Independent Financial Group, LLC

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:
2492578
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
YEE, TIMOTHY, RICHARD
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: $
 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: 

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).

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
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 

09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19550
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INDEPENDENT FINANCIAL GROUP, LLC
6.
Principal Product Type:
Money Market Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC IA RELEASE 40-5383, 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 INDEPENDENT FINANCIAL GROUP, 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 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO
DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF
MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO
INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTION 206(2) OF
THE ADVISERS ACT.
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: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
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: 
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION
206(2) OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $1,250,386.58 AND PREJUDGMENT INTEREST OF
$175,764.06, 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 IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE 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) OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $1,250,386.58 AND PREJUDGMENT INTEREST OF
$175,764.06, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. RESPONDENT SELF-REPORTED TO THE
COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE
INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY

RESPONDENT.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/23/2024
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
2023080627901
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE EXCESSIVE TRADING AND ASSURE COMPLIANCE
WITH REG BI, AND FAILED TO REASONABLY SUPERVISE A REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED FIVE CUSTOMERS' ACCOUNTS. THE
FINDINGS STATED THAT THE RESPONSIBILITY FOR REVIEWING ALERTS THAT FLAGGED POTENTIAL EXCESSIVE TRADING WAS SHARED BETWEEN
COMPLIANCE STAFF AND SUPERVISORY STAFF. THE FIRM'S WSPS MADE COMPLIANCE STAFF, WHO WERE NOT RESPONSIBLE FOR SUPERVISING
REGISTERED REPRESENTATIVES, RESPONSIBLE FOR REVIEWING AN EXCESSIVE TRADING REPORT AVAILABLE THROUGH THE FIRM'S CLEARING FIRM.
HOWEVER INSTEAD OF REVIEWING THE EXCESSIVE TRADING REPORT, THE FIRM'S COMPLIANCE STAFF REVIEWED AN INTERNAL EXCESSIVE TRADE
ALERT, WHICH SUFFERED FROM CERTAIN DEFICIENCIES OF WHICH THE FIRM WAS UNAWARE. THE FIRM'S PROCEDURES FAILED TO PROVIDE
REASONABLE GUIDANCE ABOUT HOW COMPLIANCE PERSONNEL SHOULD CONDUCT REVIEW OF EXCESSIVE TRADE ALERTS OR WHEN THEY SHOULD
TAKE ACTION BASED UPON THE INFORMATION CONTAINED IN THOSE ALERTS AND DID NOT INCLUDE GUIDANCE ON THE USE OF COST-TO-EQUITY
RATIOS OR GUIDANCE ON WHAT TURNOVER RATES COULD SIGNAL EXCESSIVE TRADING. WHEN THE FIRM'S COMPLIANCE STAFF REVIEWED EXCESSIVE
TRADE ALERTS, THEY FREQUENTLY CLOSED THEM WITHOUT CONDUCTING FURTHER INVESTIGATION INTO WHETHER THE TRADING WAS CONSISTENT
