Coordinated Capital Securities, Inc.

Allegations: THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12-B1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES. Status: Final Sanction Detail: THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961 Summary: AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTERST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS. THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, THE FIRM HAS TAKEN THE FOLLOWING ACTIONS: UPDATED FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER-COST SHARE CLASS; IDENTIFIED CLIENTS ELIGIBLE FOR REIMBURSEMENT OF THE 12B-1 FEES PAID DURING THE RELEVANT PERIOD.

Allegations: THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES. Status: Final Sanction Detail: THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961 Summary: AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS. THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, CCS HAS TAKEN THE FOLLOWING ACTIONS: UPDATED FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER COST CHARE CLASS; IDENTIFIED CLIENTS ELIGIBLE FOR REIMBURSEMENT OF THE 12-B1 FEES PAID DURING THE RELEVANT PERIOD.