susquehanna financial group, lllpsusquehanna financial group, lllp sec# 35865 8-44325 main office...

BrokerCheck Report

SUSQUEHANNA FINANCIAL GROUP, LLLP

Section Title

Report Summary

Firm History

CRD# 35865

1

7

Firm Profile 2 - 6

Page(s)

Firm Operations 8 - 24

Disclosure Events 25

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SUSQUEHANNA FINANCIAL GROUP,LLLP

CRD# 35865

SEC# 8-44325

Main Office Location

401 CITY AVESUITE 220BALA CYNWYD, PA 19004-1122Regulated by FINRA Philadelphia Office

Mailing Address

401 CITY AVESUITE 220BALA CYNWYD, PA 19004-1122

Business Telephone Number

800-825-9550

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 10

Firm Profile

This firm is classified as a other types of legalformation.

This firm was formed in Delaware on 07/25/2002.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 11 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 9 Self-Regulatory Organizations• 51 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2020 FINRA. All rights reserved. Report about SUSQUEHANNA FINANCIAL GROUP, LLLP


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a other types of legal formation.

This firm was formed in Delaware on 07/25/2002.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

SUSQUEHANNA FINANCIAL GROUP, LLLP

SEC#

35865

8-44325

Main Office Location

Mailing Address

Business Telephone Number

Doing business as SUSQUEHANNA FINANCIAL GROUP, LLLP

800-825-9550

Regulated by FINRA Philadelphia Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

SFG HOLDING, LLC

LIMITED PARTNER

75% or more

No

Domestic Entity

01/2011

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


GILROY, FRANK CHARLES

HEAD OF FIXED INCOME

Less than 5%

No

Individual

05/2012

Yes

1061333



Position


Position Start Date

KRASNICK, ALAN JONATHAN

MUNICIPAL SECURITIES PRINCIPAL

Less than 5%

Individual

04/2009

4606571








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No

Position



Position Start Date


MCENTEE, ROBERT FRANCIS JR.

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

04/2018

Yes

4722705



Position



Position Start Date


SACK, ROBERT CHRISTOPHER

FINANCIAL OPERATIONS PRINCIPAL, TREASURER, SECRETARY

Less than 5%

No

Individual

03/2013

No

2633481



SFG PARTNER LLC

Domestic EntityIs this a domestic or foreignentity or an individual?







Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


GENERAL PARTNER

Less than 5%

No

Domestic Entity

05/2002

Yes


Position



Position Start Date


WOOD, NICHOLAS H

HEAD OF EQUITIES

Less than 5%

No

Individual

03/2013

Yes

2626078








This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

BODEL, INC.

MEMBER

SFG HOLDING, LLC

75% or more

No

Domestic Entity

01/2011

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




SFG HOLDING, LLC

MEMBER

SFG PARTNER, LLC

75% or more

No

Domestic Entity

01/2011

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 9 SROs and 51 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