WITH THE CUSTOMER'S BEST INTEREST. IN ADDITION, THE FIRM'S WSPS CONTAINED A PROVISION MAKING SUPERVISORY STAFF RESPONSIBLE FOR
IDENTIFYING POTENTIAL EXCESSIVE TRADING THROUGH THEIR OVERALL REVIEW OF CLIENT TRANSACTIONS APPEARING ON TRADE BLOTTERS AND
TRADE-BY-TRADE ALERTS. A SENIOR SUPERVISOR AT THE FIRM, HOWEVER, INSTRUCTED SUPERVISORY PERSONNEL TO ASSESS EACH ALERT ONLY AS IT
PERTAINED TO THE SPECIFIC TRADE GENERATING THE ALERT. THE FIRM FAILED TO PROVIDE THE FIRM'S SUPERVISORY STAFF WITH PROCEDURES,
TOOLS, OR TRAINING TO IDENTIFY POTENTIAL EXCESSIVE TRADING BY ASSESSING ASERIES OF TRANSACTIONS AND PROVIDED NO GUIDANCE TO
SUPERVISORS REGARDING WHAT FACTORS MIGHT SUGGEST THAT A REPRESENTATIVE WAS EXCESSIVELY TRADING AN ACCOUNT OR WHAT STEPS THEY
SHOULD TAKE IF THEY IDENTIFIED POTENTIAL EXCESSIVE TRADING. A REPRESENTATIVE EXCESSIVELY TRADEDFIVE CUSTOMERS' ACCOUNTS,
DIRECTING FREQUENT IN-AND-OUT TRADING AND CAUSING A LEVEL OFTRADING THAT WAS INCONSISTENT WITH THE CUSTOMERS' INVESTMENT
PROFILES AND THAT WAS NOT INTHEIR BEST INTEREST OR WAS NOT SUITABLE. COLLECTIVELY, THESE CUSTOMERS PAID MORE THAN $2.2MILLION IN
TOTAL TRADING COSTS AND INCURRED REALIZED LOSSES TOTALING APPROXIMATELY $2.2MILLION. THE FINDINGS ALSO STATED THAT THE FIRM
FAILED TO TIMELY AND COMPLETELY RESPOND TOFINRA RULE 8210 REQUESTS. FINRA SENT THE FIRM A REQUEST FOR, AMONG OTHER THINGS,
DOCUMENTATION OF ITS SUPERVISORY REVIEW OF ALL EXCEPTIONS, ALERTS, OR OTHER DOCUMENTS TOSUPERVISE FOR EXCESSIVE TRADING, ACTIVE
ACCOUNTS, AND EXCESSIVE COMMISSIONS FOR CUSTOMERSOF THE REPRESENTATIVE. THE FIRM'S RESPONSE TO THAT REQUEST WAS INCOMPLETE
BECAUSE IT FAILED TOINCLUDE ANY OF THE EXCESSIVE TRADING REPORTS AVAILABLE THROUGH ITS CLEARING FIRM AND FAILED TO INCLUDE ANY
EXCESSIVE TRADE ALERTS THAT HAD STOPPED APPEARING ON THE FIRM'S SYSTEM. FINRA SENT A SERIES OF FOLLOW-UP REQUESTS TO THE FIRM TO
ASCERTAIN THE COMPLETENESS OF THE FIRM'S RESPONSE. AFTER MULTIPLE DISCUSSIONS WITH FINRA, THE FIRM CONTACTED THE SERVICE
PROVIDER THAT GENERATED THE FIRM'S EXCESSIVE TRADE ALERTS AND BECAME AWARE THAT EXCESSIVE TRADE ALERTS COULD AND HAD STOPPED
APPEARING EVEN IF THEY HAD NOT BEEN CLEARED. THE FIRM THEN MADE A COMPLETE PRODUCTION OF ALL EXCESSIVE TRADE ALERTS AND THE
EXCESSIVE TRADE REPORTS.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/23/2024
 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: $ 500,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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: 
THE FIRM WAS CENSURED, FINED $500,000, AND REQUIRED TO CERTIFY THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND
IMPLEMENTED A REASONABLY DESIGNED SUPERVISORY SYSTEM, INCLUDING WSPS. ALL CUSTOMERS HAVE ALREADY EITHER RECEIVED
RESTITUTION OR ARE EXPECTED TO RECEIVE FULL RESTITUTION THROUGH A SEPARATE AGREEMENT.
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).
BETWEEN JULY 2020 AND DECEMBER 2022, IFG (1) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS,
REASONABLY DESIGNED TO SUPERVISE ACTIVELY TRADED ACCOUNTS AND ACHIEVE COMPLIANCE WITH REGULATION BI AND FINRA RULE 2111 AS
THEY PERTAIN TO EXCESSIVE TRADING, AND (2) FAILED TO REASONABLY SUPERVISE A REGISTERED REPRESENTATIVE WHO EXCESSIVELY TRADED FIVE
CUSTOMERS' ACCOUNTS, IN VIOLATION OF FINRA RULES 3110 AND 2010.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/27/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021069460001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
