Select Money Management, Inc.

Allegations: THE SEC'S ORDER DATED MARCH 11, 2019 FOUND THAT OUR FIRM VIOLATED SECTION 206(2) AND SECTION 207 OF THE INVESTMENT ADVISERS ACT OF 1940 BY: (1) FAILING TO INCLUDE ADEQUATE DISCLOSURE REGARDING THE RECEIPT OF 12B-1 FEES; AND/OR (2) FAILING TO ADEQUATELY DISCLOSE ADDITIONAL COMPENSATION RECEIVED FOR INVESTING CLIENTS IN A FUND'S 12B-1 FEE PAYING SHARE CLASS WHEN A LOWER-COST SHARE CLASS WAS AVAILABLE FOR THE SAME FUND. Status: Final Sanction Detail: PAYMENT OF DISGORGEMENT OF $59,162.15 AND INTEREST OF $2,396.25 HAS BEEN COMPLETED. Summary: IN FEBRUARY 2018, THE SECURITIES AND EXCHANGE COMMISSION LAUNCHED AN INITIATIVE TO ADDRESS ITS CONCERNS THAT INVESTMENT ADVISERS WERE NOT ADEQUATELY DISCLOSING, OR ACTING CONSISTENTLY WITH THE DISCLOSURE REGARDING, CONFLICTS OF INTEREST RELATED TO THEIR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. THE INITIATIVE ENABLED INVESTMENT ADVISORY FIRMS TO VOLUNTARILY PARTICIPATE IN THE INITIATIVE AND TO REVIEW THEIR PRACTICES FOR THE PERIOD OF 1/1/2014 THROUGH 6/30/2018, SELF-REPORT THEIR FINDINGS TO THE SEC AND OFFER TO REFUND CERTAIN MUTUAL FUND 12B-1 FEES TO AFFECTED CLIENTS. ON MARCH 11, 2019 SELECT MONEY MANAGEMENT, INC. ENTERED INTO A VOLUNTARY SETTLEMENT AGREEMENT WITH THE SEC WITH RESPECT TO THE INITIATIVE. AS PROVIDED UNDER THE INITIATIVE, THE SEC DID NOT IMPOSE PENALTIES AGAINST THE SETTLING INVESTMENT ADVISERS OR US. EACH OF THE SETTLING INVESTMENT ADVISERS, INCLUDING OUR FIRM, CONSENTED TO CEASE-AND-DESIST ORDERS FINDING VIOLATIONS OF SECTION 206(2) AND, WITH RESPECT TO SEC-REGISTERED INVESTMENT ADVISERS, SECTION 207 AND A CENSURE. THE FIRMS, INCLUDING OUR FIRM, ALSO AGREED TO REFUND THE INADEQUATELY DISCLOSED FEES, WITH INTEREST, TO AFFECTED ADVISORY CLIENTS. EACH ADVISER, INCLUDING OUR FIRM, HAS ALSO UNDERTAKEN TO REVIEW AND EXPAND THE DISCLOSURES CONCERNING MUTUAL FUND SHARE CLASS SELECTION AND 12B-1 FEES, AND TO EVALUATE WHETHER EXISTING CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER-COST SHARE CLASS AND MOVE CLIENTS, AS NECESSARY. SELECT MONEY MANAGEMENT, INC. HAS COMPLETED THIS REVIEW AND ANALYSIS AND IMPLEMENTED ALL NECESSARY CHANGES.