No

No

No

Federal Regulator Status Date Effective

SEC Approved 07/15/1994

Self-Regulatory Organization Status Date Effective

FINRA Approved 07/15/1994

Cboe BYX Exchange, Inc. Approved 10/05/2010

Cboe BZX Exchange, Inc. Approved 09/03/2008

Cboe EDGA Exchange, Inc. Approved 05/26/2010

Cboe EDGX Exchange, Inc. Approved 05/27/2010

Investors' Exchange LLC Approved 08/08/2016

NYSE Arca, Inc. Approved 06/02/2006

Nasdaq BX, Inc. Approved 06/11/2012

Nasdaq Stock Market Approved 07/12/2006






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 02/09/2001

Alaska Approved 12/10/2001

Arizona Approved 04/16/1999

Arkansas Approved 07/18/2001

California Approved 09/18/2002

Colorado Approved 06/13/1996

Connecticut Approved 07/26/1996

Delaware Approved 01/11/2001

District of Columbia Approved 03/18/2001

Florida Approved 01/01/1997

Georgia Approved 07/25/1996

Hawaii Approved 01/02/2002

Idaho Approved 08/02/2001

Illinois Approved 08/02/1996

Indiana Approved 02/08/2001

Iowa Approved 02/13/2001

Kansas Approved 02/26/2001

Kentucky Approved 01/24/2001

Louisiana Approved 08/29/2001

Maine Approved 11/29/2001

Maryland Approved 02/11/1997

Massachusetts Approved 01/24/1997

Michigan Approved 06/16/1999

Minnesota Approved 01/23/2001

Mississippi Approved 09/05/2001

Missouri Approved 02/26/2001

Montana Approved 10/04/2001

Nebraska Approved 11/15/2001

Nevada Approved 05/27/1999

New Hampshire Approved 12/05/2001

New Jersey Approved 07/15/1996

New Mexico Approved 12/03/2001

New York Approved 01/01/1997

U.S. States &Territories

Status Date Effective

North Carolina Approved 05/14/2001

North Dakota Approved 11/28/2001

Ohio Approved 01/22/2001

Oklahoma Approved 10/24/2001

Oregon Approved 03/27/2001

Pennsylvania Approved 02/19/1997

Rhode Island Approved 03/16/2001

South Carolina Approved 06/17/1996

South Dakota Approved 10/30/2001

Tennessee Approved 11/15/2001

Texas Approved 03/13/2000

Utah Approved 05/24/1999

Vermont Approved 01/23/2002

Virginia Approved 11/17/2000

Washington Approved 04/28/1999

West Virginia Approved 10/29/2001

Wisconsin Approved 01/24/1997

Wyoming Approved 11/15/2001






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does effect transactions in commodities, commodity futures, or commodity options.This firm does engage in other non-securities business.

Non-Securities Business Description: FROM TIME TO TIME, THE FIRM PROVIDES INSTITUTIONALCUSTOMERS WITH LEGAL COMMENTARY ON SPECIFIC CASESRELATED TO THE ONGOING LITIGATION MATTERS OF ONE OR MORECOMPANIES.

This firm currently conducts 11 types of businesses.

Types of Business

Exchange member engaged in floor activities

Broker or dealer making inter-dealer markets in corporation securities over-the-counter

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Underwriter or selling group participant (corporate securities other than mutual funds)

Municipal securities dealer

Municipal securities broker

Put and call broker or dealer or option writer

Non-exchange member arranging for transactions in listed securities by exchange member

Trading securities for own account

Private placements of securities






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: BOFA SECURITIES, INC.

Business Address: ONE BRYANT PARKNEW YORK, NY 10036-1607

CRD #: 283942

Effective Date: 05/13/2019

Description: BOFA SECURITIES, INC. IS A CLEARING FIRM FOR SUSQUEHANNAFINANCIAL GROUP, LLLP.

Name: MERRILL LYNCH PROFESSIONAL CLEARING CORP.

Business Address: 101 HUDSON STREET7TH FLOORJERSEY CITY, NJ 07302

CRD #: 16139


Description: SUSQUEHANNA FINANCIAL GROUP, LLLP INTRODUCES CUSTOMERSON A FULLY DISCLOSED BASIS TO MERRILL LYNCH PROFESSIONALCLEARING CORP.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.



CRD #: 283942



Name: COWEN EXECUTION SERVICES LLC

Business Address: 1633 BROADWAY48TH FLOORNEW YORK, NY 10019

CRD #: 35693


Description: COWEN EXECUTION SERVICES LLC, IS A CLEARING FIRM FORSUSQUEHANNA FINANCIAL GROUP, LLLP

Name: MERRILL LYNCH INTERNATIONAL

Business Address: 2 KING EDWARD STREETLONDON, UNITED KINGDOM EC1A 1HQ


Description: MERRILL LYNCH INTERNATIONAL IS A CLEARING FIRM FORSUSQUEHANNA FINANCIAL GROUP, LLLP.



CRD #: 16139


Description: SUSQUEHANNA FINANCIAL GROUP, LLLP WILL ACT AS INTRODUCINGBROKER BY INTRODUCING ACCOUNTS TO MERRILL LYNCHPROFESSIONAL CLEARING CORP. ON A FULLY DISCLOSED BASIS.






Firm Operations

Industry Arrangements (continued)

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.



CRD #: 283942



Name: COWEN EXECUTION SERVICES LLC

Business Address: 1633 BROADWAY48TH FLOORNEW YORK, NY 10019

CRD #: 35693


Description: COWEN EXECUTION SERVICES LLC, IS A CLEARING FIRM FORSUSQUEHANNA FINANCIAL GROUP, LLLP

Name: MERRILL LYNCH INTERNATIONAL

Business Address: 2 KING EDWARD STREETLONDON, UNITED KINGDOM EC1A 1HQ


Description: MERRILL LYNCH INTERNATIONAL IS A CLEARING FIRM FORSUSQUEHANNA FINANCIAL GROUP, LLLP.