529 SAVINGS PLAN
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO SUPERVISE REPRESENTATIVES' RECOMMENDATIONS TO CUSTOMERS
THAT THEY ROLLOVER 529 SAVINGS PLAN INVESTMENTS FROM ONE STATE PLAN TO ANOTHER. THE FINDINGS STATED THAT THE FIRM DID NOT HAVE
PROCEDURES IN PLACE TO ALERT REPRESENTATIVES WHO RECOMMENDED 529 PLAN STATE-TO-STATE ROLLOVERS OF THE POTENTIAL AVAILABILITY
OF CLASS AR SALES CHARGE WAIVERS OR CLASS A SHARES FOR 529 PLAN ROLLOVERS. THE FIRM ALSO DID NOT OFFER TRAINING TO
REPRESENTATIVES REGARDING SALES CHARGE WAIVERS OR THE AVAILABILITY OF CLASS AR SHARES AND FAILED TO PROVIDE SUPERVISORS WITH
GUIDANCE OR TRAINING ON HOW TO REVIEW RECOMMENDED 529 PLAN ROLLOVER TRANSACTIONS TO IDENTIFY INSTANCES WHERE THERE MIGHT
HAVE BEEN AN AVAILABLE CLASS A SALES CHARGE WAIVERS OR CLASS AR SHARES. ALTHOUGH THE FIRM REVISED ITS WSPS TO DIRECT
REPRESENTATIVES TO CONFIRM WITH THE APPLICABLE PLAN SPONSOR IF A CLIENT IS ENTITLED TO A SALES CHARGE WAIVER OR CLASS AR SHARE
WHEN COMPLETING A 529 PLAN STATE-TO-STATE ROLLOVER, THEY FAIL TO ARTICULATE THE FIRM'S POLICY REGARDING WHETHER TO PROVIDE
CUSTOMERS WITH A SALES CHARGEWAIVER OR CLASS AR SHARE. IN ADDITION, THE REVISED WSPS DO NOT ESTABLISH ANY SYSTEM FOR MONITORING
AND REVIEWING THE APPLICATION OF AVAILABLE SALES CHARGE WAIVERS OR CLASS ARSHARES FOR ELIGIBLE CUSTOMERS. FURTHER, THE FIRM FIRST
PROVIDED TRAINING THAT APPRISED REPRESENTATIVES OF THE POTENTIAL AVAILABILITY OF SALES CHARGE WAIVERS FOR 529 PLAN ROLLOVERS,
HOWEVER THE TRAINING DID NOT ADDRESS THE FIRM'S POLICY OR INFORMATION REGARDING WHETHER TO PROVIDE CUSTOMERS WITH A SALES
CHARGE WAIVER OR CLASS AR SHARE. AS A RESULT, THE FIRM FAILED TO CONSISTENTLY APPLY AVAILABLE SALES CHARGE WAIVERS, IMPACTING AT
LEAST 18 CUSTOMERS IN WHICH TOTAL ROLLOVER DOLLARS TOTALED AT LEAST $837,000, RESULTING IN AT LEAST $17,000 IN SALES CHARGES AND
FEES THAT, HAD THE WAIVER BEEN GRANTED, WOULD NOT HAVE BEEN CHARGED.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
11/27/2024
 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: $ 75,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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: 
THE FIRM WAS CENSURED, FINED $75,000, ORDERED TO PAY RESTITUTION, PLUS INTEREST, TO CURRENT AND FORMER CUSTOMERS WHO
QUALIFIED FOR BUT DID NOT RECEIVE THE APPLICABLE SALES CHARGE WAIVER OR CLASS AR SHARES IN CONNECTION WITH RECOMMENDED
STATE-TO-STATE 529 ROLLOVERS IN THE AMOUNT TO BE DETERMINED BY THE THIRD-PARTY OUTSIDE CONSULTANT, AND REQUIRED TO
CONTINUE TO RETAIN THE THIRD-PARTY OUTSIDE CONSULTANT, AT ITS OWN EXPENSE TO REVIEW THE ADEQUACY OF THE FIRM'S COMPLIANCE
WITH MSRB RULE G-27 AND REG BI'S COMPLIANCE OBLIGATION,INCLUDING BUT NOT LIMITED TO ITS WSPS, CONTROLS AND TRAINING RELATED
TO SALES CHARGE WAIVERS OR CLASS AR SHARES IN CONNECTION WITH 529 PLAN ROLLOVER RECOMMENDATIONS, AND IDENTIFY THE
ELIGIBLE CURRENT AND FORMER CUSTOMERS AND CALCULATE THE AMOUNT OFRESTITUTION THEY ARE OWED.
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).
TIME PERIOD EXAMINED WAS 9/2015 TO 12/2021. DURING THAT TIMEFRAME THERE WERE HUNDREDS OF TRANSACTIONS. AS NOTED, THE IMPACT WAS
TO 18 CUSTOMERS WITH APPROXIMATELY $17,000 POTENTIAL RESTITUTION. THIS WILL BE VERIFIED BY THE INDEPENDENT CONSULTANT.

