X0304 TA-1/A LIVE 3.4.0 0001007444 084-05637 SEC LPL Financial LLC LPL Financial Corporation 008698 4707 Executive Drive San Diego CA CALIFORNIA 92121 false 858-450-9606 false false false false Other LLC LPL Holdings, Inc. 1989-04-01 Managing Member Parent Company Mark Robert Helliker 2008-08-01 Managing Director Broker/Dealer Support Services Robert Joseph Moore 2012-05-01 President Advisor & Institution Solutions Sharyn J. Handelsman 2014-01-01 Executive Vice President Chief Compliance Officer, Brokerage George Burton White 2007-11-01 Managing Director Chief Investment Officer Dan Hogan Arnold, Jr. 2012-05-01 Managing Director Chief Financial Officer David Paul Bergers 2013-08-01 Manging Director and Director Legal and Government Relations Michelle Oroschakoff 2013-09-01 Managing Director Chief Risk Officer Paul Middlemiss 2011-05-01 Executive Vice President Chief Compliance Officer, Advisory John Andrew Kalbaugh 2010-03-01 Managing Director Financial Institution Services Joan Dominy Khoury 2012-05-01 Managing Director Chief Marketing Officer 2014-06-01 Sallie Rebecca Larsen 2012-05-01 Managing Director Chief Human Capital Officer Victor Peter Fetter, III 2012-12-01 Managing Director Chief Technology Officer Mark Stephen Casady 2005-12-01 Chairman of the Board and CEO Chief Exectutive Officer William P. Morrissey, Jr. 2014-04-01 Managing Director Independent Advisor Services Stephanie Leigh Brown 2004-03-01 Managing Director General Counsel 2013-08-19 Esther Marion Stearns 2007-03-01 Chief Operating Officer President 2012-05-01 William Edward Dwyer III 2004-01-01 Managing Director Naitonal Sales 2013-03-01 Denise Abood 2008-01-01 Managing Director Human Capital 2012-06-30 Jonathan Eaton 2008-01-01 Managing Director Retirement Planning 2012-06-30 Christopher F. Feeney 2008-01-28 Managing Director Chief Information Officer 2012-12-31 Kathy VanNoy-Pineda 2009-05-21 EVP Chief Compliance Officer, Brokerage 2014-01-01 John J. McDermott Jr. 2009-07-27 Managing Director Chief Risk Officer 2013-09-13 Abdiel Alan Valenzuela 2009-05-21 VP - Advisory Chief Compliance Officer, Advisory Derek Bruton 2010-03-01 Managing Director National Sales 2014-04-04 Becky Shulman 2011-06-06 Managing Director Deputy CFO 2011-11-21 Mary Frances Schott 2014-06-01 Managing Director Client Experience and Training Ryan Christopher Parker 2014-06-01 Managing Director Investment and Planning Solutions true LPL Financial Holdings Inc. Principal Stockholder of LPL Holdings, Inc. false false false false false false true Linsco/Private Ledger Corp. (n/k/a LPL Financial) SEC Administrative Proceeding Rel. Nos. 33-8371 and 34-49232 2004-02-12 Securities and Exchange Commission Action involved allegations related to application of mutual breakpoints for eligible customers on purchases of front-end load mutual funds. The SEC issued and Order against LPL that resulted in a censure, monetary fine, disgorgement/restitution and cease and desist/injunction. LPL Financial Corporation SEC Administrative Proceeding No. 34-58515 2008-09-11 Securities and Exchange Commission Proceeding involved allegations of violations of the safeguards rules of Regulation S-P. The SEC issued an Order against LPL that resulted in a censure, monetary fine, remedial undertakings by LPL, and cease and desist/injunction. false true LPL Financial SEC Administrative Proceeding Rel. Nos. 33-8371 and 34-49232 2004-02-12 Securities and Exchange Commission Action involved allegations related to application of mutual breakpoints for eligible customers on purchases of front-end load mutual funds. The SEC issued an Order against LPL that resulted in a censure, monetary fine, disgorgement/restitution and cease and desist/injunction. false true Private Ledger Financial Services, Inc. (N/K/A LPL Financial) Docket/Case Number: 82-66-S 1984-05-20 State of Michigan The matter involved a client that was sold various securities by two PLFS agents who were not at the time of sale registered in Michigan, a violation of Michigan Securities Act. PLFS was censured and ordered to pay restitution of $11,163.00 to a Michigan client. Private Ledger Financial Services, Inc. (N/K/A LPL Financial) Docket/Case Number: 50-86-952(a). 