Aventura Capital Management, Llc

Allegations: AT VARIOUS TIMES FROM DECEMBER 2015 TO JUNE 2022, AVENTURA SECURITIES RECEIVED COMPENSATION INCLUDING: (1) FEES AVENTURA SECURITIES RECEIVED WHEN AVENTURA CAPITAL PURCHASED, RECOMMENDED, OR HELD FOR AVENTURA CAPITAL'S ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES") INSTEAD OF AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT DID NOT CHARGE THESE FEES; (2) FEES AVENTURA SECURITIES RECEIVED FROM ITS CLEARING BROKER AS A RESULT OF AVENTURA CAPITAL'S ADVISORY CLIENTS' UNINVESTED CASH BEING SWEPT INTO SHARE CLASSES OF CERTAIN MONEY MARKET MUTUAL FUNDS ("MONEY MARKET FUNDS") INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME MONEY MARKET FUNDS THAT DID NOT RESULT IN THE PAYMENT OF FEES TO AVENTURA SECURITIES THAT WERE AVAILABLE TO CLIENTS; AND (3) MARK-UPS AND MARK-DOWNS THAT AVENTURA SECURITIES RECEIVED WHEN AVENTURA CAPITAL DIRECTED CERTAIN TRADES ON BEHALF OF CLIENTS WITHOUT DISCLOSING THE CAPACITY IN WHICH AVENTURA CAPITAL WAS ACTING, WITHOUT PROVIDING PRIOR WRITTEN DISCLOSURE TO, AND OBTAINING CONSENT FROM CLIENTS, IN ADVANCE OF EACH TRANSACTION, AND WITHOUT DISCLOSING THE COMPENSATION THAT AVENTURA SECURITIES RECEIVED FROM SUCH TRADING. Status: Final Sanction Detail: $938756.59 Summary: ORDER ACCEPTED BY THE FIRM. FAIR FUND ACCOUNT BEING FUNDED PURSUANT TO THE ADMINISTRATIVE ORDER.