Jonathan Roberts Advisory Group, Inc.

Allegations: FINRA ALLEGED THAT THE FIRM DID NOT HAVE A REASONABLY DESIGNED SYSTEM WITH RESPECT TO THE RECOMMENDATION OF ALTERNATIVE MUTUAL FUNDS. Status: Final Sanction Detail: THE FINE WAS PAID IN FULL ON APRIL 8, 2021. THE FIRM IS IN THE PROCESS OF MAKING THE RESTITUTION PAYMENTS, IN FULL, WITHIN THE TIME FRAME SET FORTH IN THE AWC. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE AWC, THE FIRM CONSENTED TO THE ENTRY OF THOSE FINDINGS AND THE SANCTIONS DESCRIBED ABOVE.

Allegations: JWCA'S MF SHARE CLASS SELECTION RESULTED IN AN UNAFFILIATED B/D, JW COLE FINANCIAL ("JWCF") RECEIVING THREE TYPES OF FEES AS A RESULT OF JWCA'S ADVISORY CLIENTS INVESTMENTS AT TIMES FROM JANUARY 2014 THROUGH MARCH 2021. THE FEES INCLUDED 1) FEES THAT JWCF RECEIVED WHEN JWCA PURCHASED, RECOMMENDED, OR HELD IN CLIENT MF SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES") INSTEAD OF LOWER-COST AVAILABLE SHARE CLASSES FOR THE SAME FUNDS THAT DID NOT CHARGE THESE FEES; 2) FEES JWCF RECEIVED FROM ITS UNAFFILIATED CLEARING BROKER (THE "CLEARING BROKER") AS A RESULT OF JWCA'S ADVISORY CLIENTS' INVESTMENTS IN SHARE CLASSES OF MUTUAL FUNDS FOR WHICH THE CLEARING BROKER PAID REVENUE SHARING INSTEAD OF LOWER-COST AVAILABLE SHARE CLASSES FOR THE SAME FUNDS THAT WERE NOT ELIGIBLE FOR SUCH PAYMENTS; AND (3) FEES JWCF RECEIVED FROM ITS CLEARING BROKER AS A RESULT OF JWCA SWEEPING ITS ADVISORY CLIENTS 'CASH INTO CERTAIN MONEY MARKET MUTUAL FUNDS ("MONEY MARKET FUNDS")INSTEAD OF LOWER-COST SHARE CLASSES FOR THE SAME MONEY MARKET FUNDS THAT WERE AVAILABLE TO CLIENTS THAT DID NOT RESULT IN THE PAYMENT OF FEES TO JWCF. Status: Final Sanction Detail: TOTAL $1,957,053.11. Summary: JWCA WITHOUT ADMITTING OR DENYING THE FINDINGS, AS PART OF THE UNDERTAKING PROCESS, HAS UPDATED ITS ADV PART 2A AND POLICIES & PROCEDURES RELATING TO APPROPRIATE SHARE CLASSES, NTFS AND MONEY MARKET USE. THE UNAFFILIATED B/D HAS DISCONTINUED THE RECEIPT OF REVENUE SHARE ON MONEY MARKET AND NTF TRANSACTIONS RELATED TO JWCA. POTENTIALLY AFFECTED CLIENTS HAVE BEEN NOTIFIED AND A FAIR FUND ESTABLISHED FOR PAYMENT OF DISGORGEMENT AND CIVIL PENALTY.