Klein Pavlis & Peasley Financial, Inc.

Allegations: EXECUTION OF AGENCY SECURITIES TRANSACTION WITHIN THE STATE OF GEORGIA PRIOR TO EFFECTIVE DATE OR REGISTRATION Status: Final Summary: CLIENT WAS A FORMER CALIFORNIA RESIDENT WHO SUBSEQUENTLY MOVED TO GEORGIA. I REGISTERED FOR AGENCY STATUS ON MAR 10, 1987, BUT WAS NOT AWARE THAT MY REGISTRATION WAS NOT EFFECTIVE WHILE EXECUTING TRADES FOR THIS CLIENT UNTIL NOTIFIED THAT I WAS IN VIOLATION OF STATUTES.

Allegations: VIOLATIONS OF SECTIONS 5(A) AND 5(C) OF THE SECURITIES EXCHANGE ACT PROHIBITING THE OFFFERING OR SELLING OF A SECURITY UNLESS AN APPROPRIATE REGISTRATION STATEMENT IS IN EFFECT OR A VALID EXEMPTION FROM REGISTRATION EXISTS AND SECTION 7(A) OF THE INVESTMENT COMPANY ACT PROHIBITING ANY INVESTMENT COMPANY FROM ENGAGING IN THE BUSINESS OF BUYING AND SELLING SECURITIES UNLESS IT HAS REGISTERED WITH THE COMMISSION OR HAS A VALID EXEMPTION FROM REGISTRATION. Status: Final Summary: THE ACTION IS FINAL, FOR BOTH FIRMS IT RESULTED IN A CENSURE, CEASE AND DESIST ORDER AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $20,000 EACH

Allegations: FROM IN OR ABOUT OCTOBER 2018 THROUGH APRIL 2019, KPPF TRANSACTED BUSINESS IN PENNSYLVANIA AS AN INVESTMENT ADVISER WHILE NEITHER REGISTERED NOR EXEMPT FROM REGISTRATION. BY ENGAGING IN THE ACTS AND CONDUCT SET FORTH, KPPF TRANSACTED BUSINESS AS AN INVESTMENT ADVISER IN VIOLATION OF SECTION 301(C) OF THE 1972 ACT, 70P.S.1-301(C). Status: Final Sanction Detail: FINED $20,000 Summary: KPPF TO PAY PA $20,000 WITHIN 30 DAYS OF 5/6/19. KPPF ORDERED TO COMPLY WITH 1972 ACT. IF KPPF FAILS TO PAY, THE ORDER SHALL REMAIN IN FULL FORCE AND EFFECT UNTIL PAID. SHOULD KPPF FAIL TO COMPLY WITH THIS ORDER, ADDITIONAL SANCTIONS AND COSTS MAY BE IMPOSED AND PA MAY SEEK OTHER APPROPRIATE RELIEF SUBJECT TO KPPF'S RIGHT TO A HEARING PURSUANT TO THE 1972 ACT. FROM KPPF: IT WAS FOR BEING OVER TWO OF THE THE ALLOWED NUMBER OF CLIENTS ALLOWED IN THE STATE. WHEN KPPF DISCOVERED IT KPPF FILED AND THEY FINED ME FOR IT. KPPF HAD 8 WHEN YOU ARE ALLOWED 6. FOR THAT THEY FINED KPPF $20,000.

Allegations: VIOLATIONS OF SECTIONS 5(A) AND 5 (C) OF THE SECURITIES ACT PROHIBITING THE OFFERING OR SELLING OF A SECURITY UNLESS AN APPROPRIATE REGISTRATION STATEMENT IS IN EFFECT OR A VALID EXEMPTION FROM REGISTRATION EXISTS AND SECTION 7(A) OF THE INVESTMENT COMPANY ACT PROHIBITING ANY INVESTMENT COMPANY FROM ENGAGING IN THE BUSINESS OF BUYING AND SELLING SECURITIES UNLESS IT HAS REGISTERED WITH THE COMMISSION OR HAS A VALID EXEMPTION FROM REGISTRATION. Status: Final Sanction Detail: THE FIRM AND GERALD KLEIN & ASSOCIATES WERE BOTH CENSURED, RECEIVED A CEASE AND DESIST ORDER AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $20,000 EACH. BOTH FINES WERE PAID ON APPROXIMATELY 7/28/2005. IN ADDITION, THE FIRMS MUST HAVE QUARTERLY COMPLIANCE REVIEWS OF ADVISORY OPERATIONS FOR A PERIOD OF THREE YEARS BEGINNING JULY 1, 2005 AND A REPORT OF THE REVIEW FINDING MUST BE SENT TO THE SEC'S PACIFIC REGIONAL OFFICE NO LATER THAN 30 DAYS AFTER COMPLETION. Summary: THE ACTION IS FINAL, FOR BOTH FIRMS IT RESULTED IN A CENSURE, CEASE AND DESIST ORDER AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $20,000 EACH.