CRD #: 16139




CRD #: 283942 13©2020 FINRA. All rights reserved. Report about SUSQUEHANNA FINANCIAL GROUP, LLLP





Firm Operations

Industry Arrangements (continued)

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing


CRD #: 283942




Business Address: ONE BRYANT PARKNEW YORK, NY 10036

CRD #: 283942





CRD #: 16139








Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

No

Yes

CAYMAN ISLAND

Yes

07/14/2015

WINWARD 1REGATTA OFFICE PARKGRAND CAYMAN, CAYMAN ISLANDS KY1-1103

CVI INVESTMENTS, INC. is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND CVI INVESTMENTS, INC. ARE SUBSTANTIALLY THESAME.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/12/2014

1201 N ORANGE STSUITE 715WILMINGTON, DE 19801

SAL TRADING, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SAL TRADING, LLC ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)

No

Yes

IRELAND

Yes

03/12/2014

GEORGE'S DOCK HOUSE4TH FLOORIFSC DUBLIN 1, IRELAND 00000

SUSQUEHANNA INTERNATIONAL GROUP LIMITED is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA INTERNATIONAL GROUP LIMITED. ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/12/2014

401 CITY AVESUITE 220BALA CYNWYD, PA 19004

SUSQUEHANNA ADVISORS GROUP, INC. is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA ADVISORS GROUP, INC. ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

03/12/2014


SUSQUEHANNA FUNDAMENTAL INVESTMENTS, LLC is under common control with the firm.

Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

Yes

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA FUNDAMENTAL INVESTMENTS, LLC ARESUBSTANTIALLY THE SAME.

Description:



Country:

No

Yes

No

02/10/2014

440 S. LASALLE STREETSUITE 3030CHICAGO, IL 60605-1028

111528

G1 EXECUTION SERVICES, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND G1 EXECUTION SERVICES, LLC ARE SUBSTANTIALLYTHE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

03/12/2014


HEIGHTS CAPITAL MANAGEMENT, INC. is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND HEIGHTS CAPITAL MANAGEMENT, INC. ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND HEIGHTS CAPITAL MANAGEMENT, INC. ARESUBSTANTIALLY THE SAME.

Description:

No

Yes

No

03/12/2014


SUSQUEHANNA CLEARING, LLC is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA CLEARING, LLC ARE SUBSTANTIALLYTHE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

07/30/2003

401 CITY AVENUEBALA CYNWYD, PA 19004

126407

GLOBAL EXECUTION BROKERS, LP is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND GLOBAL EXECUTION BROKERS, LP ARE SUBSTANTIALLYTHE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

06/25/2003

401 CITY AVENUEBALA CYNWYD, PA 19004

SUSQUEHANNA GOVERNMENT PRODUCTS, LLLP is under common control with the firm.

Effective Date:

Business Address:






Firm Operations


No

Yes

No

06/25/2003

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA GOVERNMENT PRODUCTS, LLLP ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

No

Yes

No

10/04/2002

1201 N. ORANGE STREETSUITE 715WILMINGTON, DE 19801

DARBY FINANCIAL PRODUCTS is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND DARBY FINANCIAL PRODUCTS ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

03/22/2002

1201 N. ORANGE STREETSUITE 715WILMINGTON, DE 19801

SIG STRUCTURED PRODUCTS, LLLP is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SIG STRUCTURED PRODUCTS, LLLP ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SIG STRUCTURED PRODUCTS, LLLP ARESUBSTANTIALLY THE SAME.

Description:

No

Yes

IRELAND

Yes

03/22/2002


SUSQUEHANNA INTERNATIONAL SECURITIES LIMITED is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA INTERNATIONAL SECURITIES LIMITEDARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

AUSTRALIA

Yes

12/05/2000

2 CHIFLEY SQUARELEVEL 41SYDNEY NSW 2000, AUSTRALIA 00000

SUSQUEHANNA ASIA PTY LTD is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA ASIA PTY LTD ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

07/19/2000

1201 N ORANGE STREETSUITE 715WILMINGTON, DE 19801

SUSQUEHANNA FINANCIAL PRODUCTS is under common control with the firm.

Effective Date:

Business Address:






Firm Operations


No

Yes

No

07/19/2000

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA FINANCIAL PRODUCTS ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

No

Yes

No

08/19/1999

140 BROADWAY47TH FLNEW YORK, NY 10005

100400

SIG BROKERAGE, LP is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SIG BROKERAGE, LP ARE SUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

IRELAND

Yes

04/20/1999


SUSQUEHANNA IRELAND LIMITED is under common control with the firm.



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA IRELAND LIMITED ARE SUBSTANTIALLYTHE SAME.

Description:


No

Yes

AUSTRALIA

Yes

04/30/1998

2 CHIFLEY SQUARELEVEL 41SYDNEY, NSW 2000, AUSTRALIA 00000

SUSQUEHANNA PACIFIC PTY LTD is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA PACIFIC PTY LIMITED ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

CAYMAN ISLANDS

Yes

11/12/1991

WINWARD 1REGATTA OFFICE PARKGRAND CAYMAN, CAYMAN ISLANDS KY1-1103

CAPITAL VENTURES INTERNATIONAL is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND CAPITAL VENTURES INTERNATIONAL ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

29337

SUSQUEHANNA CAPITAL GROUP is under common control with the firm.

