Firm profile

Founders Financial Securities, LLC

TOWSON, MDCRD 137945Registration Status: ApprovedEffective since July 13, 2006SEC # 801-66892Latest ADV April 20, 2026

Founders Financial Securities, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in Towson, MD. Its latest Form ADV filing, dated April 20, 2026, reports $4.1B in regulatory assets under management, 139 employees, 69 offices, and 19,082 accounts.

Assets Under Management
$4.1B
Employees
139
Offices
69 offices
Total Clients
9,870

Associated firm names

98 names listed
  • 7 PILLARS WEALTH MANAGEMENT
  • ZINAICH CAPITAL & RISK MANAGEMENT
  • WELCH BENEFIT GROUP
  • WEINBERG FINANCIAL ADVISORY

Leadership

2 roles identified
CEOBradley Matthew Shepherd
CCOJoseph Victor Krcma

Advisory services offered

5 types reported
Financial Planning Services
Pension consulting services
Portfolio management for businesses

Fee models offered

4 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

TOWSON, Maryland, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Maryland

TOWSONPrimary office · TIMONIUM · FREDERICK · COLUMBIA · FINKSBURG · BEL AIR · LUTHERVILLE-TIMONIUM

California

FRESNO

Massachusetts

ATHOL

Michigan

BRIGHTON · LANSING

New Hampshire

SALEM

Ohio

CENTERVILLE · MILFORD

Oregon

OREGON CITY

Pennsylvania

LEBANON · WEST CHESTER · CHADS FORD

Washington

BELLINGHAM

West Virginia

MARTINSBURG

Wisconsin

CEDARBURG

24 office records listed · 69 total offices reported. 2 additional office addresses are undisclosed and are not mapped. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$4.1Bas of April 20, 2026
Discretionary88.5%
$3.7B
88% of total RAUM88.5%
Non-discretionary11.5%
$477M
12% of total RAUM11.5%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 82.3% of total clients.
Top client categories% of clientsClients
1
Individuals
82.3%
8,124
2
HNWI
14.9%
1,466
3
Pension Plans
2.4%
241
4
Charitable
0.2%
22
5
Corporations
0.2%
17

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$4.1B
Total Accounts19,082
10Y AUM Change+$3.4B (+447.8%)

Private Funds

Private funds reported by Founders Financial Securities, LLC

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees139
Clients per Employee71:1
10Y Employee Change-34 (-19.7%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
FOUNDERS FINANCIAL LLCDirect owner · Schedule AInterest in FOUNDERS FINANCIAL SECURITIES, LLC
75%+
FOUNDERS FINANCIAL HOLDINGS INC.Indirect owner · Schedule BInterest in FOUNDERS FINANCIAL LLC
75%+
MICHAEL O BROOKS 2025 IRREVOCABLE TRUSTIndirect owner · Schedule BInterest in FOUNDERS FINANCIAL HOLDINGS INC.
50% to < 75%
KAREN E BROOKS 2025 IRREVOCABLE TRUSTIndirect owner · Schedule BInterest in FOUNDERS FINANCIAL HOLDINGS INC.
50% to < 75%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Founders Financial Securities, LLC.

Reported ownership and control details

Form ADV · Filing date 2026-04-20 · Schedules A and B

13 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1BRADLEY MATTHEW SHEPHERDCEO/ROSFPIndividualFOUNDERS FINANCIAL SECURITIES, LLCLess than 5%Code NAYesCEO/ROSFP06/2014Schedule APDF page 62
2FOUNDERS FINANCIAL LLCMEMBERDomestic entityFOUNDERS FINANCIAL SECURITIES, LLC75% or moreCode EYesMEMBER12/2022Schedule APDF page 62
3JOSEPH VICTOR KRCMACHIEF COMPLIANCE OFFICERIndividualFOUNDERS FINANCIAL SECURITIES, LLCLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER06/2014Schedule APDF page 62
4JILL ANNE RECKAMPFINOPIndividualFOUNDERS FINANCIAL SECURITIES, LLCLess than 5%Code NANoFINOP03/2015Schedule APDF page 62
5FOUNDERS FINANCIAL HOLDINGS INC.MEMBER FIRMDomestic entityFOUNDERS FINANCIAL LLC75% or moreCode EYesMEMBER FIRM12/2022Schedule BPDF page 63
6MICHAEL O BROOKS 2025 IRREVOCABLE TRUSTMEMBER FIRMDomestic entityFOUNDERS FINANCIAL HOLDINGS INC.50% to less than 75%Code DYesMEMBER FIRM01/2026Schedule BPDF page 63
7JEROME G. GERAGHTYTRUSTEEIndividualMICHAEL O BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE03/2025Schedule BPDF page 63
8KATELYN B. BUERLEINTRUSTEEIndividualMICHAEL O BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE03/2025Schedule BPDF page 63
9MELISSA B. GIESETRUSTEEIndividualMICHAEL O BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE03/2025Schedule BPDF page 63
10KAREN E BROOKS 2025 IRREVOCABLE TRUSTMEMBER FIRMDomestic entityFOUNDERS FINANCIAL HOLDINGS INC.50% to less than 75%Code DYesMEMBER FIRM01/2026Schedule BPDF page 63
11EMILY HELEN HUNTERTRUSTEEIndividualKAREN E BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE01/2026Schedule BPDF page 63
12JEROME G. GERAGHTYTRUSTEEIndividualKAREN E BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE01/2026Schedule BPDF page 63
13JARED MICHAEL BROOKSTRUSTEEIndividualKAREN E BROOKS 2025 IRREVOCABLE TRUSTPercentage not specifiedCode FNoTRUSTEE01/2026Schedule BPDF page 63

