Cibc Private Wealth Advisors, Inc.

Allegations: FREDERIC A. MENDELSOHN V. RICHARD K. SHEINER AND CIBC PRIVATE WEALTH ADVISORS, INC. - PLAINTIFF FILED COMPLAINT IN CIRCUIT COURT OF COOK COUNTY ILLINOIS, ASSERTING FOUR COUNTS AGAINST SHEINER AND PWA. COMPLAINT ALLEGES THAT PLAINTIFF AGREED TO SET UP AN ACCOUNT WITH SHEINER/PWA IN THE NAME OF HIS WIFE ONLY, AND THAT SHEINER/PWA PROMISED (A) NOT TO DEPLETE OR ENCUMBER THE ACCOUNT IN ANY WAY WITHOUT PLAINTIFF'S PRIOR CONSENT, AND (B) TO IMMEDIATELY NOTIFY PLAINTIFF IF THERE WERE ANY RISKS OF DEPLETION OR ENCUMBRANCE OF THE ACCOUNT, EXCEPT FOR NORMAL INVESTMENT OR TRADING LOSSES. CLAIMS INCLUDE (I) BREACH OF FIDUCIARY DUTY, (II) FRAUDULENT INDUCEMENT, (III) BREACH OF CONTRACT, (IV) PROMISSORY ESTOPPEL, AND (V) EQUITABLE ESTOPPEL. CLAIMED DAMAGES OF $584,407.00 PWA HAS ENGAGED OUTSIDE COUNSEL ON BEHALF OF SHEINER AND PWA AND BELIEVES THE CASE IS WITHOUT MERIT. Status: Pending Summary: FREDERIC A. MENDELSOHN V. RICHARD K. SHEINER AND CIBC PRIVATE WEALTH ADVISORS, INC. - PLAINTIFF FILED COMPLAINT IN CIRCUIT COURT OF COOK COUNTY ILLINOIS, ASSERTING FOUR COUNTS AGAINST SHEINER AND PWA. COMPLAINT ALLEGES THAT PLAINTIFF AGREED TO SET UP AN ACCOUNT WITH SHEINER/PWA IN THE NAME OF HIS WIFE ONLY, AND THAT SHEINER/PWA PROMISED (A) NOT TO DEPLETE OR ENCUMBER THE ACCOUNT IN ANY WAY WITHOUT PLAINTIFF'S PRIOR CONSENT, AND (B) TO IMMEDIATELY NOTIFY PLAINTIFF IF THERE WERE ANY RISKS OF DEPLETION OR ENCUMBRANCE OF THE ACCOUNT, EXCEPT FOR NORMAL INVESTMENT OR TRADING LOSSES. CLAIMS INCLUDE (I) BREACH OF FIDUCIARY DUTY, (II) FRAUDULENT INDUCEMENT, (III) BREACH OF CONTRACT, (IV) PROMISSORY ESTOPPEL, AND (V) EQUITABLE ESTOPPEL. CLAIMED DAMAGES OF $584,407.00 PWA HAS ENGAGED OUTSIDE COUNSEL ON BEHALF OF SHEINER AND PWA AND BELIEVES THE CASE IS WITHOUT MERIT.

Allegations: THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST, OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT. Status: Final Summary: THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST, OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT. ON MAY 31, 2023, THE PLAINTIFF VOLUNTARILY DISMISSED VICKEN EKMEKJIAN FROM THIS MATTER. TO AVOID THE TIME, COSTS, AND UNCERTAINTIES OF A LITIGATION, WITHOUT ADMITTING ANY WRONGDOING ON JULY 6, 2023, THE PLAINTIFF AND CIBC PRIVATE WEALTH ADVISORS SETTLED THIS MATTER FOR $250,000. VICKEN EKMEKJIAN WAS NOT ASKED TO PARTICIPATE IN OR CONTRIBUTE TOWARDS THE SETTLEMENT. ON JULY 20, 2023, THE PLAINTIFF DISMISSED THE MATTER.

Allegations: THE CHICAGO BOARD OF OPTIONS, INC. ("CBOE") DETERMINED THAT ON OR ABOUT JUNE 1, 2016, CIBC WORLD MARKETS CORP. ("CIBC") BY AND THROUGH ITS ASSOCIATED PERSON, ACCEPTED A CUSTOMER HELD ORDER TO SELL SPX AND XSP AUGUST PUT OPTIONS AND IN TURN (1) ENGAGED IN ANTICIPATORY HEDGING TRANSACTIONS IN RELATED INSTRUMENTS; (2) FAILED TO MAKE, KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING AND EXECUTION OF CIBC CUSTOMER ORDERS, AS WELL AS CIBC'S RELATED FIRM TRANSACTIONS; (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DEISGNED TO PREVENT AND DETECT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9; AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1 AND 6.9. Status: Final Sanction Detail: FINE OF $100,000 Summary: THE CBOE DETERMINED THAT ON OR ABOUT 6/1/16, CIBC WORLD MARKETS CORP. ("CIBC") (1) THROUGH AN ASSOCIATED PERSON ENGAGED IN AN ANTICIPATORY HEDGING TRANSACTION (2) FAILED TO KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING, AND EXECUTION OF CUSTOMER ORDERS IN SPX AND XSP AS WELL AS FOR CIBC'S RELATED FIRM TRANSACTIONS (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9 AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1, 4.2, 4.24, 6.9 AND 15.1; SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER.

