Stilwell Value Llc

Allegations: THE SEC ALLEGED THAT THE ADVISER AND MR. STILWELL VIOLATED SECTIONS 206(2), 206(4), 206(7) AND 207 OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED AND RULES 206 (4)-7 AND 206 (4)-8 PROMULGATED THEREUNDER. Status: Final Sanction Detail: MR. STILWELL WAS SUSPENDED FOR 12 MONTHS (FROM 3/30/15-3/30/16) FROM ASSOCIATION WITH ANY BROKER/DEALER, INVESTMENT ADVISER, ETC. MR. STILWELL PAID A CIVIL MONETARY FINE OF $100,000 ON MARCH 19, 2015. THE ADVISER PAID A CIVIL MONETARY FINE OF $250,000 ON MARCH 30, 2015. Summary: ON MARCH 16, 2015, STILWELL VALUE LLC (THE "ADVISER") AND MR. STILWELL CONSENTED TO THE ENTRY OF AN ADMINISTRATIVE SEC ORDER THAT (1) ALLEGED VIOLATIONS OF SECTIONS 206(2), 206(4), 206(7) AND 207 OF THE INVESTMENT ADVISERS ACT OF 1940, AS AMENDED (THE "IAA") AND RULES 206(4)-7 AND 206(4)-8 PROMULGATED THEREUNDER FOR, AMONG OTHER THINGS, FAILING TO ADEQUATELY DISCLOSE CERTAIN CONFLICTS OF INTEREST PRESENTED BY INTER-FUND LOANS BETWEEN CERTAIN PRIVATE INVESTMENT PARTNERSHIPS MANAGED BY THE ADVISER AND/OR MR. STILWELL; (2) REQUIRED THE ADVISER AND MR. STILWELL TO CEASE AND DESIST FROM COMMITTING FUTURE VIOLATIONS OF THE RELEVANT PROVISIONS OF THE IAA; (3) SUSPENDED (FROM MARCH 2015 - MARCH 2016) MR. STILWELL FROM ASSOCIATION WITH ANY BROKER/DEALER, INVESTMENT ADVISER, ETC.; (4) CENSURED THE ADVISER; (5) IMPOSED AN OBLIGATION ON THE ADVISER TO DISTRIBUTE $239,157 IN MANAGEMENT FEES AND PREJUDGMENT INTEREST TO CERTAIN FUND INVESTORS; AND (6) REQUIRED THE ADVISER TO ENGAGE AN INDEPENDENT MONITOR FOR THREE YEARS, WHICH ENGAGEMENT CONCLUDED IN APRIL 2018. ALL PENALTY AND REPAYMENT OBLIGATIONS HAVE BEEN FULLY DISCHARGED.

Allegations: ALLEGED VIOLATIONS OF SECTIONS 13(D)(1) AND 13(D)(2) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED, AND RULES 13D-1 AND 13D-2 PROMULGATED THEREUNDER, FOR FAILING TO TIMELY FILE CERTAIN REPORTS ON SCHEDULE 13D AND SCHEDULE 13G Status: Final Sanction Detail: THE $75,000 FINE AMOUNT WAS PAID IN FULL ON SEPTEMBER 26, 2024. Summary: ON SEPTEMBER 25, 2024, STILWELL VALUE LLC (THE "ADVISER") CONSENTED TO THE ENTRY OF AN SEC ADMINISTRATIVE CEASE AND DESIST ORDER (THE "ORDER") THAT (1) ALLEGED VIOLATIONS OF SECTIONS 13(D)(1) AND 13(D)(2) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED, AND RULES 13D-1 AND 13D-2 PROMULGATED THEREUNDER, FOR FAILING TO TIMELY FILE CERTAIN REPORTS ON SCHEDULE 13D AND SCHEDULE 13G; (2) REQUIRED THE ADVISER TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF THE PROVISIONS CHARGED; AND (3) IMPOSED A $75,000 CIVIL MONETARY PENALTY. THE ADVISER HAS SATISFIED THE CIVIL MONETARY PENALTY IN FULL.