Palos Management Inc..

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
CRD
Number:
8001554
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Mendel, Robert, NMN
(For individuals, Last, First,
Middle)
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) 
SECURITIES EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST CENSURE

3.
Date Initiated (MM/DD/YYYY): 
07/05/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-22239
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
PALOS MANAGEMENT INC.
6.
Principal Product Type:
Penny Stock(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT PALOS, AN SEC REGISTERED INVESTMENT ADVISER WHOSE PRINCIPAL OFFICE AND PLACE OF BUSINESS IS LOCATED IN
CANADA, AND ONE OF ITS PORTFOLIO MANAGERS ACTING AS SUCH, MENDEL, ALSO LOCATED IN CANADA, ENGAGED IN CERTAIN ACTIVITIES WITHOUT
BEING PROPERLY REGISTERED AS A BROKER-DEALER, OR ASSOCIATED WITH A REGISTERED BROKER-DEALER, IN VIOLATION OF THE U.S. SECURITIES
EXCHANGE ACT OF 1934. SPECIFICALLY, THE SEC ALLEGED THAT FROM JULY 2019 UNTIL FEBRUARY 2022, MENDEL, AS AN ACCOMMODATION TO U.S.-
BASED CLIENTS, SOLD ILLIQUID SHARES OF STOCK, COMMONLY REFERRED TO AS PENNY STOCKS, THAT THEY OWNED, WITH THE EXPECTATION THAT
THE PROCEEDS OF THOSE SALES WOULD REMAIN IN THEIR ADVISORY ACCOUNTS FOR HIM TO MANAGE. MOST OF THOSE PROCEEDS WERE
WITHDRAWN BY THE CLIENTS INSTEAD OF MAINTAINED IN PALOS' ADVISORY ACCOUNTS FOR MENDEL TO MANAGE.
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):
10/15/2024
 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: $ 575,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
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: 
PALOS MANAGEMENT INC. WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $575,000. ITS NON-REGISTERED ASSOCIATED PERSON ,
ROBERT MENDEL, WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $35,000. BOTH THE FIRM AND MR. MENDEL WERE CENSURED. MR.
MENDEL WAS BARRED FROM ENGAGING IN TRANSACTIONS INVOLVING PENNY STOCKS IN ANY CAPACITY FOR A PERIOD OF 3 YEARS.
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).
ON OCTOBER 15, 2024, PALOS MANAGEMENT INC. ("PALOS"), AND ITS ASSOCIATED PERSON, ROBERT MENDEL ("MENDEL"), SETTLED AND CONSENTED
TO TWO ADMINISTRATIVE ORDERS ISSUED BY THE SECURITIES AND EXCHANGE COMMISSION, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS
MADE IN THOSE ORDERS (THE "ORDERS"). IN THE ORDERS, THE SEC ALLEGED THAT PALOS, AN SEC REGISTERED INVESTMENT ADVISER WHOSE
PRINCIPAL OFFICE AND PLACE OF BUSINESS IS LOCATED IN CANADA, AND ONE OF ITS PORTFOLIO MANAGERS ACTING AS SUCH, MENDEL, ALSO
LOCATED IN CANADA, ENGAGED IN CERTAIN ACTIVITIES WITHOUT BEING PROPERLY REGISTERED AS A BROKER-DEALER, OR ASSOCIATED WITH A
REGISTERED BROKER-DEALER, IN VIOLATION OF THE U.S. SECURITIES EXCHANGE ACT OF 1934. SPECIFICALLY, THE SEC ALLEGED THAT FROM JULY
2019 UNTIL FEBRUARY 2022, MENDEL, AS AN ACCOMMODATION TO U.S.-BASED CLIENTS, SOLD ILLIQUID SHARES OF STOCK, COMMONLY REFERRED TO
AS PENNY STOCKS, THAT THEY OWNED, WITH THE EXPECTATION THAT THE PROCEEDS OF THOSE SALES WOULD REMAIN IN THEIR ADVISORY
ACCOUNTS FOR HIM TO MANAGE. MOST OF THOSE PROCEEDS WERE WITHDRAWN BY THE CLIENTS INSTEAD OF MAINTAINED IN PALOS' ADVISORY
ACCOUNTS FOR MENDEL TO MANAGE. IN FEBRUARY 2022, PALOS TERMINATED THIS ACCOMMODATION SERVICE. THE ORDERS IMPOSED CENSURES AND

CEASE AND DESIST ORDERS ON PALOS AND MENDEL, IMPOSED FINES ON BOTH, AND IMPOSED A THREE-YEAR BAR ON MENDEL FROM ENGAGING IN
TRANSACTIONS INVOLVING PENNY STOCKS, WITH THE RIGHT TO REAPPLY THEREAFTER. ACCORDING TO THE SEC ORDER, THERE WERE NO FINDINGS
OF VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940.