Silver Oak Securities Incorporated

Allegations: FINRA RULE 2010, NASD RULE 3010: THE FIRM PERMITTED A SINGLE REGISTERED REPRESENTATIVE TO RECOMMEND AND SELL NON-TRADITIONAL ETFS TO SOME OF THE FIRM'S CUSTOMERS. THE FIRM DID NOT, HOWEVER, INVESTIGATE THE CHARACTERISTICS AND RISK FACTOR'S OF SUCH PRODUCTS BEFORE ALLOWING ITS RR TO RECOMMEND THEM TO CUSTOMERS OR PROVIDE ITS RR ANY TRAINING. THE FIRM DID NOT IMPLEMENT ANY PROCEDURES FOR SUPERVISING THE FIRM'S PURCHASE AND TRADING OF NON-TRADITIONAL ETFS. INSTEAD, THE FIRM RELIED ON SUPERVISORY SYSTEMS ALREADY IN PLACE FOR THE RELEVANT PERIOD. AS A RESULT OF THE FIRM'S FAILURE TO IMPLEMENT A SUPERVISORY SYSTEM TAILORED TO NON-TRADITIONAL ETFS, THE FIRM DID NOT MONITOR TRANSACTIONS INVOLVING NON-TRADITIONAL ETFS, WHICH WOULD INCLUDE TRACKING THE VOLUME OF CUSTOMERS' HOLDINGS IN NON-TRADITIONAL ETFS, AS WELL AS TRACKING THE LENGTH OF TIME OPEN POSITIONS WERE MAINTAINED IN NON-TRADITIONAL ETFS, AND ANY RESULTING UNREALIZED LOSSES. THE FIRM ALSO DID NOT IMPOSE ANY LIMITATIONS ON TRADING OR HOLDING NON-TRADITIONAL ETFS. Status: Final Sanction Detail: N/A Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS.

Allegations: REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS WAS CANCELLED PURSUANT TO SECTION 8.E(2) OF THE ILLINOIS SECURITIES LAW Status: Final Summary: ON JANUARY 27, 2004 AN ORDER VACATING ORDER OF CANCELLATION WAS ISSUED. ON MARCH 2, 2004 A CONSENT ORDER OF DISMISSAL WAS SIGNED.

Allegations: FAILURE TO COMPLY WITH NAC 90.392 WHICH REQUIRES THE LICENSING OF A BRANCH OFFICE IN THE STATE OF NEVADA FOR THE PERIOD OF SEPTEMBER 13, 2011 THROUGH JANUARY 4, 2013, Status: Final Sanction Detail: CIVIL PENALTY OF 1,500.00 PAID ON JULY 25, 2016.

Allegations: ON AUGUST 3, 2016, THE BANKING COMMISSIONER ENTERED A CONSENT ORDER WITH RESPECT TO SILVER OAK SECURITIES, INC., A BROKER DEALER AND INVESTMENT ADVISER WITH ITS MAIN OFFICE AT 3339 NORTH HIGHLAND AVENUE, JACKSON, TENNESSEE 38305. THE FIRM ALSO MAINTAINS A BRANCH OFFICE AT 100 GREAT MEADOW ROAD, SUITE 502, WETHERSFIELD, CONNECTICUT 06109. SHARING OFFICE SPACE AT THE WETHERSFIELD LOCATION IS JB CAPITAL LLC, HEADED BY JOEL MARK JOHNSON. REGISTERED AGENTS OF SILVER OAK SECURITIES, INCORPORATED CONDUCT INVESTMENT-RELATED ACTIVITIES UNDER THE NAME OF "JOHNSON BRUNETTI". THE CONSENT ORDER WAS THE OUTGROWTH OF AN EXAMINATION AND INVESTIGATION THAT CITED CERTAIN FIRM IRREGULARITIES AND DEFICIENCIES INVOLVING 1)RECORDKEEPING RELATING TO THE SALE OF ALTERNATIVE INVESTMENTS: 2) THE FIRM'S SUPERVISORY SYSTEM;3) THE USE OF SIGNATURE STAMPS BY SILVER OAK, INCORPORATED AND ITS AGENTS; AND 4) THE FIRM'S EMPLOYMENT OF AN UNREGISTERED INVESTMENT ADVISER AGENT. THE ALTERNATIVE INVESTMENT RECORDKEEPING ISSUE PROMPTED DIVISION CONCERNS REGARDING CONCENTRATION LEVELS AND PRODUCT SUITABILITY. Status: Final Sanction Detail: SEE RESPONSE 12.B. Summary: SEE RESPONSE 12.B.

Allegations: THE COMMISSIONER, AS A RESULT OF AN EXAMINATION AND INVESTIGATION, ALLEGES THAT, FROM EARLY 2008 FORWARD, SILVER OAK VIOLATED SECTION 36B-6(D) OF THE ACT BY TRANSACTNG BUSINESS FROM 3 PLACES OF BUSINESS PRIOR TO THOSE LOCATIONS BEING REGISTERED AS BRANCH OFFICES. Status: Final Sanction Detail: NO LATER THAN THE DATE THIS CONSENT ORDER IS ENTERED BY THE COMMISSIONER, SILVER OAK SHALL REMIT TO THE DEPARTMENT BY CHECK MADE PAYABLE TO "TREASURER, STATE OF CONNECTICUT" THE SUM OF FIVE THOUSAND DOLLARS ($5,000), THREE THOUSAND DOLLARS ($3,000) OF WHICH SHALL CONSTITUTE AN ADMINISTRATIVE FINE AND TWO THOUSAND ($2,000) OF WHICH SHALL BE APPLIED TO DEFRAY THE DIVISION'S EXAMINATION AND INVESTIGATIVE COSTS.