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Wefunder Portal LLC – ‘CFPORTAL/A’ on 6/30/23

On:  Friday, 6/30/23, at 2:54pm ET   ·   Effective:  6/30/23   ·   Accession #:  1670254-23-689   ·   File #:  7-00033

Previous ‘CFPORTAL’:  ‘CFPORTAL/A’ on 3/10/23   ·   Latest ‘CFPORTAL’:  This Filing

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  As Of               Filer                 Filing    For·On·As Docs:Size

 6/30/23  Wefunder Portal LLC               CFPORTAL/A  6/30/23    1:13K

Amendment to Application for Registration by a Crowdfunding Portal   —   Form Funding Portal   —   SEA’34

Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: CFPORTAL/A  Amendment to Application for Registration by a      HTML     13K 
                Crowdfunding Portal -- primary_doc.xml


        

This ‘CFPORTAL/A’ Document is an XML Data File that may be rendered in various formats:

  Form Funding Portal    –   Plain Text   –  SEC Website  –  EDGAR System  –    XML Data    –  <?xml?> File
 
 
SEC Info℠ rendering:  Amendment to Application for Registration by a Crowdfunding Portal
 

CFPORTAL/A: Filer Information

CFPORTAL/A: Identifying Information

Schedule A must be completed as part of all initial applications. Amendments to Schedule A must be provided on Schedule B. Schedule C must be completed by nonresident funding portals. If this is a withdrawal of a funding portal's registration, complete Schedule D.

If this is an amendment to any part of the funding portal's most recent Form Funding Portal, provide an explanation describing the amendment:
Updating Item 7 to reflect current arrangements.

Exact name, principal business address, mailing address, if different, and contact information of the funding portal.

A. Full name of the funding portal:
Wefunder Portal LLC
B. Name(s) under which business is conducted, if different from Item 1A:
Wefunder
Website URL(s) under which business is conducted, if different from Item 1A:
Wefunder.com
C. IRS Empl. Ident. No:
81-1942299
D. If a name and/or website URL in (1A) or (1B) has changed since the funding portal's most recent Form Funding Portal, enter the previous name and/or website URL and specify whether the name change is of the: Checkbox not checked funding portal name (1A)  Checkbox not checked business name/website (1B)
E. Funding portal's main street address (Do not use a P.O. Box):
Address 1:
1885 MISSION STREET
Address 2:
City:
SAN FRANCISCO
State/Country:
CALIFORNIA
Mailing Zip/ Postal Code:
94103
F. Mailing Address(es) (if different) and office locations (if more than one):
Mailing Address
Check here if mailing address is the same as the main address entered in Item 1.E.
Checkbox not checked
Address 1:
4104 24th Street
Address 2:
PMB 8113
City:
San Francisco
State/Country:
CALIFORNIA
Zip/Postal Code:
94114
Other Office Locations
Address 1:
Address 2:
City:
State/Country:
Zip/Postal Code:
G. Contact Information:
Telephone Number:
6282664770
Fax Number:
E-mail Address:
chris@wefunder.com
H. Contact employee information:
Prefix
First Name:
Christopher
Middle Name:
Andrew
Last Name:
Vail
Suffix:
Title:
Deputy General Counsel
Direct Telephone Number:
Fax Number:
Direct E-Mail Address:
I. Month applicant's fiscal year ends:
December
J. Registrations
Was the applicant previously registered on Form Funding Portal as a funding portal or with the Commission in any other capacity?
Radio button not checked  Yes  Radio button checked  No
K. Foreign registrations
(1) Is the applicant registrant with a foreign financial regulatory authority? Answer "no" even if affiliatted with a business that is registered with a foreign financial regulatory authority
.		Radio button not checked  Yes  Radio button checked  No
If "yes", complete Section K.2 below.
(2) List the name, in English, of each foreign financial regulatory authority and country with which the applicant is registered. A separate entry must be completed for each foreign financial regulatory authority with which the applicant is registered.

