J.W. Korth & Company, Limited Partnership

Allegations: SEC WANTED SERIAL NUMBERS OF REPUDIATED GERMAN DEBT TO DELIVER SAME TO GERMANY UNDER 17(A)(1) AND 17(B) OF THE SECURITY EXCHANGE ACT OF 1934. 02-06-97, SEC NEWS DIGEST ISSUE NO. 97-24, 2/5/97, ENFORCEMENT PROCEEDINGS DISCLOSE: ON 2/4, THE SEC FILED A CIVIL SUIT IN THE U.S. DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA AGAINST JAMES WILDER KORTH. THE COMPLAINT ALLEGES THAT KORTH HAS REPEATEDLY REFUSED TO GIVE TRUE, COMPLETE COPIES OF RECORDS CONTAINING CERTIFICATE NUMBERS FOR DEFAULTED PRE-WORLD WAR II GERMAN GOLD BONDS (BONDS) IN VIOLATION OF SECTIONS 17(A)(1) AND 17(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (EXCHANGE ACT) AND RULE 17A-4(J). THE SEC CHARGES THAT KORTH VIOLATED THESE PROVISIONS AS AN AIDER AND ABETTOR, PURSUANT TO SECTION 20(F) OF THE EXCHANGE ACT. THE SUIT SEEKS A TEMPORARY RESTRAINING ORDER, PRELIMINARY AND PERMANENT INJUNCTIONS, A CIVIL PENALTY AND CERTAIN ANCILLARY RELIEF. Status: Final Summary: THIS DID NOT INVOLVE CUSTOMERS AND WAS AN UNFORTUNATE DISPUTE ON PRINCIPLES OF LAW. 17(B)(1) OF THE EXCHANGE ACTS STATES: "ALL RECORDS OF PERSONS ARE SUBJECT AT ANY TIME, OR FROM TIME TO TIME, TO SUCH "REASONABLE" PERIODIC, SPECIAL, OR OTHER EXAMINATIONS BY REPRESENTATIVES OF THE COMMISSION". J W KORTH & COMPANY,IN AN EFFORT TO PROTECT ITS CUSTOMERS FOUND IT "UNREASONABLE" TO GIVE THE SEC SERIAL NUMBERS OF CERTAIN BONDS FOR THE FOLLOWING REASONS: 1. THE SEC DISCLOSED TO J W KORTH THAT IT INTENDED TO SEND THE SERIAL NUMBERS OF THE BONDS TO THE ISSUER, THE GERMAN GOVERNMENT. 2. J W KORTH & COMPANY HAD RECEIVED REPORTS FROM RELIABLE SOURCES,THAT GERMANY WOULD PUT THE SERIAL NUMBERS BONDS ON A "REPUDIATION LIST" AND THEREBY HARM THE INTERESTS OF J W KORTH'S CUSTOMERS WHO OWNED THE BONDS. DESPITE ITS ARGUMENT, J W KORTH WITHOUT EVER BEING GRANTED A HEARING WAS FOUND IN VIOLATION OF THE EXCHANGE ACT AND WAS GIVEN A REDUCED FINE, CENSURE AND A PERMANENT INJUNCTION. J W KORTH'S ACTIVITIES WERE NOT RESTRICTED IN ANY MANNER AND THE COURT LOWERED THE REQUESTED FINES BY 50%.

Allegations: NASD RULE 2110,6230 AND MSRB RULE G-14: RESPONDENT MEMBER FIRM REPORTED ITS MUNICIPAL SECURITIES TRANSACTIONS TO THE MSRB LATE: AND ITS CORPORATE BOND TRANSACTIONS REPORTED THROUGH TRACE WERE REPORTED LATE. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENT MEMBER FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS: THEREFORE, FIRM IS CENSURED AND FINED $2000.00 Summary: THIS DOCKET WAS INITIATED AND CLOSED 04/09/07. THE $2,000 FINE WAS PAID. OUR FIRM WAS GIVEN NOTICE THAT OUR FORM BD WAS NOT UPDATED. I HAVE REVIEWED THE CASE AND UPDATED IT AS OF 10/02/2007

Allegations: ITEM 7. FINRA ALLEGED OUR FIRM CHARGED CUSTOMERS EXCESSIVE MARK-UPS OR MARK DOWNS ON A TOTAL OF 69 MUNICIPAL, CORPORATE AND CMO TRANSACTIONS OUT OF A TOTAL OF MORE THAN 18000 FROM APRIL 2009 TO DECEMBER 2011. Status: Final Sanction Detail: OUR FIRM WAS CENSURED, ORDERED TO PAY RESTITUTION OF $29,268, PLUS $1,681.52 IN APPEAL COSTS, AND ORDERED US TO RETAIN AN INDEPENDENT CONSULTANT WITH EXPERIENCE IN ESTABLISHING PRICING PROCEDURES FOR SALES AND PURCHASES OF DEBT SECURITIES FOR THE LIMITED PURPOSE OF REVIEWING OUR FIRM'S PRICING PROCEDURES. Summary: AN INDEPENDENT CONSULTANT WILL BE RETAINED FOR A REVIEW OF OUR PRICING POLICIES AND RESTITUTION WILL BE MADE TO CLIENTS IN ACCORDANCE WITH THE ORDER.

