Florence Capital Advisors, Llc

Allegations: ON SEPTEMBER 29, 2023, THE SEC PUBLISHED AN ORDER OF SETTLEMENT BETWEEN IT AND THE REGISTRANT AND GREGORY HERSCH ("RESPONDENTS") RELATING TO THE SEC'S FINDING THAT THE RESPONDENTS FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST IN CONNECTION WITH CLIENT INVESTMENTS IN A THIRD-PARTY PRIVATE FUND, FF FUND I, L.P. (THE "FUND"), FROM WHICH REGISTRANT WAS RECEIVING SUBSTANTIAL ADVISORY FEES, AND THAT REGISTRANT RECEIVED FEES FROM THE FUND PURSUANT TO ADVISORY AGREEMENTS, WHILE RECOMMENDING INVESTMENTS IN THE FUND TO REGISTRANT'S CLIENTS AND ADVISING REGISTRANT'S CLIENTS ON THEIR EXISTING INVESTMENTS IN THE FUND. WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTS CONSENTED TO THE ENTRY OF THE SEC'S ORDER FINDING VIOLATIONS OF SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940, AND AGREED TO A CEASE-AND-DESIST ORDER AGAINST FUTURE VIOLATIONS OF THIS PROVISION, A CENSURE AND A $200,000 CIVIL PENALTY. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTS CONSENTED TO THE ENTRY OF THE SEC'S ORDER FINDING VIOLATIONS OF SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940, AND AGREED TO A CEASE-AND-DESIST ORDER AGAINST FUTURE VIOLATIONS OF THIS PROVISION, A CENSURE, AND A $200,000 CIVIL PENALTY, WHICH WAS PAID ON OCTOBER 4, 2023. Summary: THIS MATTER WAS SETTLED ON SEPTEMBER 29, 2023 AS DESCRIBED ABOVE.