CFPORTAL/A: Form of Organization

CFPORTAL/A: Successions

A. Is the applicant at the time of this filing succeeding to the business of a currently registered funding portal? Do not report previous successions already reported on Form Funding Portal. If "yes," complete Section 3.B. below. Radio button not checked  Yes  Radio button checked  No

CFPORTAL/A: Control Relationships

In this Item, identify every person that, directly or indirectly, controls the applicant, controls management or policies of the applicant, or that the applicant directly or indirectly controls.
Greg Belote


Suzanna Rush


Nicholas Tommarello


Christopher Vail


If this is an initial application, the applicant also must complete Schedule A. Schedule A asks for information about direct owners and executive officers. If this is an amendment updating information reported on the Schedule A filed with the applicant's initial application, the applicant must complete Schedule B.

CFPORTAL/A: Disclosure Information

In this Item, provide information about the applicant's disciplinary history and the disciplinary history of all associated persons or control affiliates of the applicant (as applicable). This information is used to decide whether to revoke registration, to place limitations on the applicant's activities as a funding portal, and to identify potential problem areas on which to focus during examinations. One event may result in the requirement to answer "yes" to more than one of the questions below. Check all answers that apply. Refer to the Explanation of Terms section of Form Funding Portal Instructions for explanation of italicized terms.

If the answer is "yes" to any question in this Item, the applicant must complete the appropriate Disclosure Reporting Page ("DRP") (FP) - Criminal, Regulatory Action, Civil Judicial Action, Bankruptcy/SIPC, Bond, or Judgment/Lien, as applicable.

Criminal Disclosure

If the answer is "yes" to any question below, complete a Criminal DRP.

Regulatory Action Disclosure

If the answer is "yes" to any question below, complete a Regulatory Action DRP.

C. Has the SEC or the Commodities Futures Trading Commission ("CFTC") ever:
(1) found the applicant or any associated person to have made a false statement or omission?
Radio button not checked Yes   Radio button checked No
(2) found the applicant or any associated person to have been involved in a violation of any SEC or CFTC regulations or statutes?
Radio button not checked Yes   Radio button checked No
(3) found the applicant or any associated person to have been a cause of the denial, suspension, revocation, or restriction of the authorization of an investment-related business to operate?
Radio button not checked Yes   Radio button checked No
(4) entered an order against the applicant or any associated person in connection with investment-related activity?
Radio button not checked Yes   Radio button checked No
(5) imposed a civil money penalty on the applicant or any associated person, or ordered the applicant or any associated person to cease and desist from any activity?
Radio button not checked Yes   Radio button checked No
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found the applicant or any associated person to have made a false statement or omission, or been dishonest, unfair, or unethical?
Radio button not checked Yes   Radio button checked No
(2) ever found the applicant or any associated person to have been involved in a violation of investment-related regulations or statutes?
Radio button not checked Yes   Radio button checked No
(3) ever found the applicant or any associated person to have been the cause of a denial, suspension, revocation, or restriction of the authorization of an investment-related business to operate?
Radio button not checked Yes   Radio button checked No
(4) in the past ten years entered an order against the applicant or any associated person in connection with an investment-related activity?
Radio button not checked Yes   Radio button checked No
(5) ever denied, suspended, or revoked the registration or license of the applicant or that of any associated person, or otherwise prevented the applicant or any associated person of the applicant, by order, from associating with an investment-related business or restricted the activities of the applicant or any associated person?
Radio button not checked Yes   Radio button checked No
E. Has any self-regulatory organization or commodities exchange ever:
(1) found the applicant or any associated person to have made a false statement or omission?
Radio button not checked Yes   Radio button checked No
(2) found the applicant or any associated person to have been involved in a violation of its rules (other than a violation designated as a minor rule violation under a plan approved by the SEC?
Radio button checked Yes   Radio button not checked No
(3) found the applicant or any associated person to have been the cause of a denial, suspension, revocation or restriction of the authorization of an investment-related business to operate?
Radio button not checked Yes   Radio button checked No
(4) disciplined the applicant or any associated person by expelling or suspending the applicant or the associated person from membership, barring or suspending the applicant or the associated person from association with other members, or by otherwise restricting the activities of the applicant or the associated person?
Radio button not checked Yes   Radio button checked No
F. Has the applicant or any associated person ever had an authorization to act as an attorney, accountant, or federal contractor revoked or suspended? Radio button not checked Yes   Radio button checked No
G. Is the applicant or any associated person currently the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 5-C, 5-D, or 5-E? Radio button not checked Yes   Radio button checked No

Civil Judicial Disclosure

If the answer is "yes" to a question below, complete a Civil Judicial Action DRP.