1986-05-14 State of Georgia The matter involved allegations that PLFS offered for sale and sold securities which were not effectively registered nor exempt from registration. PLFS reimbursed the Commissioner in the amount of $1,000.00 and agreed to cease and desist without admitting or denying any of the findings of fact or conclusions of Law. LPL Financial Docket/Case Number: 9501-04LC 1996-10-09 State of Pennsylvania The matter involved conduct of an agent formerly licensed with LPL and one of its predecessor firms, Private Ledger Financial Services (PLFS). LPL Consented to an order requiring it to engage and independent consultant to review its existing compliance policies & procedures, pay costs of $19,304.94, and comply with PA securities regulations. LPL Financial Docket/Case Number: 97E179 1998-12-01 State of Kansas The proceeding was based on the conduct of a representative formerly licensed with LPL and one of its predecessor firms, PLFS. LPL agreed to review procedures and make modifications that LPL determines to be reasonable & not overly burdensome & offer restitution to certain LPL customers. LPL Financial Docket/Case Number: IC06-CAF-19 2006-06-28 State of Texas Involved allegations that LPL failed to timely update its Form BD to reflect the use of other business names in connection w/securities activity by certain LPL Branch offices in TX. The order resulted in a reprimand and administrative fine in the amount of $10,000.00. LPL Financial Docket/Case Number: 2007-03-01 2007-11-20 State of Pennsylvania Allegations that at certain times between 1998 and 2006, LPL failed to maintain or enforce procedures reasonably designed to supervise one or more of its agents in PA. The matter resulted in a $200,000.00 administrative assessment and $30,000.00 for investigative and legal costs. LPL Financial Docket/Case Number: SEC-2009-46 2009-09-11 State of Montana Allegations that LPL failed to reasonably supervise a registered representative. Consent order resulted in LPL agreeing to pay restitution of $1,144,416.51 and a fine to the State of MT of $150,000. LPL Financial Docket/Case Number: SEU-2007-73 2007-12-24 State of Hawaii Allegation of failure to disclose to clients material information in connection with the offer, sale or purchase of securities. Consent agreement resulted in an administrative penalty of $10,000.00. LPL Financial Docket/Case Number: 2010-AH-012 2009-12-08 State of Kentucky Allegation that LPL paid advisory compensation to an agent who was not qualified and was not registered as an investment advisor representative. $4,000.00 fine. LPL Financial Docket/Case Number: 0800381 2010-07-12 State of Illinois Allegation that LPL failed to detect role of one of its representatives in the sale of participations in oil and gas projects. Matter resulted in a $300,000.00 fine and restitution of $167,796.00. LPL Financial Docket/Case Number: AP-10-16 2010-08-11 State of Missouri Matter involved sale of variable annuity contract in which representative allegedly misunderstood how a rider operated. Matter resulted in a censure and $37,540.00 in total for fine, restitution and interest. LPL Financial Docket/Case Number:1000096 2011-10-24 State of Illinois Allegation that LPL failed to supervise a registered representative. Matter resulted in $1,885,000.00 restitution to customers. LPL Financial Docket/Case Number: 2009-10-06 2011-12-06 State of Pennsylvania Allegation that LPL failed to supervise two registered representatives. Matter resulted in $59,092.52 fine for investigative costs. LPL Financial Docket/Case Number: S-07-0001-2 2011-11-08 State of Oregon Allegation that LPL failed to supervise an OSJ manager's transactions. Matter resulted in $100,000.00 fine. LPL Financial Docket/Case Number: AP-13-21 2013-12-17 State of Missouri Allegation that LPL failed to supervise a registered representative. Fine of $175,000.00 and pay the cost of the