P.A.W. Capital Partners, Lp

Allegations: IT WAS ALLEGED THAT THE ADVISER VIOLATED AND CAUSED VIOLATIONS OF SECTIONS 13(D) AND 16(A) OF THE EXCHANGE ACT OF 1934 AND RULES 13D-1, 13D-2 AND 16A-3 PROMULGATED THEREUNDER. Status: Final Sanction Detail: THE ADVISER PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $68,000 ON SEPTEMBER 16, 2014. Summary: WITHOUT ADMITTING OR DENYING ANY WRONGDOING, THE ADVISER AGREED TO THE TERMS OF THE SETTLEMENT WITH THE SEC ON SEPTEMBER 10, 2014, THAT INCLUDES THE SANCTIONS DESCRIBED IN QUESTION 12 ABOVE.

Allegations: PRIOR TO JOINING P.A.W. AND IN CONJUNCTION WITH HIS PRIOR EMPLOYMENT, GERALD T. MALONE, AN ADVISORY AFFILIATE OF THE ADVISER, IN APRIL 2005, SETTLED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AN SEC ADMINISTRATIVE PROCEEDING IN WHICH THE SEC ALLEGED THAT MR. MALONE, A FORMER OFFICER OF ALLIANCE CAPITAL MANAGEMENT, L.P. ("ALLIANCE CAPITAL") AND FORMER PORTFOLIO MANAGER OF THE ALLIANCE TECHNOLOGY MUTUAL FUND AND ALLIANCE TECHNOLOGY HEDGE FUND, AIDED AND ABETTED ALLIANCE CAPITAL'S VIOLATIVE CONDUCT WITH REGARD TO CERTAIN MARKET TIMING TRANSACTIONS INVOLVING THE ALLIANCE TECHNOLOGY MUTUAL FUND. Status: Final Sanction Detail: MR. MALONE WAS SUSPENDED AND PROHIBITED FOR A PERIOD OF 12 MONTHS (BEGINNING APRIL 28, 2005) FROM ASSOCIATING WITH AND/OR EMPLOYMENT BY ANY INVESTMENT ADVISER OR REGISTERED INVESTMENT COMPANY AND FOR THREE YEARS (BEGINNING APRIL 28, 2005) PROHIBITED FROM SERVING AS A CHAIRMAN, DIRECTOR, OR OFFICER OF ANY INVESTMENT ADVISER OR REGISTERED INVESTMENT COMPANY. MR. MALONE WAS ORDERED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $150,000 AND DISGORGEMENT IN THE AMOUNT OF $1 TO THE UNITED STATES TREASURY. Summary: AS NOTED ABOVE, PRIOR TO JOINING P.A.W. AND IN CONJUNCTION WITH HIS PRIOR EMPLOYMENT, GERALD T. MALONE, AN ADVISORY AFFILIATE OF THE ADVISER, IN APRIL 2005, SETTLED, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AN SEC ADMINISTRATIVE PROCEEDING IN WHICH THE SEC ALLEGED THAT MR. MALONE, A FORMER OFFICER OF ALLIANCE CAPITAL MANAGEMENT, L.P. ("ALLIANCE CAPITAL") AND FORMER PORTFOLIO MANAGER OF THE ALLIANCE TECHNOLOGY MUTUAL FUND AND ALLIANCE TECHNOLOGY HEDGE FUND, AIDED AND ABETTED ALLIANCE CAPITAL'S VIOLATIVE CONDUCT WITH REGARD TO CERTAIN MARKET TIMING TRANSACTIONS INVOLVING THE ALLIANCE TECHNOLOGY MUTUAL FUND.