H. Has any domestic or foreign court:
(1) in the past ten years, enjoined the applicant or any associated person in connection with any investment-related activity?
Radio button not checked Yes   Radio button checked No
(2) ever found that the applicant or any associated person was involved in a violation of investment-related statutes or regulations?
Radio button not checked Yes   Radio button checked No
(3) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against the applicant or any associated person by a state or foreign financial regulatory authority?
Radio button not checked Yes   Radio button checked No
I. Is the applicant or any associated person now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 5-H(1)-(3)? Radio button not checked Yes   Radio button checked No

Financial Disclosure

If the answer is "yes" to a question below, complete a Bankruptcy/Disclosure, Bond Disclosure or Judgment/Lien DRP, as applicable.

J. In the past ten years, has the applicant or a control affiliate of the applicant ever been a securities firm or a control affiliate of a securities firm that:
(1) has been the subject of a bankruptcy petition?
Radio button not checked Yes   Radio button checked No
(2) has had a trustee appointed or a direct payment procedure initiated under the Securities Investor Protection Act?
Radio button not checked Yes   Radio button checked No
K. Has a bonding company ever denied, paid out on, or revoked a bond for the applicant? Radio button not checked Yes   Radio button checked No
L. Does the applicant have any unsatisfied judgments or liens against it? Radio button not checked Yes   Radio button checked No

CFPORTAL/A: Non-Securities Related Business

Does the applicant engage in any non-securities related business? Radio button not checked Yes  Radio button checked No 

CFPORTAL/A: Qualified Third Party Arrangements; Compensation Arrangements

A. Qualified Third Party Arrangements. Complete the following information for each person that will hold investor funds in escrow or otherwise pursuant to the requirements of Rule 303(e) of Regulation Crowdfunding (17 CFR 227.303(e)).
Name of person:
First Citizens Bank
Address 1:
3003 Tasman Dr.
Address 2:
City:
Santa Clara
State/Country:
CALIFORNIA
Mailing Zip/ Postal Code:
95054
Phone Number:
4086547400
Name of person:
Thread Bank
Address 1:
210 East Main Street
Address 2:
City:
Rogersville
State/Country:
TENNESSEE
Mailing Zip/ Postal Code:
37857
Phone Number:
4232722200
B. Compensation. Please describe any compensation arrangements the funding portal has with issuers.
Wefunder Portal will charge transaction based fees calculated as a percentage of the entire fundraising round of offerings completed on Wefunder Portal when charged to issuers or calculated as a percentage of an investors commitment if charged to investors. Wefunder Portal will decide prior to each offering what percentage of this transaction based fee will be paid by investors and what percentage will be paid by the issuer. Wefunder Portal may decide to cap investor fees at a certain dollar amount. Wefunder Portal may waive fees for certain issuers or investors. Wefunder Portal may also take an equity position in an issuer in return for reducing the issuers cash transaction fee. Wefunder Portal may also charge the following fees: - Documentation fee for custom documentation charged to issuers - Form C filing fee charged to issuers Associated persons APs of Wefunder Portal may receive salaries and or bonuses. They will not receive transaction based compensation. Compensation to Wefunder Portal and to APs will be clearly disclosed to investors and issuers.

EXECUTION

The funding portal consents that service of any civil action brought by or notice of any proceeding before the Securities and Exchange Commission or any self-regulatory organization in connection with the funding portal's investment-related business may be given by registered or certified mail to the funding portal's contact person at the main address, or mailing address, if different, given in Items 1.E, 1.F. and 1.H.. If the applicant is a nonresident funding portal, it must complete Schedule C to designate a U.S. agent for service of process.