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 4/20/2026 12:46:54 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 1 source block

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 63–65
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 1,615,465.88
How was matter resolved — filed text
Order

Action status / disposition — filed text

RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE, AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $1,246,133.60 AND PREJUDGMENT INTEREST OF $229,332.28, SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $140,000 TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS TAKEN BY RESPONDENT, INCLUDING ENDING THE PRACTICE OF RECEIVING OR BENEFITING FROM 12B-1 FEES IN FEBRUARY 2017, AND REVISING ITS DISCLOSURES AND COMPLIANCE POLICIES AND PROCEDURES.
Other filed details

Description of allegations — filed text

SEC ADMIN RELEASE 34-87177; IA RELEASE 5397, SEPTEMBER 30, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST FOUNDERS FINANCIAL SECURITIES, LLC ("RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT RECEIVED OR BENEFITED FROM 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO ADEQUATELY DISCLOSE THE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. IN ADDITION, RESPONDENT BREACHED ITS DUTY TO SEEK BEST EXECUTION FOR ITS CLIENTS BY INVESTING THEM IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES RATHER THAN AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED, OR BENEFITED FROM, OVER $1.24 MILLION IN 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. RESPONDENT ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES. AS A RESULT OF ITS CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

Sanction detail — filed text

RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $1,246,133.60 AND PREJUDGMENT INTEREST OF $229,332.28, SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $140,000 TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
Full extracted filing text

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the

same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19570
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASE 34-87177; IA RELEASE 5397, SEPTEMBER 30, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND
IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST FOUNDERS FINANCIAL
SECURITIES, LLC ("RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS
ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE
CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR
HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME
FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT RECEIVED OR BENEFITED FROM 12B-1 FEES IN CONNECTION WITH THESE
INVESTMENTS. RESPONDENT FAILED TO ADEQUATELY DISCLOSE THE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND ITS

SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. IN ADDITION, RESPONDENT BREACHED ITS DUTY TO SEEK BEST EXECUTION FOR
ITS CLIENTS BY INVESTING THEM IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES RATHER THAN AVAILABLE LOWER-COST SHARE CLASSES OF THE
SAME FUNDS. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED, OR BENEFITED FROM, OVER $1.24 MILLION IN 12B-1 FEES FOR ADVISING
CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. RESPONDENT ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE
POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION
WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES. AS A RESULT OF ITS CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTION 206(2)
AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 1,615,465.88
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SEE BELOW
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2)
AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF
$1,246,133.60 AND PREJUDGMENT INTEREST OF $229,332.28, SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $140,000 TO THE
SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY AND SHALL COMPLY WITH
THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE, AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER.
ACCORDINGLY, IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF SECTION 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. RESPONDENT IS CENSURED,
SHALL PAY DISGORGEMENT OF $1,246,133.60 AND PREJUDGMENT INTEREST OF $229,332.28, SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF
$140,000 TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY AND SHALL
COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION
CONSIDERED REMEDIAL ACTS TAKEN BY RESPONDENT, INCLUDING ENDING THE PRACTICE OF RECEIVING OR BENEFITING FROM 12B-1 FEES IN
FEBRUARY 2017, AND REVISING ITS DISCLOSURES AND COMPLIANCE POLICIES AND PROCEDURES.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.