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) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
10/27/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2023079071301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THEENTRY OF FINDINGS THAT IT PERMITTED A
REGISTERED REPRESENTATIVE TO CONTINUE ASSOCIATING WITHTHE FIRM DURING THE PERIOD OF HIS SUSPENSION WHEN HE WAS STATUTORILY
DISQUALIFIED. THEFINDINGS STATED THAT THE FIRM REGISTERED REPRESENTATIVE WAS SUSPENDED BY FINRA FROMASSOCIATING WITH ANY FINRA
MEMBER IN ALL CAPACITIES. THE AWC INSTITUTING THE SUSPENSION NOTEDTHAT THE SUSPENSION WOULD MAKE THE REPRESENTATIVE "SUBJECT TO
A STATUTORY DISQUALIFICATION,"MEANING "HE MAY NOT BE ASSOCIATED WITH ANY FINRA MEMBER IN ANY CAPACITY, INCLUDING CLERICAL
ORMINISTERIAL FUNCTIONS, DURING THE PERIOD OF THE ... SUSPENSION." HOWEVER, DURING THESUSPENSION AND STATUTORY DISQUALIFICATION,
THE FIRM PERMITTED THE REPRESENTATIVE TO CONTINUEASSOCIATING WITH IT BY ENTERING SECURITIES ORDERS THROUGH BOTH THE TRADING
DESK ANDELECTRONIC SYSTEM OF ITS CLEARING FIRM.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
10/27/2025
 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: $ 100,000.00
 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: 
THE FIRM WAS CENSURED AND FINED $100,000.
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).