The undersigned represents and warrants that he/she has executed this form on behalf of, and is duly authorized to bind, the funding portal. The undersigned and the funding portal represent that the information and statements contained herein and other information filed herewith, all of which are made a part hereof, are current, true and complete. The undersigned and the funding portal further represent that, if this is an amendment, to the extent that any information previously submitted is not amended, such information is currently accurate and complete.

Date:
6/30/23
Full Legal Name of Funding Portal:
Wefunder Portal LLC
By: (Signature)
Suzanna Rush
Title:
President

FORM FUNDING PORTAL SCHEDULE A

Direct Owners and Executive Officers

  • 1. Complete Schedule A only if submitting an initial application. Schedule A asks for information about the applicant's direct owners and executive officers. Use Schedule B to amend this information.

    Guidance: To determine direct ownership and executive officer status, see instruction 2 below.

  • 2. Direct Owners and Executive Officers. List below the names of:
    (a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer, director and any other individuals with similar status or functions;

    (b) if applicant is organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of the applicant's voting securities, unless applicant is a public reporting company (a company subject to Section 13 or 15(d) of the Exchange Act);

    Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of 5% or more of a class of the applicant's voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.


    (c) if the applicant is organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have contributed, 5% or more of the applicant's capital.

    (d) in the case of a trust, (i) a person that directly owns 5% or more of a class of the applicant's voting securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of the applicant's capital, (ii) the trust and (iii) each trustee; and

    (e) if the applicant is organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of the applicant's capital, and (ii) if managed by elected managers, all elected managers.

  • 3. In the DE/FE/NP column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "NP" if the owner or executive officer is a natural person.

  • 4. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member; and for shareholders or members, the class of securities owned (if more than one is issued).

  • 5. Ownership codes are:
    • NA – less than 5%
    • A – 5% but less than 10%
    • B – 10% but less than 25%
    • C – 25% but less than 50%
    • D – 50% but less than 75%
    • E – 75% or more
    • G – Other (general partner, trustee, or elected member)

  • 6. Control Person:
    (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form Funding Portal, and enter "No" if the person does not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are "control persons".
    (b) In the PR column, enter "PR" if the owner is a public reporting company under Section 13 or 15(d) of the Exchange Act.

Complete each of the following:

FORM FUNDING PORTAL SCHEDULE B

Amendments to Schedule A

  • 1. Use Schedule B only to amend information requested on Schedule A. Refer to Schedule A for specific instructions for completing this Schedule B. Complete each column. File with a completed Execution Page.

  • 2. In the Type of Amendment column, indicate "A" (addition), "D" (deletion), or "C" (change in information about the same person).

  • 3. Ownership codes are:
    • NA – less than 5%
    • A – 5% but less than 10%
    • B – 10% but less than 25%
    • C – 25% but less than 50%
    • D – 50% but less than 75%
    • E – 75% or more
    • G – Other (general partner, trustee, or elected member)

  • 4. List below all changes to Schedule A (Direct Owners and Executive Officers):

FORM FUNDING PORTAL SCHEDULE C

Nonresident Funding Portals

Service of Process and Certification Regarding Prompt Access to Books and Records and Ability to Submit to Inspections and Examinations

Each nonresident funding portal applicant shall use Schedule C of Form Funding Portal to: identify its United States agent for service of process, and certify that it can, as a matter of law and will: (1) provide the Commission and any registered national securities association of which it becomes a member with prompt access to its books and records, and (2) submit to onsite inspection and examination by the Commission and any registered national securities association of which it becomes a member.

