Peak Investment Advisors, Inc.

Allegations: FIRM FAILED TO TIMELY FILE THE FIRM'S ANNUAL UPDATING AMENDMENT AND DID NOT FILE AN UPDATED FORM ADV PART 2 BROCHURE. FIRM FAILED TO PROVIDE CLIENTS WITH THE FORM ADV PART 2 BROCHURE. FIRM DID NOT MAINTAIN REQUIRED WRITTEN SUPERVISORY PROCEDURES AND OPERATED A POOLED INVESTMENT VEHICLE WITHOUT A SECURITIES REGISTRATION OR EXEMPTION FILING, NOR INDEPENDENT "GATEKEEPER". Status: Final Sanction Detail: FIRM IS TO COMPLY WITH ALL REQUIREMENTS OUTLINED IN THE DEFICIENCY LETTER, INCLUDING RETENTION OF A COMPLIANCE CONSULTANT FOR A PERIOD OF TWO YEARS. Summary: FIRM IS TO RESOLVE ALL ISSUES AS OUTLINED IN A DEFICIENCY LETTER ISSUED NOVEMBER 12, 2019. FIRM IS TO RETAIN A COMPLIANCE CONSULTANT FOR A PERIOD OF TWO YEARS TO ENSURE COMPLIANCE. FIRM IS TO TIMELY FILE AND UPDATE DISCLOSURE DOCUMENTS. FIRM IS TO REVIEW AND DEVELOP ALL REQUIRED POLICIES AND PROCEDURES TO INSURE COMPLIANCE WITH THE COLORADO SECURITIES ACT AND RULES THEREUNDER. IN 2022, THE COLORADO DIVISION OF SECURITIES CONDUCTED A FOLLOW-UP EXAMINATION OF PEAK AND STATED THAT PEAK HAD FULLY COMPLIED WITH THE CONSENT ORDER. THE CONSENT ORDER EXPIRED EFFECTIVE NOVEMBER 2021.