CRD #:22©2020 FINRA. All rights reserved. Report about SUSQUEHANNA FINANCIAL GROUP, LLLP





Firm Operations


No

Yes

No

01/02/1995

401 CITY LINE AVENUEBALA CYNWYD, PA 19004

29337

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SAL EQUITY TRADING, GP ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

Yes

No

04/01/1994

401 CITY LINE AVENUEBALA CYNWYD, PA 19004

35874

SUSQUEHANNA SECURITIES is under common control with the firm.

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA SECURITIES ARE SUBSTANTIALLY THESAME.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

No

11/12/1991

401 CITY LINE AVENUESUITE 220BALA CYNWYD, PA 19004

33875

SUSQUEHANNA INVESTMENT GROUP is under common control with the firm.

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations


No

Yes

No

THE ULTIMATE BENEFICIAL OWNERS OF SUSQUEHANNA FINANCIALGROUP, LLLP AND SUSQUEHANNA INVESTMENT GROUP ARESUBSTANTIALLY THE SAME.

Description:



Country:

Foreign Entity:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 10 0






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 10

Reporting Source: Regulator

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR TRANSACTIONS INTRACE-ELIGIBLE CORPORATE DEBT SECURITIES AND ALSO FAILED TOREPORT THE TRANSACTIONS WITHIN THE TIMEFRAME REQUIRED. THEFINDINGS STATED THAT THE FIRM ALSO FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDA OF BROKERAGE ORDERS FORTHE TRANSACTIONS IN CORPORATE DEBT SECURITIES MENTIONEDABOVE.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other Sanction(s)/ReliefSought:

Date Initiated: 10/07/2016

Docket/Case Number: 2015046869101

Principal Product Type: Debt - Corporate

Other Product Type(s):

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TOREPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE)THE CORRECT TIME OF TRADE EXECUTION FOR TRANSACTIONS INTRACE-ELIGIBLE CORPORATE DEBT SECURITIES AND ALSO FAILED TOREPORT THE TRANSACTIONS WITHIN THE TIMEFRAME REQUIRED. THEFINDINGS STATED THAT THE FIRM ALSO FAILED TO SHOW THE CORRECTTIME OF EXECUTION ON THE MEMORANDA OF BROKERAGE ORDERS FORTHE TRANSACTIONS IN CORPORATE DEBT SECURITIES MENTIONEDABOVE.

Resolution Date: 10/07/2016

Resolution:

Other Sanctions Ordered:

Sanction Details: THE FIRM WAS CENSURED AND FINED $7,500.FINE PAID IN FULL ON OCTOBER 19, 2016.

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Sanctions Ordered: CensureMonetary/Fine $7,500.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") ALLEGEDTHAT, DURING THE PERIOD FROM APRIL 1, 2015 THROUGH JUNE 30, 2015,THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR 100 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATEDEBT SECURITIES, AND FAILED TO REPORT SUCH TRANSACTIONS WITHINTHE TIMEFRAME REQUIRED BY FINRA RULE 6730. FINRA FURTHERALLEGED THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE BROKERAGE ORDER MEMORANDA FOR SUCHTRANSACTIONS IN ALLEGED VIOLATION OF SEC RULE 17A-3 AND FINRARULE 4511.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2015046869101


Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA")


Civil and Administrative Penalt(ies) /Fine(s)



Docket/Case Number: 20150468691-01

Principal Product Type: Equity Listed (Common & Preferred Stock)


Allegations: FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA") ALLEGEDTHAT, DURING THE PERIOD FROM APRIL 1, 2015 THROUGH JUNE 30, 2015,THE FIRM FAILED TO REPORT TO TRACE THE CORRECT TIME OF TRADEEXECUTION FOR 100 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATEDEBT SECURITIES, AND FAILED TO REPORT SUCH TRANSACTIONS WITHINTHE TIMEFRAME REQUIRED BY FINRA RULE 6730. FINRA FURTHERALLEGED THAT THE FIRM FAILED TO SHOW THE CORRECT TIME OFEXECUTION ON THE BROKERAGE ORDER MEMORANDA FOR SUCHTRANSACTIONS IN ALLEGED VIOLATION OF SEC RULE 17A-3 AND FINRARULE 4511.


Resolution:


Sanction Details: A FINE OF $7,500



Disclosure 2 of 10

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Initiated By: FINRA

Allegations: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRMCONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THATIT IMPROPERLY MADE PAYMENTS FOR ORDER FLOW TO ANUNREGISTERED ENTITY, IN CONNECTION WITH TRADES DETAILED IN THEENTITY'S INVOICES. THE FINDINGS STATED THAT THE ENTITY, WHICHENGAGED IN TRADING AND RESEARCH ON EXCHANGE TRADED FUNDSFOR INSTITUTIONAL CUSTOMERS, HAS NEVER BEEN A FINRA MEMBER ORA REGISTERED BROKER-DEALER.