ALLEGATION THAT FROM APRIL-NOVEMBER 2022 WHILE A REGISTERED REPRESENTATIVE WAS SUSPENDED IFG ALLOWED SUCH MEMBER TO CONTINUE
TO ASSOCIATE WITH THE FIRM. FROM APRIL - SEPTEMBER THE FIRM WAS UNAWARE THAT THE INDIVIDUAL WAS CALLING THE CLEARING FIRM'S
TRADING DESK TO PLACE TRADES (MAINLY FOR ADVISORY CLIENTS). IN AN EFFORT TO RESOLVE THE ISSUE WITHOUT THE NEED FOR COSTLY AND
TIME-CONSUMING PROTRACTED LITIGATION THE FIRM DECIDED TO SETTLE WITH FINRA BY AGREEING TO A CENSURE AND A $100,000 FINE.

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:
Cease and Desist
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
09/08/2026
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-22707
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION FOUND THAT IFG FIT THE DEFINITION OF AN INSTITUTIONAL INVESTMENT MANAGER AS DEFINED IN
SECTION 13F OF THE EXCHANGE ACT AND HAD INVESTMENT DISCRETION PURSUANT TO RULE 13F-1(B) OVER AT LEAST $100 MILLION OF REPORTABLE
SECURITIES AND WAS, THEREFORE, OBLIGATED TO FILE QUARTERLY FORMS 13F BEGINNING BY AT LEAST FEBRUARY 2022. HOWEVER, IFG FAILED TO
FILE FORMS 13F UNTIL MAY 2026.
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):
09/08/2026
 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: $ 500,000.00
 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: 
THE FIRM WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING VIOLATIONS AND FURTHER VIOLATIONS OF EXCHANGE ACT
SECTION 13(F)(1) AND RULE 13F-1 PROMULGATED THEREUNDER; WAS CENSURED; AND ORDERED TO PAY A $500,000 CIVILE MONEY PENALTY TO
THE SEC.
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).
SENIOR MANAGEMENT WAS NOT AWARE THAT THE FORMS WERE NOT BEING FILED. WHEN IFG CONDUCTED ITS INITIAL INVESTIGATION FOLLOWING
RECEIPT OF THE SEC'S FIRST REQUEST FOR INFORMATION IT LEARNED THIS FACT. THERE HAD BEEN AN ONGOING DEBATE AMONG THE CCO AT THAT
TIME AND OTHER COMPLIANCE EMPLOYEES ABOUT WHETHER OR NOT THE FORM NEEDED TO BE FILED. IN DISCUSSIONS BY THE HEAD OF LEGAL WITH
IFG'S BACK-OFFICE SYSTEM PROVIDER, IT WAS DISCOVERED THAT THE BACK OFFICE SYSTEM HAD A REPORT THAT COULD BE USED TO GATHER THE
DATA FOR THE FILING. IT HAS COME TO LIGHT THAT THE CCO AT THE TIME (WHO HAD VOICED AN OPINION THAT IFG DID NOT NEED TO FILE) WAS
LATER WORKING TO TEST THE REPORT; HE NEVER COMPLETED THE PROJECT NOR DID HE EVER FILE OR FACILITATE THE FILING OF ANY FORM 13F
REPORTS. RULE 13F IS DESIGNED TO PROMOTE TRANSPARENCY FOR INSTITUTIONAL INVESTING. THE FRAMEWORK ENSURES THAT LARGE
INSTITUTIONAL INVESTORS DISCLOSE THEIR HOLDINGS, HELPING MAINTAIN MARKET INTEGRITY AND PROVIDING VALUABLE INFORMATION TO THE
MARKET AND OTHER MARKET PARTICIPANTS. THE FIRM DISAGREED WITH THE SEC'S STANCE AND ITS FINDINGS AND INDICATED A CONCERN THAT
FILING WOULD NOT BE PROVIDING CORRECT/ACCURATE INFORMATION TO THE PUBLIC. HOWEVER, WE AGREED TO SETTLE AS A RESULT OF A "NO
WIN" SITUATION AND TO CAP EXPENSES RELATED TO FIGHTING A HOPELESS OUTCOME, AND FILING BOTH HISTORICAL 13F AND FUTURE REPORTS
WAS NOT A TIME CONSUMING OR BURDENSOME PROCESS. THROUGHOUT THE COURSE OF THE SEC'S INVESTIGATION IFG PROVIDED EVIDENCE,
INCLUDING WRITTEN SUPERVISORY PROCEDURES OUTLINING THAT REPRESENTATIVES CANNOT VOTE PROXIES, THAT IARS ARE INDEPENDENT
CONTRACTORS THAT RUN THEIR OWN BUSINESS AND THAT IFG'S RIA DOES NOT HAVE AN INVESTMENT MANAGEMENT TEAM OR ANY OTHER RESOURCE

OR TEAM THAT PROVIDES GUIDANCE OR MODELS, ALL OF WHICH SUPPORT THAT APPLICATION OF THE DEFINITION OF "INSTITUTIONAL INVESTMENT
MANAGER" AS DEFINED IN SECTION 13(F) OF THE EXCHANGE ACT WAS NOT APPLICABLE. ALSO, THE CONSTRUCT OF THE RULE AND THE REQUIRED
FORM FILING DOES NOT CONTEMPLATE INDEPENDENT BROKER-DEALERS THAT HAVE A DUAL/HYBRID RIA TO ALLOW AFFILIATED REPRESENTATIVES TO
PROVIDE INVESTMENT ADVISORY SERVICES TO THEIR CLIENTS, WHERE THE IARS DO NOT ACT IN CONCERT WHEN EXERCISING DISCRETION OR
MAKING INVESTMENT DECISIONS, AND WHO ARE NOT AUTHORIZED TO VOTE PROXIES.