A. Agent for Service of Process:

1. Name of United States person applicant designates and appoints as agent for service of process:
2. Address of United States person applicant designates and appoints as agent for service of process
Address 1:
Address 2:
City:
State/Country:
Mailing Zip/ Postal Code:
  • The above identified agent for service of process may be served any process, pleadings, subpoenas, or other papers in:

    (a) any investigation or administrative proceeding conducted by the Commission that relates to the applicant or about which the applicant may have information; and

    (b) any civil or criminal suit or action or proceeding under the federal securities laws brought against the applicant or to which the applicant has been joined as defendant or respondent, in any appropriate court in any place subject to the jurisdiction of any state or of the United States or of any of its territories or possessions or of the District of Columbia. The applicant has stipulated and agreed that any such suit, action or administrative proceeding may be commenced by the service of process upon, and that service of an administrative subpoena shall be effected by service upon, the above-named agent for service of process, and that service as aforesaid shall be taken and held in all courts and administrative tribunals to be valid and binding as if personal service thereof had been made.

B. Certification regarding access to records and ability to submit to inspections and examinations:

  • Applicant can, as a matter of law, and will:

    1. provide the Commission and any registered national securities association of which it becomes a member with prompt access to its books and records, and
    2. submit to onsite inspection and examination by the Commission and any registered national securities association of which it becomes a member.

  • Applicant must attach as an exhibit to this Form Funding Portal, Exhibit C, a copy of the opinion of counsel it is required to obtain in accordance with Rule 400(f) of Regulation Crowdfunding, i.e., the opinion of counsel that the nonresident funding portal can, as a matter of law, provide the Commission and any registered national securities association of which the nonresident funding portal becomes a member with prompt access to the books and records of such nonresident funding portal, and that the nonresident funding portal can, as a matter of law, submit to onsite inspection and examination by the Commission and any registered national securities association of which the nonresident funding portal becomes a member.

  • EXECUTION FOR NON-RESIDENT FUNDING PORTALS

  • The undersigned represents and warrants that he/she has executed this form on behalf of, and is duly authorized to bind, the nonresident funding portal. The undersigned and the nonresident funding portal represent that the information and statements contained herein and other information filed herewith, all of which are made a part hereof, are current, true and complete. The undersigned and the nonresident funding portal further represent that, if this is an amendment, to the extent that any information previously submitted is not amended, such information is currently accurate and complete.

  • The undersigned certifies that the nonresident funding portal can, as a matter of law, and will provide the Commission and any registered national securities association of which it becomes a member with prompt access to the books and records of such nonresident funding portal and can, as a matter of law, and will submit to onsite inspection and examination by the Commission and any national securities association of which it becomes a member. Finally, the undersigned authorizes any person having custody or possession of these books and records to make them available to federal regulatory representatives.
Signature:
Printed Name:
Title:
Date:

REGULATORY ACTION DISCLOSURE REPORTING PAGE (FP)

GENERAL INSTRUCTIONS

You must provide a valid response to each question on every section of this DRP before any of your information can be saved. Invalid or incomplete responses will prevent you from closing the DRP with your information saved. It is recommended that you consult the Print Form of this DRP to make sure you have gathered all the required information before beginning your entry of information online.

This Disclosure Reporting Page (DRP FP) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 5-C, 5-E, 5-F, or 5-G of Form Funding Portal. Radio button checked INITIAL  Radio button not checked AMENDED
Check item(s) being responded to:
Checkbox not checked 5-C(1) Checkbox not checked 5-C(2) Checkbox not checked 5-C(3) Checkbox not checked 5-C(4) Checkbox not checked 5-C(5) Checkbox not checked 5-D(1) Checkbox not checked 5-D(2) Checkbox not checked 5-D(3) Checkbox not checked 5-D(4) Checkbox not checked 5-D(5)
Checkbox not checked 5-E(1) Checkbox checked 5-E(2) Checkbox not checked 5-E(3) Checkbox not checked 5-E(4) Checkbox not checked 5-F Checkbox not checked 5-G     

Use a separate DRP for each event or proceeding. An 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 5-C, 5-D, 5-E, 5- F or 5-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 1

The person(s) or entity(ies) for whom this DRP is being filed is (are) the:
Select only one:Radio button checked Applicant (the funding portal)
Radio button not checked Applicant and one or more of the applicant's associated person(s)
Radio button not checked One or more of applicant's associated person(s)

Applicant

If this DRP is being filed for the applicant, and it is an amendment that seeks to remove a DRP concerning the applicant from the record, the reason the DRP should be removed is: Radio button not checked The applicant is registered or applying for registration and the event or proceeding was resolved in the applicant's favor.
Radio button not checked The DRP was filed in error.

