* * * * * * * * * * * * * * * * * * IN THE MATTER OF:  SILVER OAK SECURITIES, INCORPORATED CRD No. 46947     * * * * * * * * * * * * * * * * * *

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CONSENT ORDER No. CO-16-8056-S

WHEREAS, Silver Oak Securities, Incorporated (“Silver Oak”) is a broker-dealer and an investment adviser with its principal office located at 3339 North Highland Avenue, Jackson, Tennessee 38305.  Silver Oak has been registered as a broker-dealer under Chapter 672a of the General Statutes of Connecticut, the Connecticut Uniform Securities Act (“Act”), since February 7, 2007.  Silver Oak has been registered with the Securities and Exchange Commission (the “SEC”) (SEC No. 801-71178) as an investment adviser since September 28, 2012, and has filed the notice required by Section 36b-6(e) of the Act.  Silver Oak maintains a branch office at 100 Great Meadow Road, Suite 502, Wethersfield, Connecticut 06109 (“Wethersfield Branch”).  Sharing office space at the Wethersfield location is JB Capital LLC, an SEC-registered investment adviser (CRD No. 171168) since May 9, 2014, whose chief executive officer is Joel Mark Johnson (“Johnson”).  Registered Agents of Silver Oak associated with the Wethersfield Branch conduct investment-related activities under the name “Johnson Brunetti”;

WHEREAS, the Banking Commissioner (“Commissioner”) is charged with the administration of the Act and Sections 36b-31-2 to 36b-31-33, inclusive, of the Regulations of Connecticut State Agencies (“Regulations”) promulgated under the Act;

WHEREAS, the Commissioner, through the Securities and Business Investments Division (“Division”) of the Department of Banking, conducted an examination of Silver Oak pursuant to Section 36b-14(d) of the Act and 36b-31-14f of the Regulations, and a related investigation of Silver Oak under Section 36b-26 of the Act to determine whether Silver Oak had violated, was violating or was about to violate any provision of Act or any regulation or order under the Act (the “Investigation and Examination”);

WHEREAS, the Investigation and Examination cited certain irregularities and deficiencies involving, inter alia, Silver Oak’s supervisory system; the use of signature stamps by Silver Oak and its agents, Silver Oak’s employment of an unregistered investment adviser agent from September 2012 to November 2012; and Silver Oak’s books and records relating to the sale of alternative investments;

WHEREAS, as a result of the Investigation and Examination, the Commissioner has reason to believe that the foregoing conduct violates certain provisions of the Act and Regulations, and would support administrative proceedings against Silver Oak under Sections 36b-15 and 36b-27 of the Act;

WHEREAS, the Commissioner acknowledges that Silver Oak has cooperated with the Division during the Investigation and Examination and that Silver Oak has submitted to the Division the remedial Undertakings described in Section IV of this Consent Order, some of which Silver Oak instituted on its own initiative prior to entry of this Consent Order;

WHEREAS, Section 36b-31(a) of the Act provides, in relevant part, that “[t]he commissioner may from time to time make . . . such . . . orders as are necessary to carry out the provisions of sections 36b-2 to 36b-34, inclusive”;

WHEREAS, Section 36b-31(b) of the Act provides, in relevant part, that “[n]o . . . order may be made . . . unless the commissioner finds that the action is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of sections 36b-2 to 36b-34, inclusive”;

WHEREAS, an administrative proceeding initiated under Sections 36b-15 and 36b-27 of the Act would constitute a “contested case” within the meaning of Section 4-166(4) of the General Statutes of Connecticut, as amended by Public Act 15-61;

WHEREAS, Section 4-177(c) of the General Statutes of Connecticut and Section 36a-1-55(a) of the Regulations provide that a contested case may be resolved by consent order, unless precluded by law;

WHEREAS, without holding a hearing and without trial or adjudication of any issue of fact or law, and prior to the initiation of any formal proceeding, the Commissioner and Silver Oak reached an agreement, the terms of which are reflected in this Consent Order, in full and final resolution of the matters described herein;

WHEREAS, Silver Oak expressly consents to the Commissioner’s jurisdiction under the Act and to the terms of this Consent Order;

WHEREAS, the Commissioner finds that the issuance of this Consent Order is necessary or appropriate in the public interest or for the protection of investors and consistent with the purposes fairly intended by the policy and provisions of the Act;

AND WHEREAS, Silver Oak, through its execution of this Consent Order, specifically represents and agrees that none of the violations alleged in this Consent Order shall occur in the future.   

In witness whereof I hereunto set my hand.
  

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