Initiated By: FINRA





Principal Product Type: No Product



Resolution:


Sanction Details: THE FIRM WAS CENSURED AND FINED $15,000.

FINE PAID IN FULL ON SEPTEMBER 7, 2016.


No




Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA")




Allegations: FROM JANUARY 2011 THROUGH NOVEMBER 2011, THE FIRM MADEPAYMENTS FOR ORDER FLOW TOTALING APPROXIMATELY $30,439 TO ANUNREGISTERED ENTITY, IN VIOLATION OF NASD RULE 2420 AND FINRARULE 2010.














Resolution:


Sanction Details: A FINE OF $15,000



Disclosure 3 of 10

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Initiated By: FINRA


Other


N/A





Allegations: FINRA RULE 2010, NASD RULES 2711(G)(2), 2711(G)(3), 2711(H)(1)(A): THEFIRM ISSUED FOUR RESEARCH REPORTS ON A COMPANY BUT FAILED TODISCLOSE IN THEM THAT A MEMBER OF A FIRM RESEARCH ANALYST'SHOUSEHOLD HAD A FINANCIAL INTEREST IN THE COMPANY'S SECURITIES.WHEN TRANSACTIONS IN THE RESEARCH ANALYST'S HOUSEHOLDACCOUNTS INVOLVING THE COMPANY'S SECURITIES WERE PROSCRIBEDUNDER NASD RULE 2711(G)(2), A TOTAL OF 675 SHARES OF THECOMPANY'S COMMON STOCK WERE SOLD IN THE HOUSEHOLDACCOUNTS IN 11 TRANSACTIONS, SIX OF WHICH WERE INCONSISTENTWITH THE "HOLD" RECOMMENDATION CONTAINED IN THE MOST RECENTRESEARCH REPORT THE FIRM HAD PUBLISHED.









Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $10,000. FINE PAID IN FULL APRIL24, 2012.


No




Initiated By: FINRA


Other






Allegations: FINRA RULE 2010, NASD RULES 2711(G)(2), 2711(G)(3), 2711(H)(1)(A): THEFIRM ISSUED FOUR RESEARCH REPORTS ON A COMPANY BUT FAILED TODISCLOSE IN THEM THAT A MEMBER OF A FIRM RESEARCH ANALYST'SHOUSEHOLD HAD A FINANCIAL INTEREST IN THE COMPANY'S SECURITIES.WHEN TRANSACTIONS IN THE RESEARCH ANALYST'S HOUSEHOLDACCOUNTS INVOLVING THE COMPANY'S SECURITIES WERE PROSCRIBEDUNDER NASD RULE 2711(G)(2), A TOTAL OF 675 SHARES OF THECOMPANY'S COMMON STOCK WERE SOLD IN THE HOUSEHOLDACCOUNTS IN 11 TRANSACTIONS, SIX OF WHICH WERE INCONSISTENTWITH THE "HOLD" RECOMMENDATION CONTAINED IN THE MOST RECENTRESEARCH REPORT THE FIRM HAD PUBLISHED.










Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $10,000



Disclosure 4 of 10

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Initiated By: FINRA


Other


N/A



Principal Product Type: Options


Allegations: FINRA RULE 2010, NASD RULE 1021: AT ALL TIMES RELEVANT HEREIN, THEFIRM MAINTAINED A BRANCH OFFICE IN NEW YORK CITY AT WHICH ITEFFECTED OPTIONS TRANSACTIONS, PREDOMINANTLY FORINSTITUTIONAL CUSTOMERS. THE FIRM DESIGNATED AN INDIVIDUAL TOBE THE MANAGER OF THAT OFFICE. THE INDIVIDUAL WAS REGISTEREDWITH FINRA AS A GENERAL SECURITIES PRINCIPAL BUT NOT AS AREGISTERED OPTIONS AND SECURITY FUTURES (ROSF) PRINCIPAL. THEFIRM PERMITTED THE INDIVIDUAL TO SUPERVISE OPTIONSTRANSACTIONS EFFECTED IN THE BRANCH OFFICE AND OTHERWISEENGAGE IN ACTIVITIES REQUIRING REGISTRATION AS A ROSF PRINCIPALEVEN THOUGH HE WAS NOT REGISTERED WITH FINRA IN THAT CAPACITY.



Resolution: Acceptance, Waiver & Consent(AWC)









Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE IT IS CENSURED AND FINED $20,000.


No



Initiated By: FINRA


Other


N/A



Principal Product Type: Options


Allegations: FINRA RULE 2010, NASD RULE 1021: AT ALL TIMES RELEVANT HEREIN, THEFIRM MAINTAINED A BRANCH OFFICE IN NEW YORK CITY AT WHICH ITEFFECTED OPTIONS TRANSACTIONS, PREDOMINANTLY FORINSTITUTIONAL CUSTOMERS. THE FIRM DESIGNATED AN INDIVIDUAL TOBE THE MANAGER OF THAT OFFICE. THE INDIVIDUAL WAS REGISTEREDWITH FINRA AS A GENERAL SECURITIES PRINCIPAL BUT NOT AS AREGISTERED OPTIONS AND SECURITY FUTURES (ROSF) PRINCIPAL. THEFIRM PERMITTED THE INDIVIDUAL TO SUPERVISE OPTIONSTRANSACTIONS EFFECTED IN THE BRANCH OFFICE AND OTHERWISEENGAGE IN ACTIVITIES REQUIRING REGISTRATION AS A ROSF PRINCIPALEVEN THOUGH HE WAS NOT REGISTERED WITH FINRA IN THAT CAPACITY.


Resolution: Acceptance, Waiver & Consent(AWC)33©2020 FINRA. All rights reserved. Report about SUSQUEHANNA FINANCIAL GROUP, LLLP







Resolution:





Disclosure 5 of 10

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Initiated By: FINRA







Allegations: SEC RULE 10B-10, FINRA RULE 7450 - SUSQUEHANNA FINANCIAL GROUP,LLLP TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA: REPORTS DID NOT INCLUDE THE "NOT HELD"CONDITION, ONE REPORT CONTAINED AN INCORRECT DESTINATIONCODE; THE FIRM SUBMITTED ONE INCORRECT CANCEL/REPLACE REPORTAND THE FIRM SUBMITTED ONE INCORRECT DESK REPORT. THE FIRMFAILED TO DISCLOSE ACCURATE INFORMATION ON CUSTOMERCONFIRMATIONS: THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATIONDISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY INTRANSACTIONS AND ON ONE OCCASION, THE FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE.



Resolution: Acceptance, Waiver & Consent(AWC)








Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED AND FINED $7,500.


No



Initiated By: FINRA







Allegations: SEC RULE 10B-10, FINRA RULE 7450 - SUSQUEHANNA FINANCIAL GROUP,LLLP TRANSMITTED REPORTS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLYFORMATTED DATA: REPORTS DID NOT INCLUDE THE "NOT HELD"CONDITION, ONE REPORT CONTAINED AN INCORRECT DESTINATIONCODE; THE FIRM SUBMITTED ONE INCORRECT CANCEL/REPLACE REPORTAND THE FIRM SUBMITTED ONE INCORRECT DESK REPORT. THE FIRMFAILED TO DISCLOSE ACCURATE INFORMATION ON CUSTOMERCONFIRMATIONS: THE FIRM FAILED TO PROVIDE WRITTEN NOTIFICATIONDISCLOSING TO ITS CUSTOMER ITS CORRECT CAPACITY INTRANSACTIONS AND ON ONE OCCASION, THE FIRM FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMER THAT THETRANSACTION WAS EXECUTED AT AN AVERAGE PRICE.









Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM WAS CENSURED AND FINED $7,500.



Disclosure 6 of 10

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Initiated By: FINRA


Other


N/A





Allegations: FINRA RULES 2010, 6730: SUSQUEHANNA FINANCIAL GROUP EFFECTEDABOUT 1,848 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE BONDS ASAGENT FOR AN AFFILIATED CUSTOMER. IN REPORTING THOSETRANSACTIONS TO TRACE, THE FIRM INCORRECTLY REPORTED ITSCAPACITY AS PRINCIPAL AND, WITH RESPECT TO EACH TRANSACTION,FAILED TO REPORT THE CUSTOMER SIDE TO TRACE AS REQUIRED.



Resolution:


No











No



Initiated By: FINRA


Other






Allegations: FINRA RULES 2010, 6730: SUSQUEHANNA FINANCIAL GROUP EFFECTEDABOUT 1,848 TRANSACTIONS IN TRACE-ELIGIBLE CORPORATE BONDS ASAGENT FOR AN AFFILIATED CUSTOMER. IN REPORTING THOSETRANSACTIONS TO TRACE, THE FIRM INCORRECTLY REPORTED ITSCAPACITY AS PRINCIPAL AND, WITH RESPECT TO EACH TRANSACTION,FAILED TO REPORT THE CUSTOMER SIDE TO TRACE AS REQUIRED.



Resolution:












Disclosure 7 of 10

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Initiated By: FINRA







Allegations: NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLLPTRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDERAUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FORCONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRMFAILED TO REPAIR SOME OF THE REJECTED ROES SO THAT THE FIRMFAILED TO TRANSMIT THEM TO OATS.



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CENSURED AND FINED $12,500.


