True Link Financial Advisors, Llc

Allegations: IN AN MAY 2, 2022 CEASE AND DESIST ORDER (THE "ORDER"), THE SEC DESCRIBES AN ORLANDO-BASED NONPROFIT (THE "NPC") AND AN ORLANDO-BASED FOR-PROFIT COMPANY (THE "FPC") AND FINDS THAT, WHILE CERTAIN POOLED SPECIAL NEEDS TRUSTS (THE "POOLED TRUSTS") WERE REPRESENTED TO BE MANAGED BY NPC AS TRUSTEE, IN REALITY, FPC OPERATED AND MANAGED THE TRUSTS. POOLED TRUSTS BY LAW MUST BE ESTABLISHED AND MANAGED BY A NON-PROFIT ASSOCIATION. THE ORDER FINDS THAT TRUE LINK FINANCIAL ADVISORS, LLC ("TRUE LINK") ACTED AS INVESTMENT AND ASSET MANAGER FOR THE POOLED TRUSTS WHEN IT SHOULD HAVE KNOWN THEY ARE NOT MANAGED BY A NON-PROFIT TRUSTEE. AS A RESULT OF PROVIDING THESE SERVICES, TRUE LINK AND KAI STINCHCOMBE, THE FIRM'S CEO, CAUSED VIOLATIONS BY FPC, NPC, AND TWO OF FPC'S PRINCIPALS OF SECTION 17(A)(3) OF THE SECURITIES ACT, AND CAUSED VIOLATIONS BY FPC AND TWO OF FPC'S PRINCIPALS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 THEREUNDER. Status: Final Sanction Detail: THE ORDER REQUIRES TRUE LINK AND STINCHCOMBE TO PAY CIVIL MONEY PENALTIES OF $200,000 AND $20,000, RESPECTIVELY (WHICH WERE PAID ON MAY 6, 2022). THE ORDER ALSO REQUIRES THE PARTIES TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY PARTY TO COMMIT ANY VIOLATIONS OF THE STATUTES AND RULES MENTIONED IN ITEM 7. SOLELY FOR THE PURPOSES OF SETTLING THESE PROCEEDINGS, TRUE LINK AND STINCHCOMBE CONSENTED TO THE ORDER WITHOUT ADMITTING OR DENYING THE MATTERS IN IT (EXCEPT THE SEC'S JURISDICTION). Summary: THE FINDINGS AND SANCTIONS ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.