The Oak Ridge Financial Services Group, Inc

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM DID NOT CONDUCT ANY FORMAL DUE DILIGENCE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) BEFORE ALLOWING ITS REPRESENTATIVES TO RECOMMEND AND SELL THEM TO CUSTOMERS. THE FINDINGS STATED THAT THE FIRM ALSO DID NOT PROVIDE ANY FORMAL TRAINING FOR ITS REPRESENTATIVES RELATED TO NON-TRADITIONAL ETFS. IN ADDITION, THE FIRM DID NOT USE OR MAKE AVAILABLE TO ITS SUPERVISORY PERSONNEL ANY REPORTS OR OTHER TOOLS TO MONITOR EITHER THE LENGTH OF TIME THAT CUSTOMERS HELD OPEN POSITIONS IN NON-TRADITIONAL ETFS OR ANY LOSSES OCCURRING THOSE POSITIONS. THE FINDINGS ALSO STATED THAT THROUGH THIS CONDUCT, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REGARDING THE SALE OF NON-TRADITIONAL ETFS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS. Status: Final Sanction Detail: SEE ABOVE Summary: THE FIRM HAS SINCE UPDATED ITS WRITTEN POLICIES AND PROCEDURES REGARDING THE SALE OF NON-TRADITIONAL ETFS SO AS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED FINRA RULES WHEN TRANSACTING CORPORATE BOND TRADES. BETWEEN APRIL 2020 AND JANUARY 2024, OAK RIDGE FINANCIAL EFFECTED CORPORATE BOND TRANSACTIONS WITH ITS CUSTOMERS AT PRICES DEEMED UNFAIR BASED ON THE FIRM USING THE INCORRECT PREVAILING MARKET PRICE OF THE BOND. ADDITIONALLY, IN CORPORATE BOND TRANSACTIONS WHERE THE FIRM USED THE CORRECT PREVAILING MARKET PRICE, ITS MARK-UP OR MARK-DOWN WAS NOT COMPARABLE TO SIMILAR CORPORATE BOND TRANSACTIONS. ACCORDINGLY, FINRA FOUND OAK RIDGE FINANCIAL VIOLATED FINRA RULES 2121 AND 2010, AND THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS FAIR PRICING OBLIGATIONS IN VIOLATION OF FINRA RULES 3110 AND 2010. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $270,000, ORDERED TO PAY $68,857.69, PLUS INTEREST, IN RESTITUTION TO THE CUSTOMERS, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM DID NOT CONDUCT ANY FORMAL DUE DILIGENCE OF NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) BEFORE ALLOWING ITS REPRESENTATIVES TO RECOMMEND AND SELL THEM TO CUSTOMERS. THE FINDINGS STATED THAT THE FIRM ALSO DID NOT PROVIDE ANY FORMAL TRAINING FOR ITS REPRESENTATIVES RELATED TO NON-TRADITIONAL ETFS. IN ADDITION, THE FIRM DID NOT USE OR MAKE AVAILABLE TO ITS SUPERVISORY PERSONNEL ANY REPORTS OR OTHER TOOLS TO MONITOR EITHER THE LENGTH OF TIME THAT CUSTOMERS HELD OPEN POSITIONS IN NON-TRADITIONAL ETFS OR ANY LOSSES OCCURRING THOSE POSITIONS. THE FINDINGS ALSO STATED THAT THROUGH THIS CONDUCT, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WRITTEN POLICIES AND PROCEDURES, REGARDING THE SALE OF NON-TRADITIONAL ETFS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS. Status: Final Sanction Detail: SEE ABOVE Summary: THE OAK RIDGE FINANCIAL SERVICES GROUP INC SIGNED AWC #2012030789401 ON 05/06/2014. WE WERE FINED $10,000 AND CENSURED, AND THE AWC WAS APPROVED BY FINRA ON 06/16/2014 AND THE FINE HAS BEEN PAID.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED FINRA RULES WHEN TRADING FOR ITS OWN ACCOUNT, SOLD (OR BOUGHT) CORPORATE BONDS TO (OR FROM) CUSTOMERS AND FAILED TO SELL (OR BUY) SUCH BONDS AT A PRICE THAT WAS FAIR, TAKING INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED AND THAT THE FIRM WAS ENTITLED TO A PROFIT. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO CERTAIN APPLICABLE SECURITIES LAWS AND REGULATIONS, AND/OR THE RULES OF FINRA. WHILE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) PROVIDED THAT A DESIGNATED FIRM OFFICIAL WAS RESPONSIBLE FOR CONDUCTING DAILY REVIEWS OF ALL EXECUTED TRANSACTIONS, THEY FAILED TO DESCRIBE THE SUPERVISORY STEPS OR REVIEWS TO BE CONDUCTED BY THAT INDIVIDUAL TO ENSURE COMPLIANCE WITH THE FAIR PRICING REQUIREMENTS SET FORTH IN RULE 2121. MOREOVER, THE WSPS DID NOT STATE HOW THE DAILY REVIEWS WERE TO BE DOCUMENTED. AS A CONSEQUENCE, THE FIRM'S SUPERVISORY SYSTEM, INCLUDING ITS WSPS, WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH FINRA RULE AND 2121. Status: Final Sanction Detail: THE FIRM WAS CENSURED, FINED $17,500, ORDERED TO PAY $4,956.25, PLUS INTEREST, IN RESTITUTION TO THE CUSTOMERS, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES.