Steward Capital Management, Inc.

Allegations: STEWARD FAILED TO TIMELY DELIVER AUDITED FINANCIALS TO PRIVATE INVESTMENT FUND INVESTORS FROM 2018 THROUGH 2021. STEWARD FAILED TO UPDATE OR REVISE ITS FORM ADV IN A TIMELY MANNER. THESE FAILURES LED TO A VIOLATION OF THE CUSTODY RULE. Status: Final Sanction Detail: TOTAL FINE AMOUNT IS $75,000 WHICH WAS PAID ON [INSERT DATE] Summary: WITH SCM'S CONSENT, THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS ON SEPTEMBER 9, 2022. THE SEC ALLEGED THAT SCM FAILED TO TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES TO INVESTORS IN CERTAIN PRIVATE FUNDS THAT SCM ADVISED. IN ADDITION, SCM DID NOT PROMPTLY UPDATE ITS FORMS ADV AS NEW EVENTS REGARDING THOSE AUDITS OCCURRED. THESE FAILURES RESULTED IN VIOLATIONS OF THE ADVISERS ACT AND THE "CUSTODY RULE," WHICH REQUIRED SCM TO UPDATE CERTAIN INFORMATION ABOUT SCM'S PRIVATE FUND AUDITS IN ITS FORMS ADV. PURSUANT TO THE ORDER, SCM WAS REQUIRED TO (I) NOT CAUSE ANY FURTHER VIOLATIONS OF THE CUSTODY RULE AND (II) PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000. SCM WAS ALSO CENSURED FOR THESE ACTIVITIES.