPL was required to pay a civil penalty and administrative costs. LPL failed to comply with the order in paying the civil penalty and administrative costs.

     LPL did not receive the invoice for the $1,000 civil penalty and administrative costs. When the firm became aware of the order of revocation, the monetary penalty was paid promptly and the firm's license was reinstated on February 27, 2015. On February 27, 2015, the Ohio department of insurance issued an order vacating the prior order of revocation entered on February 13, 2015.

188. Oct 31, 2014
     Regulatory Action: State of Illinois, Illinois Securities Department FinalSanctions: Restitution; Notice of hearing · Fine: $500,000 · Begun Oct 31, 2014 · Resolved Oct 31, 2014 · Consent · Docket 1200385

     LPL Financial failed to detect improper and fraudulent coduct on the part of david lisnek toward his LPL clients. LPL Financial allowed MR. lisnek to remain a registered representative while several facts, viewed together as a pattern of conduct, would have constituted multiple cautionary indicators ("red flags") of the potential for improper conduct.

     LPL entered into a consent agreement pursuant to which LPL paid a fine of $500,000 and restitution to investors meeting the consent agreement criteria.

189. Sep 4, 2014
     Regulatory Action: State of Ohio Department of Insurance FinalSanctions: Civil and Administrative Penalt(ies) /Fine(s) · Fine: $800 · Begun Aug 25, 2014 · Resolved Sep 4, 2014 · Order · Docket NONE

     From approximately December 2010 through December 12, 2012, LPL Financial was subject to various FINRA actions and other administrative actions on its professional licenses in the states of Illinois, Kentucky, Missouri, and Texas. LPL Financial reported its administrative actions to the Ohio department of insurance. However, they weren't reported to the department within the required thirty-day time period.

     LPL paid a civil fine of $800 and administrative costs of $200.

190. Jul 30, 2014
     Regulatory Action: FINRA FinalSanctions: Other; N/a · Fine: $30,000 · Begun Jul 30, 2014 · Resolved Jul 30, 2014 · Acceptance, Waiver & Consent(AWC) · Docket 2012031659001

     Without admitting or denying the findings, the firm consented to the sanctions and to the entry of findings that it failed to execute orders fully and promptly. The findings stated that the firm transmitted to OATS reports that contained inaccurate, incomplete, or improperly formatted data. Specifically, the reports contained inaccurate timestamps. Additionally, the firm failed to transmit two reportable order events (ROES) to OATS. The findings also stated that the firm failed to show the correct order receipt time on the memorandum. The findings also included that the firm's supervisory system did not provide for supervision reasonably designed to achieve compliance with respect to the applicable securities laws and regulations, and the rules of FINRA or the SEC. FINRA found that the firm failed to report S1 transactions in TRACE-eligible agency debt securities within 15 minutes of the time of execution to TRACE.

     Without admitting or denying the findings, LPL consented to a censure and a fine of $30,000, which LPL paid.

191. Jun 30, 2014
     Regulatory Action: State of Illinois, Illinois Securities Department FinalSanctions: Restitution; Notice of hearing · Fine: $2.0M · Begun Jun 30, 2014 · Resolved Jun 30, 2014 · Consent · Docket 1200385

     From at least 2009 to 2013, LPL Financial failed to adequately maintain certain books and records documenting its variable annuity exchange business and failed to enforce its supervisory system and procedures in connection with the documentation of certain salespersons' variable annuity exchange activities. LPL Financial's conduct constitutes cause to impose sanctions pursuant to sections 8.E.1(e) and (q) of the Illinois securities law of 1953, [815 ilcs 5/1 et seq.,] (the "act") and violates section 12.a of the act.

     LPL entered into a consent agreement pursuant to which LPL paid a fine of $200,000 and restitution to investors meeting the consent agreement criteria.

192. Dec 22, 2010
     Regulatory Action: FINRA FinalSanctions: Censure · Fine: $175,000 · Begun Dec 22, 2010 · Resolved Dec 22, 2010 · Acceptance, Waiver & Consent(AWC) · Docket 2009017682701

     FINRA rule 2010, NASD rules 2110, 3010: on December 4, 2006, the firm entered into an AWC relating to its failure to reasonably supervise its variable annuity exchange business. The firm had inadequate automated systems and written procedures for variable annuity exchanges reported on the electronic branch trade report system ("EBTR"). At the time the firm entered into the AWC, the firm was in the process of upgrading its centralized online order-entry system to switch from the EBTR to the annuity order entry system (AOE) system in order to enhance the firm's overall review of variable annuity exchange transactions. Accordingly, as part of the AWC, FINRA required that the firm retain an independent consultant to review and make recommendations regarding the AOE system and the firm's procedures to reasonably ensure that the firm was in compliance with federal securities laws and NASD rules relating to the exchange of variable annuities. In May 2008, the firm attested to FINRA that it had implemented the rollout of the new AOE system. When the rollout was completed, the firm amended its written supervisory procedures to make the use of the AOE system mandatory, with minor exceptions, for all registered representatives who engaged in variable annuity exchange transactions as of October 15, 2008. Despite the rollout of the AOE system and the firm's attestation to FINRA, the firm failed to enforce the mandatory usage of the AOE system until October 2009. As a result, during the period of October 2008 until October 2009, the firm's registered representatives entered orders for approximately 15% of the firm's variable annuity exchange transactions using the EBTR system instead of the AOE system. Therefore, by failing to enforce the mandatory use of the AOE system from October 2008 until October 2009, the firm failed to enforce its written supervisory procedures relating to variable annuity exchange transactions

     Without admitting or denying the findings, LPL consented to a censure and a fine of $175,000, which LPL paid.

Disclosures filed elsewhere

The firm's Form ADV names these and the kind of action only; the details are on the named firm's own filing.

• 1 regulatory action disclosure about Harvest Financial

Form ADV Item 11 and its Disclosure Reporting Pages, via the SEC record. All adviser disciplinary records.