Between October 2019 and December 2020, Oakwood Capital Securities, while under previous management, failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to surveil rates of deferred variable annuity exchanges. Accordingly, Oakwood violated FINRA Rules 3110, 2330(d), and 2010. For these violations, Oakwood is censured and fined $20,000.

Between September and October 2023, while associated with LPL, Buchholz effected 11 unauthorized transactions totaling more than $590,000 in the accounts of four customers, the adult daughters (the Customers) of a deceased senior customer. The transactions generated more than $16,000 in commissions. By this conduct, Buchholz effected unauthorized transactions in violation of FINRA Rule 2010 and is suspended for one month, fined $7,500, and ordered to disgorge $7,480 plus interest.