Part 2

1. Regulatory Action was initiated by :Radio button not checked SEC
Radio button not checked Foreign Authority
Radio button not checked Other Federal Authority
Radio button not checked State
Radio button checked SRO
(Full name of regulator, foreign financial regulatory authority, federal authority, state or SRO)
FINRA
2. Principal Sanction (check appropriate item):Radio button checked Civil and Administrative Penalty(ies)/Fine(s)
Radio button not checked Restitution
Radio button not checked Bar
Radio button not checked Cease and Desist
Radio button not checked Censure
Radio button not checked Denial
Radio button not checked Expulsion
Radio button not checked Revocation
Radio button not checked Injunction
Radio button not checked Prohibition
Radio button not checked Reprimand
Radio button not checked Disgorgement
Radio button not checked Suspension
Radio button not checked Undertaking
Radio button not checked Other
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
1/1/21
Specify if Date Initiated is Exact or needs an Explanation
Radio button not checked Exact   Radio button checked Explanation
If not exact, provide explanation:
FINRA initiated the action via a variety of requests received over the course of 2021 and 2022.
4. Docket/Case Number:
2021071940801
6.Principal Product Type (check appropriate item): Radio button not checked Annuity(ies) - Fixed
Radio button not checked Annuity(ies) - Variable
Radio button not checked Money Market Fund(s)
Radio button not checked CD(s)
Radio button not checked Commodity Option(s)
Radio button not checked Debt - Asset Backed
Radio button not checked Debt - Corporate
Radio button not checked Debt - Government
Radio button not checked Debt - Municipal
Radio button not checked Derivative(s)
Radio button not checked Direct Investment(s) - DPP & LP Interest(s)
Radio button not checked Equity - OTC
Radio button not checked Equity Listed (Common & Preferred Stock)
Radio button not checked Futures - Commodity
Radio button not checked Futures - Financial
Radio button not checked Index Option(s)
Radio button not checked Insurance
Radio button not checked Investment Contract(s)
Radio button not checked Mutual Fund(s)
Radio button not checked Options
Radio button not checked Penny Stock(s)
Radio button not checked Unit Investment Trust(s)
Radio button checked Other
Radio button not checked No Product
If Other is selected, please specify:
Equity and debt securities in unlisted companies (crowdfunding)
Other Product Types:
Equity and debt securities in unlisted companies (crowdfunding)
7. Describe the allegations related to this regulatory action. (The response must fit within the space provided.)
FINRA alleged various violations of crowdfunding and FINRA rules related to concurrent securities offerings, reconciliation of investor funds, marketing materials, and supervisory systems.
8. Current status of the event?Radio button not checked Pending   Radio button not checked On Appeal   Radio button checked Final

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved (check appropriate item):Radio button checked Acceptance, Waiver & Consent (AWC)
Radio button not checked Consent
Radio button not checked Decision
Radio button not checked Decision & Order of Offer of Settlement
Radio button not checked Dismissed
Radio button not checked Withdrawn
Radio button not checked Settled
Radio button not checked Stipulation & Consent
Radio button not checked Vacated
Radio button not checked Order
Radio button not checked Other
11. Resolution Date (MM/DD/YYYY):
4/14/22
Specify if Resolution Date is Exact or needs an Explanation
Radio button checked Exact   Radio button not checked Explanation
12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check appropriate item):


Checkbox checked Monetary/Fine
Checkbox not checked Bar
Checkbox not checked Revocation/Expulsion/Denial
Checkbox not checked Disgorgement
Checkbox not checked Cease and Desist/ Injunction
Checkbox not checked Censure
Checkbox not checked Suspension
Amount:
$1,500,000.00
B. Other Sanctions Ordered:
C. 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 the applicant or an associated person, 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:
The action is fully resolved as of December 2022.

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