investigation in the amount of $10,000.00. LPL Financial Docket/Case Number: SEC-2012-144 2012-11-04 State of Montana Allegation that LPL failed to supervise a registered representative. Fine of $10,000.00 and $20,500.00 restitution to customers. LPL Financial Docket/Case Number: 2012-0036 2012-12-12 State of Massachusetts Allegations of failure to supervise and train registered representatives in connection with the sale of non-traded REITS. Fine of $500,000.00 and restitution to certain customers. LPL Financial Docket/Case Number: IC08-CAF-22 2008-12-30 State of Texas The state alleged that LPL failed to enforce its written procedures relating to the notification of a felony charge and Form U4 updates. Fine of $5,000.00 LPL Financial File No. 1200385 2014-06-30 State of Illinois Securities Department In June 2014, LPL submitted to a consent order with the Illinois Securities Department in connection with certain variable annuity exchange transactions, in particular, relating to its failure to adequately enforce supervisory procedures and maintain certain books and records required under Illinois law. LPL agreed to a censure, fine of $2,000,000.00 and restitution to impacted customers of approximately $800,000.00 false true LPL Financial Docket/Case Number: IC06-CAF-19 2006-06-28 State of Texas Involved allegations with LPL failed to timely update its Form BD to reflect the use of other business names in connection w/securities activity by certain LPL branch offices in TX. The order resulted in a reprimand and a fine in the amount of $10,000.00. LPL Financial Docket/Case Number: SEC-2009-46 2009-10-26 State of Montana Allegations that LPL failed to reasonably supervise a registered representative. Consent order resulted in LPL agreeing to pay restitution of $1,144,416.51 and a fine to the State of MT of $150,000.00. LPL Financial Docket/Case No. 2010-AH-012 2009-12-08 State of Kentucky Allegation that LPL paid advisory compensation to an agent who was not qualified and was not registered as an investment advisor representative. $4,000.00 fine. LPL Financial Docket/Case Number: 0800381 2010-07-12 State of Illinois Allegation that LPL failed to detect role of one of its representatives in the sale of participations in oil and gas projects. Matter resulted in a $300,000.00 fine and restitution of $167,796.00. LPL Financial Docket/Case Number: 1000096 2011-10-24 State of Illinois Allegation that LPL failed to supervise a registered representative. Matter resulted in $1,885,000.00 restitution to customers. LPL Financial Docket/Case Number: 2009-10-06 2011-12-06 State of Pennsylvania Allegation that LPL failed to supervise two registered representatives. Matter resulted in $59,092.52 fine for investigative costs. LPL Financial Docket/Case Number: S-07-0001-2 2011-11-08 State of Oregon Allegation that LPL failed to supervise OSJ managers transactions. Matter resulted in $100,000.00 fine. LPL Financial Docket/Case Number: AP-10-16 2010-08-11 State of Missouri Matter involved sale of variable annuity contract in which representative allegedly misunderstood how a rider operated. Matter resulted in a censure and $37,540.00 in total for fine, restitution and interest. LPL Financial Docket/Case No. 2007-03-01 2007-11-20 State of Pennsylvania Allegations that at certain times between 1998 and 2006, LPL failed to maintain or enforce procedures reasonably designed to supervise one or more of its agents in PA. The matter resulted in a $200,000.00 administrative assessment and $30,000.00 for investigative and legal costs. LPL Financial Docket/Case Number: IC08-CAF-22 2008-12-30 State of Texas The state alleged that LPL failed to enforce its written procedures relating to the notification of a felony charge and Form U4 updates. Fine of $5,000.00. LPL Financial Docket/Case Number: AP-13-21 2013-12-17 State of Missouri Allegation that LPL failed to supervise a registered representative. Fine of $175,000.00 and pay the cost of the investigation in the amount of $10,000.00. LPL Financial Docket/Case Number: SEC-2012-144 