Allegations: ON JULY 1, 2013 CIBC BROKERED AND ENTERED INTO TWO EXCHANGE FOR RELATED POSITIONS (EFRPS) WHICH DID NOT CONTAIN DOCUMENTATION OF THE RELATED OTC TRANSACTION AND THEREFORE, WERE NOT BONA FIDE EFRPS. THE NYMEX BUSINESS CONDUCT COMMITTEE PANEL FOUND THAT AS A RESULT CIBC VIOLATED LEGACY EXCHANGE RULE 538.H (RECORDKEEPING). Status: Final Sanction Detail: AT HEARING ON FEBRUARY 18, 2015 DURING WHICH CIBC NEITHER ADMITTED NOR DENIED A VIOLATION OF CME RULE 538.H, A PANEL OF THE NYMEX BUSINESS CONDUCT COMMITTEE ORDERED CIBC TO PAY A FINE OF $15,000 TO THE CME FOR A VIOLATION OF CME RULE 538.H CIBC PAID THE FINE ON MARCH 5, 2015. Summary: AT HEARING ON FEBRUARY 18, 2015 DURING WHICH CIBC NEITHER ADMITTED NOR DENIED A VIOLATION OF CME RULE 538.H, A PANEL OF THE NYMEX BUSINESS CONDUCT COMMITTEE ORDERED CIBC TO PAY A FINE OF $15,000 TO THE CME FOR A VIOLATION OF CME RULE 538.H CIBC PAID THE FINE ON MARCH 5, 2015.

Allegations: FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ISE RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT: (I) REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING. Status: Final Sanction Detail: $33,333.33 Summary: CIBC WORLD MARKETS CORP (CIBC) WAS SUBJECT TO CENSURE AND A FINE OF $33,333.33.

Allegations: 1. OCC MADE A SETTLEMENT REPORT AVAILABLE TO CIBC REFLECTING CIBC'S NET SETTLEMENT OBLIGATION FOR 10/2/2014 IN THE AMOUNT OF $12,969,113. 2. CIBC DESIGNATED CLEARING BANK PURSUANT TO OCC RULE 203 DID NOT ACCEPT THE SETTLEMENT INSTRUCTIONS UNTIL TWO MINUTES AFTER THE SETTLEMENT WAS DUE AS SET FORTH IN OCC RULES AND 3. THIS ACTION CONSTITUTED A VIOLATION OF ART. 1 SECTION 1,S(14) OF THE OCC BYLAWS AND RULES 502(A) AND 605 THAT CIBC DID NOT TIMELY MEET ITS INITIAL MORNING SETTELMENT OBLIGATION ON 10/2/214. Status: Final Sanction Detail: MONETARY FINE OF $25,000 Summary: CIBC WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE CHARGES, CONSENTED TO THE ENTRY OF A FINAL DECISION PROVIDING FOR THE IMPOSITIONS OF SANCTIONS AGAINST THE FIRM IN THE AMOUNT OF $25,000 WHICH WAS PAID ON JANUARY 28, 2015

Allegations: FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONS SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH AND TO DETECT AND PREVENT VIOLATIONS OF THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE RULE THAT REQUIRE: ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS AND PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING. Status: Final Sanction Detail: FINED $33,333.33 Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, CIBC CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS THAT THE FIRM FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE EXCHANGE FOR EXECUTION.

Allegations: FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PHLX RULE 760. CIBC ALSO VIOLATED PHLX RULE 748 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT: (I)REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PRHOIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING. Status: Final Sanction Detail: FINE OF $33,333.33 Summary: CIBC WAS SUBJECT TO CENSURE AND A MONETARY FINE OF $33,333.33

Allegations: CIBC WORLD MARKETS CORP VIOLATED CBOE RULES 4.2, 5.12, 8.1, 8.2 AND OCC BY LAWS ARTICLE VI SECTION I IN THAT THEY IMPROPERLY USED THE OCC ADJUSTMENT PROCESS. THE FIRM ALSO VIOLATED CBOE RULE 8.16 IN THAT THEY DID NOT ESTABLISH SUFFICIENT SUPERVISORY PROCEDURES REGARDING ITS USE OF THE OCC ADJUSTMENT PROCESS. THE FIRM HAD IN PLACE PROCEDURES REGARDING ITS ACCOMMODATION ACCOUNT, WHICH IT USED AS PART OF THE ADJUSTMENT PROCESS. HOWEVER, THOSE PROCEDURES WERE NOT CONSISTENT WITH INTERPRETATIONS AND POLICIES .01(A) TO OCC BYLAWS ARTICLE VI, SECTION I, SINCE THEY PERMITTED ADJUSTMENTS, AFTER SUPERVISORY REVIEW AND SIGN-OFF, FOR PURPOSES OTHER THAN TO CORRECT BONA FIDE ERRORS IN TRADES THAT WERE PREVIOUSLY SUMMITTED TO THE OCC. Status: Final Sanction Detail: CENSURE AND MONETARY FINE OF $80,000 Summary: THE FIRM WAS CENSURED AND FINED $80,000

Allegations: ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS. Status: Final Sanction Detail: A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. Summary: ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.