St. Germain Investment Management, Inc.

Allegations: ST. GERMAIN FAILED TO FILE A "DESIGNATED PRINCIPAL FORM DPF" WITH THE STATE BY DECEMBER 31, AS REQUIRED BY ILLINOIS STATUTES. Status: Final Sanction Detail: $250 FINE ACCEPTED BY ILLINOIS. JUNE 3, 2010 Summary: $250 FINE ACCEPTED BY ILLINOIS, JUNE 3,2010

Allegations: FINRA RULES 2010,7450,NASD RULES 2110,3010,6955(A)- ST. GERMAIN SECURITIES, INC FAILED TO TRANSMIT ALL OF IT'S ORDERS TO THE ORDER AUDIT TRAIL SYSTEM(OATS) THAT IT WAS REQUIRED TO TRANSMIT DURING A PARTICULAR PERIOD.THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITY LAWS, REGULATIONS AND NASD RULES CONCERNING OATS REPORTING. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $27,500, AND REQUIRED TO REVISE IT'S WRITTEN SUPERVISORY PROCEDURES REGARDING OATS REPORTING WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC. Summary: PURSUANT TO A FINRA AWC, THE ABOVE FINE HAS BEEN PAID. SINCE THE TIME IF THE ACTION, WE HAVE BECOME AN INTRODUCING BROKER WITH OUR CLEARING FIRM RESPONSIBLE FOR OATS REPORTING.

Allegations: IN JULY OF 2021, ST. GERMAIN INVESTMENT MANAGEMENT ENTERED INTO A SETTLEMENT WITH THE SECURITIES EXCHANGE COMMISSION INVOLVING THE FIRM'S SPECIFIED DISCLOSURE OF A CONFLICT OF INTEREST ARISING FROM THE PARTICIPATION OF THE FIRM'S AFFILIATED BROKER DEALER IN A CASH SWEEP REVENUE SHARING AGREEMENT. PER THE TERMS OF THE SETTLEMENT, THE FIRM AGREED TO PAY DISGORGEMENT, PREJUDGMENT INTEREST AND A CIVIL PENALTY TOTALING $1,925,250. THE FIRM HAS DETERMINED TO AVOID ANY FURTHER CONFLICTS OF INTEREST, IT WILL NO LONGER PARTICIPATE IN SUCH ARRANGEMENTS. Status: Final Sanction Detail: ST. GERMAIN PAID A CIVIL PENALTY OF $300,000 AND DISGORGEMENT OF $1,443,411. Summary: IN JULY OF 2021, ST. GERMAIN INVESTMENT MANAGEMENT ENTERED INTO A SETTLEMENT WITH THE SECURITIES EXCHANGE COMMISSION INVOLVING THE FIRM'S SPECIFIED DISCLOSURE OF A CONFLICT OF INTEREST ARISING FROM THE PARTICIPATION OF THE FIRM'S AFFILIATED BROKER DEALER IN A CASH SWEEP REVENUE SHARING AGREEMENT. PER THE TERMS OF THE SETTLEMENT, THE FIRM AGREED TO PAY DISGORGEMENT, PREJUDGMENT INTEREST AND A CIVIL PENALTY TOTALING $1,925,250. THE FIRM HAS DETERMINED TO AVOID ANY FURTHER CONFLICTS OF INTEREST, IT WILL NO LONGER PARTICIPATE IN SUCH ARRANGEMENTS.