2012-11-04 State of Montana Allegation that LPL failed to supervise a registered representative. Fine of $10,000.00 and $20,500.00 restitution to customers. LPL Financial Docket/Case Number: 2012-0036 2012-12-12 State of Massachusetts Allegations of failure to supervise and train registered representatives in connection with the sale of non-traded REITS. Fine of $500,000.00 and restitution to certain customers. LPL Financial File No. 1200385 2014-06-30 State of Illinois Securities Department In June 2014, LPL submitted to a consent order with the Illinois Securities Department in connection with certain variable annuity exchange transactions, in particular, relating to its failure to adequately enforce supervisory procedures and maintain certain books and records required under Illinois law. LPL agreed to a censure, fine of $2,000,000.00 and restitution to impacted customers of approximately $800,000.00 false false true LPL Financial Acceptance, Waiver and Consent 2013-05-21 FINRA The matter involved inadequate email supervision and allegations of misstatements regarding the chronology of events concerning the LPL's discovery of the issue. Fine of $7,500,000.00. true PLFS (N/K/A LPL Financial) Acceptance, Waiver and Consent 1980-06-04 NASD District 2 Business Conduct Committee Allegations involved failure to supervise branch office for use of stationary and business cards and failure to use name of PLFS on front door of branch office in a phone book. Fine of $500.00. LPL Financial Acceptance, Waiver and Consent 2003-02-13 NASD The matter arose out of a representatives unauthorized participation/postings on electronic bulletin boards. The AWC resulted in a fine of $5,000.00 and an undertaking to revise LPLs written supervisory procedures concerning communications with the public via electronic media. LPL Financial Acceptance, Waiver and Consent 2003-03-27 NASD The matter arose from an error in reporting 23 transactions in FIPS securities within five minutes after execution. The AWC resulted in a fine of $5,000.00. LPL Financial Acceptance, Waiver and Consent 2004-02-12 NASD Action involved allegations related to application of mutual breakpoints for eligible customers on purchases of front-end load mutual funds. LPL was censured and fine $2,232,805.00 and made various other undertakings to the NASD. LPL Financial Acceptance, Waiver and Consent 2004-10-11 NASD The matter involved allegations related to two municipal bond liquidations. AWC resulted in censure and fine of $5000, restitution of $4,662.00, and undertaking to review written supervisory procedures related to determining FMV of municipal securities. LPL Financial Acceptance, Waiver and Consent 2004-11-30 NASD The matter arose out of LPLs alleged late filing of amendments to Forms U4 and Forms U5 from January 2002 through March 2004. The AWC resulted in a censure, fine in the amount of $450,000.00 and various undertakings by LPL. LPL Financial Acceptance, Waiver and Consent 2005-06-08 NASD The matter arose out of LPLs acceptance of directed brokerage payments from mutual fund companies. The AWC resulted in a fine of $3,602,398.00. LPL Financial Acceptance, Waiver and Consent 2005-11-14 NASD Allegations were that LPL failed to establish, maintain and enforce reasonable system of procedures to supervise activities of registered persons in connection with wire transfers. AWC resulted in a censure and fine of $75,000.00. LPL Financial Acceptance, Waiver and Consent 2005-12-19 NASD Matter arose out of allegations related to recommendations to customers for the purchase of mutual fund Class B and C shares. The AWC resulted in a fine of $2,400,000.00 LPL Financial Acceptance, Waiver and Consent 2006-01-06 NASD The matter arose out of allegations related to violations of NASD rules regarding the termination of research coverage of subject companies. The matter resulted in a fine of $5,000.00. LPL Financial Acceptance, Waiver and Consent 2006-12-21 NASD Allegations were that during a period, LPL failed to establish, maintain and enforce adequate supervisory