No










Initiated By: FINRA







Allegations: NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLLPTRANSMITTED REPORTABLE ORDER EVENTS (ROES) TO THE ORDERAUDIT TRAIL SYSTEM (OATS) THAT WERE REJECTED BY OATS FORCONTEXT OR SYNTAX ERRORS AND WERE REPAIRABLE BUT THE FIRMFAILED TO REPAIR SOME OF THE REJECTED ROES SO THAT THE FIRMFAILED TO TRANSMIT THEM TO OATS.



Resolution:





Disclosure 8 of 10

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Allegations: MSRB RULE G-14 - SUSQUEHANNA FINANCIAL GROUP LLLP FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL,SPECIFICALLY THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.








Initiated By: FINRA





Principal Product Type: Debt - Municipal


MSRB RULE G-14 - SUSQUEHANNA FINANCIAL GROUP LLLP FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL,SPECIFICALLY THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.


No

Sanctions Ordered: Monetary/Fine $5,000.00



Allegations: MSRB RULE G-14 - SUSQUEHANNA FINANCIAL GROUP LLLP FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL,SPECIFICALLY THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.







Initiated By: FINRA





Principal Product Type: Debt - Municipal


MSRB RULE G-14 - SUSQUEHANNA FINANCIAL GROUP LLLP FAILED TOREPORT INFORMATION REGARDING PURCHASE AND SALETRANSACTIONS EFFECTED IN MUNICIPAL SECURITIES TO THE REAL-TIMETRANSACTION REPORTING SYSTEM (RTRS) IN THE MANNER PRESCRIBEDBY RULE G-14 RTRS PROCEDURES AND THE RTRS USERS MANUAL,SPECIFICALLY THE FIRM FAILED TO REPORT INFORMATION ABOUT SUCHTRANSACTIONS WITHIN 15 MINUTES OF TIME OF TRADE TO AN RTRSPORTAL.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS FINED $5,000.

Sanctions Ordered: Monetary/Fine $5,000.00


Disclosure 9 of 10

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Allegations: NASD RULE 3370 - SUSQUEHANNA FINANCIAL GROUP, LLLP ACCEPTEDCUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND FOREACH ORDER, FAILED TO MAKE AN AFFIRMATIVE DETEMINATION THAT THEFIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THECUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ONBEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; NONEOF THE EXECUTIONS OF THESE ORDERS RESULTED IN A FAIL TO DELIVER.FOLLOWING A REFERRAL FROM THE NASDAQ ISSUER SERVICE, FINRAREVIEWED THE FIRM'S ACTIVITY IN A PARTICULAR SECURITY.SUSQUEHANNA ACCEPTED CUSTOMER SHORT SALE ORDERS IN THESECURITY AND FOR EACH ORDER, FAILED TO MAKE AN AFFIRMATIVEDETEMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THESECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULDBORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERYBY SETTLEMENT DATE; NONE OF THE EXECUTIONS OF THESE ORDERSRESULTED IN A FAIL TO DELIVER.







Initiated By: FINRA





Principal Product Type: Other

Other Product Type(s): UNKNOWN TYPE OF SECURITIES

NASD RULE 3370 - SUSQUEHANNA FINANCIAL GROUP, LLLP ACCEPTEDCUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND FOREACH ORDER, FAILED TO MAKE AN AFFIRMATIVE DETEMINATION THAT THEFIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THECUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ONBEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; NONEOF THE EXECUTIONS OF THESE ORDERS RESULTED IN A FAIL TO DELIVER.FOLLOWING A REFERRAL FROM THE NASDAQ ISSUER SERVICE, FINRAREVIEWED THE FIRM'S ACTIVITY IN A PARTICULAR SECURITY.SUSQUEHANNA ACCEPTED CUSTOMER SHORT SALE ORDERS IN THESECURITY AND FOR EACH ORDER, FAILED TO MAKE AN AFFIRMATIVEDETEMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THESECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULDBORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERYBY SETTLEMENT DATE; NONE OF THE EXECUTIONS OF THESE ORDERSRESULTED IN A FAIL TO DELIVER.


Resolution:




No




Allegations: NASD RULE 3370 - SUSQUEHANNA FINANCIAL GROUP, LLLP ACCEPTEDCUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND FOREACH ORDER, FAILED TO MAKE AN AFFIRMATIVE DETEMINATION THAT THEFIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THECUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ONBEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; NONEOF THE EXECUTIONS OF THESE ORDERS RESULTED IN A FAIL TO DELIVER.FOLLOWING A REFERRAL FROM THE NASDAQ ISSUER SERVICE, FINRAREVIEWED THE FIRM'S ACTIVITY IN A PARTICULAR SECURITY.SUSQUEHANNA ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAINSECURITIES AND FOR EACH ORDER, FAILED TO MAKE AN AFFIRMATIVEDETEMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THESECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULDBORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERYBY SETTLEMENT DATE; NONE OF THE EXECUTIONS OF THESE ORDERSRESULTED IN A FAIL TO DELIVER.








