Pekin Hardy Strauss, Inc.

Allegations: THE COMMISSION FOUND THAT THE FIRM DID NOT CONDUCT TIMELY ANNUAL COMPLIANCE REVIEWS IN 2009 AND 2010 AND IMPLEMENT AND ENFORCE CERTAIN POLICIES AND PROCEDURES. THE FIRM DID NOT CAUSE THE FIRM'S ADVISORY CLIENTS WHO HELD OR PURCHASED APPLESEED FUND INVESTOR CLASS SHARES TO ACQUIRE INSTITUTIONAL CLASS SHARES AFTER THE INSTITUTIONAL SHARE CLASS BECAME AVAILABLE. THE SETTLING PARTIES AGREED TO RELIEF IN THE FORM OF CENSURES AND A CEASE AND DESIST ORDER. THE FIRM PAID A $150,000 PENALTY AND THE NAMED ASSOCIATES EACH PAID A $45,000 PENALTY. THE ORDER ACKNOWLEDGED THE FIRM HAD TAKEN REMEDIAL MEASURES DESIGNED TO ADDRESS THE IDENTIFIED COMPLIANCE SHORTCOMINGS AS WELL AS THE FACTS THAT THE FIRM DETECTED AND SELF-REPORTED THE SHARE CLASS MATTER TO THE COMMISSION AND VOLUNTARILY AND PROACTIVELY REIMBURSED THE FIRM'S ADVISORY CLIENTS AFFECTED BY IT. Status: Final Sanction Detail: PEKIN SINGER STRAUSS PAID A $150,000 PENALTY AND THE NAMED ASSOCIATES EACH PAID A $45,000 PENALTY. ALL FINES WERE PAID BY 6/25/2015. Summary: ALL FINES WERE PAID BY 6/25/2015.