Allegations: THE COMMISSION'S DIVISION OF SECURITIES AND RETAIL FRANCHISING CONDUCTED AN INVESTIGATION AND ALLEGED OUR FIRM VIOLATED 13.1-504B OF THE ACT BY EMPLOYING AN UNREGISTERED AGENT FOR CERTAIN TRANSACTIONS OCCURRING IN 2011. THE COMMISSION ALSO ALLEGED OUR FIRM VIOLATED STATUTE 21 VAC 5-20-240 BY NOT MAINTAINING TRUE AND ACCURATE RECORDS IN THAT THE INVESTOR'S LIQUID ASSETS FINANCIAL INFORMATION ON THE NEW ACCOUNT FORM WAS INCORRECT AND THAT OUR FIRM FAILED TO ENSURE THE INFORMATION WAS FULL AND ACCURATE. Status: Final Sanction Detail: $8,000 FINE ALONG WITH AN ADDITIONAL $2,000 TO DEFRAY COSTS OF THE INVESTIGATION..BOTH WERE PAID IN FULL WITH THE ENTRY OF THE ORDER. Summary: IN MARCH OF 2014 THE COMMONWEALTH NOTIFIED OUR FIRM IT WAS INVESTIGATING WHETHER OR NOT WE WERE IN VIOLATION OF THE VIRGINIA STATE SECURITIES ACT AND ASSOCIATED RULES. THEIR INVESTIGATION STEMMED FROM A SETTLEMENT WITH A CLIENT RESIDING IN VIRGINIA CONCERNING THE SALE OF A BOND. OUR FIRM RESPONDED TO THEIR INQUIRIES AND PROVIDED ADDITIONAL INFORMATION. IT WAS DETERMINED OUR FIRM ERRED IN BELIEVING TWO TRANSACTIONS BETWEEN OUR REPRESENTATIVE AND HIS FAMILY MEMBER WERE DE MINIMOUS AND DID NOT REQUIRE VIRGINIA REGISTRATION AND FURTHER THE FIRM ERRED IN NOT CORRECTING THE ACCOUNT STATEMENT FOR AN ACCURATE ASSESSMENT OF THE REPRESENTATIVE'S FAMILY MEMBER'S NET WORTH. ULTIMATELY THE MATTER WAS SETTLED FOR AN $8,000 FINE ALONG WITH AN ADDITIONAL $2,000 TO DEFRAY COSTS OF THE INVESTIGATION.