Initiated By: FINRA







Other Product Type(s): UNKNOWN

NASD RULE 3370 - SUSQUEHANNA FINANCIAL GROUP, LLLP ACCEPTEDCUSTOMER SHORT SALE ORDERS IN CERTAIN SECURITIES AND FOREACH ORDER, FAILED TO MAKE AN AFFIRMATIVE DETEMINATION THAT THEFIRM WOULD RECEIVE DELIVERY OF THE SECURITY ON BEHALF OF THECUSTOMER OR THAT THE FIRM COULD BORROW THE SECURITY ONBEHALF OF THE CUSTOMER FOR DELIVERY BY SETTLEMENT DATE; NONEOF THE EXECUTIONS OF THESE ORDERS RESULTED IN A FAIL TO DELIVER.FOLLOWING A REFERRAL FROM THE NASDAQ ISSUER SERVICE, FINRAREVIEWED THE FIRM'S ACTIVITY IN A PARTICULAR SECURITY.SUSQUEHANNA ACCEPTED CUSTOMER SHORT SALE ORDERS IN CERTAINSECURITIES AND FOR EACH ORDER, FAILED TO MAKE AN AFFIRMATIVEDETEMINATION THAT THE FIRM WOULD RECEIVE DELIVERY OF THESECURITY ON BEHALF OF THE CUSTOMER OR THAT THE FIRM COULDBORROW THE SECURITY ON BEHALF OF THE CUSTOMER FOR DELIVERYBY SETTLEMENT DATE; NONE OF THE EXECUTIONS OF THESE ORDERSRESULTED IN A FAIL TO DELIVER.


Resolution:





Disclosure 10 of 10

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Allegations: SEC RULES 10B-10, 11AC1-6 N/K/A SEC RULE 606 OF REGULATION NMS,NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLPTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATTRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE AND FAILED ONONE OCCASION TO REFLECT THE CORRECT EXECUTION VENUE ON THECONFIRMATION; AND THE FIRM FAILED TO PROPERLY CHARACTERIZE AS "OTHER" NOT-HELD ORDERS IN A QUARTERLY REPORT ON ITS ROUTINGOF NON-DIRECTED ORDERS IN COVERED SECURITIES DURING THATQUARTER.







Initiated By: NASD






Other Product Type(s): UNKNOWN TYPE OF SECURITIES

SEC RULES 10B-10, 11AC1-6 N/K/A SEC RULE 606 OF REGULATION NMS,NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLPTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATTRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE AND FAILED ONONE OCCASION TO REFLECT THE CORRECT EXECUTION VENUE ON THECONFIRMATION; AND THE FIRM FAILED TO PROPERLY CHARACTERIZE AS "OTHER" NOT-HELD ORDERS IN A QUARTERLY REPORT ON ITS ROUTINGOF NON-DIRECTED ORDERS IN COVERED SECURITIES DURING THATQUARTER.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;THEREFORE, THE FIRM IS CNESURED AND FINED $25,000.


No




Allegations: SEC RULES 10B-5, 11AC1-6 N/K/A SEC RULE 606 OF REGULATION NMS,NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLPTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATTRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE AND FAILED ONONE OCCASION TO REFLECT THE CORRECT EXECUTION VENUE ON THECONFIRMATION; AND THE FIRM FAILED TO PROPERLY CHARACTERIZE AS "OTHER" NOT-HELD ORDERS IN A QUARTERLY REPORT ON ITS ROUTINGOF NON-DIRECTED ORDERS IN COVERED SECURITIES DURING THATQUARTER.








Initiated By: NASD


Censure


FINED



Principal Product Type: Equity - OTC


SEC RULES 10B-5, 11AC1-6 N/K/A SEC RULE 606 OF REGULATION NMS,NASD RULE 6955(A) - SUSQUEHANNA FINANCIAL GROUP, LLPTRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE,INCOMPLETE OR IMPROPERLY FORMATTED DATA; FAILED TO PROVIDEWRITTEN NOTIFICATION DISCLOSING TO ITS CUSTOMERS THATTRANSACTIONS WERE EXECUTED AT AN AVERAGE PRICE AND FAILED ONONE OCCASION TO REFLECT THE CORRECT EXECUTION VENUE ON THECONFIRMATION; AND THE FIRM FAILED TO PROPERLY CHARACTERIZE AS "OTHER" NOT-HELD ORDERS IN A QUARTERLY REPORT ON ITS ROUTINGOF NON-DIRECTED ORDERS IN COVERED SECURITIES DURING THATQUARTER.


Resolution:










End of Report

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