John Christopher Oldham, of Wautoma, Wisconsin, a stockbroker formerly registered with NFB Financial Group, LLC, has been fined $5,000.00 and suspended from associating with any Financial Industry Regulatory Authority (FINRA) member in any capacity based upon consenting to findings that he engaged in an unauthorized commission sharing agreement with an unregistered institution, and caused the records and books of his firm to be plagued with inaccuracies. Letter of Acceptance, Waiver and Consent, No. 2015046203101 (Apr. 3, 2017).

According to the AWC, in August of 2014, Oldham made arrangements with an investment advisory to facilitate the advisory customers’ purchases of non-traded business development companies and real estate investment trusts. Apparently, customers were referred by the investment advisory to Oldham to make the alternative investment purchases via NFB Financial Group in return for the investment advisory to receive a share of Oldham’s commissions in connection with the transactions. FINRA noted that neither the investment advisory nor its staff were registered with FINRA.

The AWC further detailed that between August of 2014 and July of 2015, ninety-nine of the non-traded business development company and real estate investment trust transactions were facilitated via Oldham, in which fifty customers collectively invested in excess of $4,800,000.00 in funds. Evidently, the investment advisory raked in $240,000.00 in commissions in connection with Oldham’s activities in this regard. FINRA found that since Oldham shared commissions with an institution which was not registered, his conduct was violative of FINRA Rule 2010 and NASD Rule 2420.

The AWC revealed that customers referred by the investment advisory entered into subscription agreements with Oldham, where Oldham claimed to have been the customers’ financial advisor. Oldham reportedly claimed to have provided customers with advice concerning the alternative investments’ ability to be traded in the market and discussed the liquidity of the products. However, FINRA stated that in several cases, Oldham’s representations were not correct because he never engaged in communications with customers who entered into subscription agreements with him. FINRA found that Oldham caused inaccuracies in NFB Financial’s records and books as a result; conduct which was violative of FINRA Rule 2010 and 4511.

Oldham’s registration with NFB Financial Group, LLC was terminated on September 15, 2015, based upon allegations of Oldham’s misconduct subject of FINRA’s disciplinary action against him.

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