Allegations: 9/4/03 DUE TO ACTION BY THE SEC IN 1997 REGARDING A PRINCIPLED DISPUTE OVER THE REASONABLENESS UNDER THE LAW OF PROVIDING THE SERIAL NUMBERS OF CERTAIN BONDS TO EXAMINERS WHEN DOING SO MAY HAVE DEBILITATED THE INTERESTS OF J W KORTH CUSTOMERS(PLEASE SEE CIVIL DRP FOR DETAILS), THE STATE OF CONNECTICUT PLANNED TO DENY REGISTRATION UNLESS J W K0RTH ATTENDED A HEARING THERE. IT WAS NOT ECONOMICALLY FEASIBLE TO ATTEND THE HEARING AND THE APPLICATION WAS WITHDRAWN. Status: Final Sanction Detail: IN LIEU OF CONTESTING THE ALLEGATIONS IN THE NOTICE OF INTENT TO DENY, THE RESPONDENT SOUGHT TO WITHDRAW ITS APPLICATION, AND REPRESENTED TO THE AGENCY THAT IT HAD TRANSACTED NO SECURITIES BUSINESS WITH CONNECTICUT RESIDENTS. ON 10/22/2003, THE CONNECTICUT BANKING COMMISSIONER ISSUED AN ORDER CONDITIONING THE RESPONDENT'S WITHDRAWAL. THE ORDER CONDITIONING WITHDRAWAL RENDERED THAT WITHDRAWAL EFFECTIVE AS OF OCTOBER 22, 2003 SUBJECT TO CERTAIN CONDITIONS: 1) FOR THIRTY-SIX MONTHS, THE RESPONDENT WOULD NOT REAPPLY FOR REGISTRATION IN CONNECTICUT AS A BROKER-DEALER OR INVESTMENT ADVISER; 2) DURING THE THIRTY-SIX MONTH PERIOD, THE RESPONDENT WOULD NOT RELY ON ANY DEFINITIONAL EXCLUSION OR EXEMPTION THAT WOULD OTHERWISE EXCUSE REGISTRATION BY A PERSON TRANSACTING BUSINESS IN CONNECTICUT AS A BROKER-DEALER OR INVESTMENT ADVISER; 3) AT THE CONCLUSION OF THE THIRTY-SIX MONTH PERIOD, THE RESPONDENT COULD APPLY FOR REGISTRATION AS LONG AS IT FURNISHED A WRITTEN SUBMISSION STATING THAT IT HAD NOT BEEN THE SUBJECT OF ANY SECURITIES-RELATED COMPLAINT, ACTION OR PROCEEDING SINCE THE ENTRY OF THE CONDITIONING ORDER AND HAD BEEN IN COMPLIANCE WITH THE CONDITIONING ORDER; AND 4) THE RESPONDENT WOULD NOT VIOLATE THE CONNECTICUT UNIFORM SECURITIES ACT OR ANY RULE, REGULATION OR ORDER UNDER THE ACT. Summary: J W KORTH WITHDREW ITS APPLICATION FOR REGISTRATION IN CONNECTICUT.....10/22/08 J.W. KORTH APPLIED AND WAS GRANTED REGISTRATION IN CONNECTICUT.

Allegations: VIOLATIONS OF SECTIONS 17(A)(1) AND 17(B)OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 17A-4(J) THEREUNDER. Status: Final Sanction Detail: COMPANY WAS FINED $55,000.00 AND JAMES W. KORTH WAS FINED $5,500.00. FINES WERE PAID IN FULL ON AUGUST 27, 1998. Summary: IN A PRINCIPLED DISPUTE WITH SEC WHICH DID NOT INVOLVE CUSTOMERS OR INVESTORS, COMPANY FOUND IT UNREASONABLE TO GIVE SERIAL NUMBERS OF DEFAULTED GERMAN BONDS TO SEC WHEN GERMANY CLAIMED SOME WERE STOLEN AND WOULD NOT PUBLISH LOST AND STOLEN LIST AS REQUIRED BY U.S. LAW. COURT FOUND COMPANY'S ARGUMENT WITHOUT MERIT AND FOUND INFRACTION AND ENTERED CENSURE AND FINE AGAINST COMPANY. SERIAL NUMBERS WERE TURNED OVER TO SEC. NO HARM TO CUSTOMERS, INVESTORS OR ANY OTHER PARTIES WAS FOUND.

Allegations: THE SEC ALLEGED OUR FIRM EFFECTED 201 RISKLESS PRINCIPAL TRANSACTIONS FROM MARCH 2015 TO OCTOBER 2018 FOR INVESTMENT ADVISORY CLIENTS WITHOUT PROVIDING PRIOR WRITTEN DISCLOSURE OF OUR CAPACITY IN THE TRANSACTIONS AND OBTAINING TRANSACTION BY TRANSACTION CONSENT. THE SEC ALLEGED THESE TRANSACTIONS WERE IN VIOLATION OF SECTION 206(3) OF THE ADVISERS ACT. ADDITIONALLY, THE SEC ALLEGED OUR FIRM VIOLATED SECTION 206(4) AND RULE 206-4(7) BY FAILING TO IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF SECTION 206(3) OF THE ADVISERS ACT Status: Final Sanction Detail: SANCTIONS INCLUDED A $125,000 CIVIL PENALTY FINE, $46,857 DISGORGEMENT AND $4,676 PREJUDGEMENT INTEREST. THE FULL AMOUNT WAS LEVIED AGAINST THE FIRM AND IT WAS PAID IN FULL ON 09/14/21 Summary: THIS MATTER INVOLVED RULE INTERPRETATIONS OF THE TECHNICAL ASPECTS OF RECORDING AND REPORTING FOR PURCHASES AND SALES OF BONDS AND THE RELEVANCE OF CERTAIN DISCLOSURES. AS A RESULT OF THE PROCEEDINGS, OUR FIRM HAS MADE CHANGES TO OUR POLICIES AND PROCEDURES REGARDING THESE TYPES OF TRANSACTIONS. FINES, DISGORGEMENTS AND PREJUDGMENT INTEREST HAS BEEN REMITTED TO THE SEC.