system reasonably related to variable annuity exchange business. The AWC resulted in various undertakings by LPL. LPL Financial Acceptance, Waiver and Consent 2007-04-17 NASD Allegations were that LPL failed to timely amend representatives Forms U4 with material information. The AWC resulted in a fine of $5,000.00. LPL Financial Acceptance, Waiver and Consent 2009-09-04 FINRA Allegations involved failure to comply with MSRB Rule G-14. AWC resulted in a fine to LPL of $5,000.00. LPL Financial Acceptance, Waiver and Consent 2011-01-20 FINRA Allegations involved review of e-mails. Resulted in a censure and fine of $100,000.00. LPL Financial Acceptance, Waiver and Consent 2011-01-20 FINRA Allegations involved review of procedures on transmittal of cash and securities from customer accounts to third party accounts. Resulted in a censure and fine of $100,000.00. LPL Financial Acceptance, Waiver and Consent 2011-01-06 FINRA Allegations involved LPL did not use reasonable diligence to ascertain best inter-dealer market and failed to buy or sell in such market so that the resulting price to customers was as favorable as possible. Resulted in a censure and fine of $20,000.00. LPL Financial Acceptance, Waiver and Consent 2010-12-22 FINRA Allegations involved procedures on supervision of variable annuity exchanges. Resulted in a censure and fine of $175,000.00. LPL Financial Acceptance, Waiver and Consent 2008-06-03 FINRA Allegations involved failure to supervise a registered representative in connection with his/her use of strategies, marketing materials and appropriateness of investments. Resulted in a censure and fine of $125,000.00 LPL Financial Acceptance, Waiver and Consent 2011-06-08 FINRA Allegations involved procedures on supervision of advertising and public appearances. AWC resulted in a fine of $25,000.00. LPL Financial Acceptance, Waiver and Consent 2012-06-26 FINRA Allegations of trade reporting violation. Matter resulted in censure and $17,000.00 fine. LPL Financial Acceptance, Waiver and Consent 2011-07-26 FINRA Allegation of trade reporting violation. Matter resulted in censure and $22,500.00 fine. LPL Financial Acceptance, Waiver and Consent 2013-05-21 FINRA The matter involved inadequate email supervision and allegations of misstatements regarding the chronology of events concerning the LPL's discovery of the issue. Fine of $7,500,000.00. LPL Financial Acceptance, Waiver and Consent 2013-05-16 FINRA The action arose from allegations of charging commissions that were not fair and reasonable on certain corporate and municipal bonds. Fine of $60,000.00. LPL Financial Acceptance, Waiver and Consent 2012-12-31 FINRA Allegations of inadequate supervision of mutual fund prospectus delivered to customers. Fine of $400,000.00. LPL Financial Acceptance, Waiver and Consent 2014-07-30 FINRA Allegations of trading-related reporting violations for TRACE, OATS, and ROES violations. Fine of $30,000.00. false false false false true N/A N/A 1989-12-01 N/A A claim for recovery of corporate funds embezzled by an employee (not securities licensed) in the Private Ledger Financial Services Accounting Department. Claim was paid in late 1989 by the National Union Fire Insurance Company. N/A N/A 2006-12-01 N/A Claim for recovery of customer funds misappropriated by a registered representative of LPL. Claim was paid during 2004 through 2006 by Zurich American. N/A N/A 2007-07-27 N/A Claim of misappropriation of funds by former registered representative of LPL. Claim of $50,000.00 was paid on July 27, 2007 by Zurich. N/A N/A 2011-11-02 N/A Indemnification payments received from fidelity bond carrier. Claims arising from payments made by individuals to former broker. Payments totaling $1,279,433.79. Dates of payments: August 31, 2009 - $1,080,233.79; July 20, 2010 - $14,000.00 and; November 2, 2011 - $185,200.00. N/A N/A 2011-10-18 N/A Issue related to non-payment of funds loaned to former broker. $2,000,000.00 claim paid. false Greg M. Woods Executive Vice President, Deputy General Counsel 617-423-3644 2012-08-29