Focused Wealth Management, Inc.

Allegations: FWM ENTERED INTO CONSENTED TO THE ENTRY OF AN ADMINISTRATIVE AND CEASE-AND-DESIST ORDER INSTITUTED BY THE SEC FINDING THAT FWM VIOLATED SECTION 204 OF THE ADVISERS ACT AND RULE 204-2(A)(7) THEREUNDER BY FAILING TO MAINTAIN AND PRESERVE CERTAIN OFF-CHANNEL COMMUNICATIONS. THE ORDER FURTHER FOUND THAT FWM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE FIRM AND ITS SUPERVISED PERSONS FROM VIOLATING RECORDKEEPING REQUIREMENTS UNDER THE ADVISERS ACT RELATING TO OFF-CHANNEL COMMUNICATIONS, IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THE ORDER STATED THAT THE SEC CONSIDERED THE STEPS PROMPTLY UNDERTAKEN AND COOPERATION AFFORDED THE SEC STAFF BY FWM. BEFORE BEING APPROACHED BY THE STAFF, FWM BEGAN REMEDIATING THE DEFICIENCIES IN ITS COMPLIANCE POLICIES AND PROCEDURES IN 2021, AND CONTINUED ITS REMEDIATION EFFORTS THROUGHOUT THE RELEVANT PERIOD. AS PART OF THIS REMEDIATION, FWM HIRED A COMPLIANCE CONSULTANT AND UPGRADED ITS METHODS FOR ARCHIVING AND REVIEWING TEXT MESSAGES. Status: Final Sanction Detail: FWM PAID FINE OF $325,000 ON 10/1/24. NO PORTION OF THE PENALTY WAS WAIVED. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL, PURSUANT TO THE SEPTEMBER 24, 2024 ORDER DESCRIBED ABOVE. THE CIVIL PENALTY WAS PAID WITHIN 14 DAYS OF THE ENTRY OF THE ORDER. NO PORTION OF THE PENALTY WILL BE BORNE BY FWM'S CLIENTS.