Equitas Capital Advisors,Llc

Allegations: THE SEC ALLEGED THAT EQUITAS CAPITAL, LLC OVERBILLED CERTAIN CLIENTS, MADE FALSE/MISLEADING DISCLOSURES TO CLIENTS REGARDING HISTORICAL PERFORMANCE, COMPENSATION, CONFLICTS OF INTEREST, AND PRIOR EXAM DEFICIENCIES, FAILED TO CONDUCT ADEQUATE ANNUAL COMPLIANCE REVIEWS AND TO MAINTAIN ADEQUATE POLICIES AND PROCEDURES AND THAT EQUITAS PARTNERS, LLC FAILED TO CONDUCT ADEQUATE ANNUAL COMPLIANCE REVIEWS. Status: Final Sanction Detail: EQUITAS CAPITAL WAS ORDERED TO AND AGREED TO PAY A CIVIL PENALTY OF $100,000. THE PENALTY WAS PAID ON OCTOBER 31, 2013. Summary: ON OCTOBER 23, 2013, THE SEC ENTERED AN ORDER INSTITUTING SETTLED CEASE AND DESIST PROCEEDINGS PURSUANT TO SECTIONS 203(E), 203(F) AND 203(K) OF THE INVESTMENT ADVISERS ACT, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND DESIST ORDER. WITHOUT ADMITTING OR DENYING THE FINDINGS, EQUITAS CAPITAL ADVISORS, LLC, ("EQUITAS CAPITAL") AND EQUITAS PARTNERS, LLC, ("EQUITAS PARTNERS') (COLLECTIVELY "RESPONDENTS") CONSENTED TO THE ENTRY OF THE ORDER PRINCIPALLY SUMMARIZED AS FOLLOWS: RESPONDENTS VIOLATED AND WERE ORDERED TO CEASE AND DESIST FROM VIOLATING CERTAIN SECTIONS AND RULES OF THE ADVISERS ACT AS A RESULT OF THE FOLLOWING: EQUITAS CAPITAL INADVERTENTLY OVERBILLED CERTAIN CLIENTS, NEGLIGENTLY MADE FALSE/MISLEADING DISCLOSURES TO CLIENTS REGARDING HISTORICAL PERFORMANCE, COMPENSATION, CONFLICTS OF INTEREST, AND PRIOR EXAM DEFICIENCIES, FAILED TO CONDUCT ADEQUATE ANNUAL COMPLIANCE REVIEWS AND TO MAINTAIN ADEQUATE POLICIES AND PROCEDURES. EQUITAS PARTNERS FAILED TO CONDUCT ADEQUATE ANNUAL COMPLIANCE REVIEWS. RESPONDENTS WERE ORDERED TO AND AGREED TO HIRE AN INDEPENDENT CONSULTANT TO PERFORM THREE ANNUAL REVIEWS OF RESPONDENTS' POLICIES AND PROCEDURES. EQUITAS CAPITAL WAS ORDERED TO AND AGREED TO PAY A CIVIL PENALTY OF $100,000.

Allegations: SCC OF VA ALLEGED THAT A REMOTE WORKER LOGGING IN FROM HOME CONSTITUTED A PLACE OF BUSINESS WITHIN VA, WHICH WOULD RESULT IN A FAILURE TO NOTICE FILE WITH THE STATE AGENCY. Status: Final Sanction Detail: THE PENALTY WAS REDUCED FROM $5000 TO $4000, AND FROM $2500 FOR THE COST OF THE INVESTIGATION TO $1000, PAID ON THE FINAL SETTLEMENT 11/27/23. Summary: EQUITAS DID NOT ADMIT OR DENY THE ALLEGATIONS, BUT SETTLED THE MATTER.