Voya Financial Advisors, Inc.

Allegations: ALLEGATIONS THAT THE FIRM AND FOUR CONTROL AFFILIATES (DIRECTED SERVICES, LLC, ING AMERICA EQUITIES, INC., ING FINANCIAL ADVISERS, LLC, AND ING INVESTMENT ADVISORS, LLC) COLLECTIVELY KNOWN AS ("RESPONDENT FIRMS"), WERE INVOLVED IN VIOLATIONS OF THE SUPERVISION AND EMAIL RETENTION REQUIREMENTS OF FINRA RULES AND FEDERAL SECURITIES LAWS OVER AN EXTENDED PERIOD OF TIME. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS, THE RESPONDENT FIRMS CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS BY AGREEING TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC") WITH FINRA. THE RESPONDENT FIRMS WERE CENSURED AND FINED IN THE AGGREGATE AMOUNT OF $1.2 MILLION, OF WHICH ING FINANCIAL PARTNERS, INC. WAS RESPONSIBLE FOR $347,394.96. IN THE AWC, FINRA ACKNOWLEDGED THAT THE RESPONDENT FIRMS SELF-REPORTED THE EMAIL ISSUES DESCRIBED HEREIN AND UNDERTOOK AN INTERNAL REVIEW OF THEIR SUPERVISORY POLICIES, PROCEDURES AND SYSTEMS RELATING TO THESE ISSUES. FINRA STATED THAT THE SANCTIONS REFLECT THE CREDIT THAT THE RESPONDENT FIRMS HAVE BEEN GIVEN FOR SELF-REPORTING THESE ISSUES, AND FOR THE SUBSTANTIAL ASSISTANCE THEY PROVIDED TO FINRA DURING ITS INVESTIGATION BY, AMONG OTHER THINGS, PROVIDING INFORMATION OBTAINED AS A RESULT OF THEIR INTERNAL INVESTIGATION. THE RESPONDENT FIRMS FURTHER AGREED TO COMPLY WITH THE FOLLOWING UNDERTAKINGS: THE RESPONDENT FIRMS WILL EACH CONDUCT A COMPREHENSIVE REVIEW OF THEIR SYSTEMS AND PROCEDURES FOR THE CAPTURE, RETENTION AND REVIEW OF EMAIL TO DETERMINE THAT THOSE SYSTEMS AND PROCEDURES ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE RECORDKEEPING AND SUPERVISORY REQUIREMENTS OF FINRA RULES AND THE FEDERAL SECURITIES LAWS.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. (FIRM) DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS) BETWEEN JANUARY 1, 2009 AND MAY 26, 2016. ELIGIBLE CUSTOMERS WERE INSTEAD SOLD CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. FINRA ALSO ALLEGED THAT DURING THIS PERIOD THE FIRM FAILED TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS TO MUTUAL FUNDS TRANSACTIONS BY ELIGIBLE CUSTOMERS, FAILED TO MAINTAIN WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ASSIST FINANCIAL ADVISORS IN DETERMINING WHETHER A CUSTOMER WAS ELIGIBLE FOR A SALES CHARGE WAIVER, AND FAILED TO NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. FINRA ALLEGED THAT THESE SUPERVISORY VIOLATIONS RESULTED IN THE FIRM VIOLATING NASD CONDUCT RULE 3010 (FOR VIOLATIONS BEFORE DECEMBER 1, 2014), AND FINRA RULE 3110 (FOR VIOLATIONS AFTER DECEMBER 1, 2014, AND FINRA RULE 2010. Status: Final Sanction Detail: THE FIRM CONSENTED TO THE ENTRY OF A CENSURE, AND AGREED TO PROVIDE REMEDIATION TO ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES-CHARGE WAIVER. Summary: WITHOUT ADMITTING OR DENYING THESE FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA. THE FIRM FURTHER AGREED TO PROVIDE FINRA WITH I) A SCHEDULE OF ELIGIBLE CUSTOMERS IDENTIFIED FOR REMEDIATION, AND A DETAILED PLAN TO REMEDIATE ELIGIBLE CUSTOMERS BASED ON SPECIFIC DETAILS WITHIN 60 DAYS OF THE AWC'S ACCEPTANCE, AND II) A SATISFACTORY PROOF OF PAYMENT OF RESTITUTION TO ELIGIBLE CUSTOMERS BY A REGISTERED PRINCIPAL OF THE FIRM NO LATER THAN 180 DAYS FROM THE AWC'S ACCEPTANCE. THE FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY $125,982. FINRA ACCEPTED THE AWC ON 4/23/2019.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT BETWEEN MARCH 2018 AND SEPTEMBER 2019, VOYA FINANCIAL ADVISORS, INC. (FIRM) PAID APPROXIMATELY $2.9 MILION TO AN UNREGISTERED ENTTIY IN CONNECTION WITH THE SALE OF VARIABLE UNIVERSAL LIFE INSURANCE (VUL), A SECURITIES PRODUCT. THE FIRM AND THE UNREGISTERED ENTITY WERE PARTIES TO A VARIABLE MARKETING AGREEMENT, WHICH PROVIDED THAT THE UNREGISTERED ENTITY WOULD PROVIDE A VARIETY OF SERVICES TO FACILITATE VUL SALES, INCLUDING DISTRIBUTING SALES MATERIALS AND ASSISTING WITH SALES PROMOTIONAL ACTIVITIES. FINRA ALLEGED THAT THESE PAYMENTS RESULTED IN THE FIRM VIOLATING FINRA RULE 2040 AND FINRA RULE 2010. Status: Final Sanction Detail: THE FIRM CONSENTED TO THE ENTRY OF A CENSURE AND TO PAY A FINE IN THE AMOUNT OF $500,000. THE FIRM PAID THIS FINE ON 1/30/2024. Summary: WITHOUT ADMITTING OR DENYING THESE FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA. THE FIRM FURTHER AGREED TO PAY THE MONETORY SANCTION OF $500,000 AT THE TIME THE AWC WAS ACCEPTED. FINRA ACCEPTED THE AWC ON JANUARY 25, 2024.

Allegations: ALLEGATIONS THAT FROM 04/01/2009 TO 04/30/2014 THE FIRM FAILED TO APPLY VOLUME DISCOUNTS TO CERTAIN ELIGIBLE PURCHASES OF NON-TRADED REITS AND BDCS IN VIOLATION OF FINRA RULE 2010; AND THAT FROM 5/01/2009 TO 04/30/2015 THE FIRM FAILED TO APLLY SALES CHARGE DISCOUNTS TO CERTAIN ELIGIBLE PURCHASES OF UITS IN VIOLATION OF FINRA RULE 2010. Status: Final Sanction Detail: FINRA ALLEGED THAT THE FIRM FAILED TO IDENTIFY AND APPLY VOLUME DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE NON-TRADED REAL ESTATE INVESTMENT TRUST (REIT) AND BUSINESS DEVELOP COMPANY (BDC) PURCHASES, RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $42,000; FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REGARDING THE SALE OF NON-TRADED REITS AND BDCS; FAILED TO HAVE IN PLACE PROCEDURES REASONABLY DESIGNED TO IDENTIFY ACCOUNTS THAT WOULD BE ELIGIBLE FOR VOLUME DISCOUNTS; FAILED TO PROVIDE ADEQUATE GUIDELINES, INSTRUCTIONS OR POLICIES FOR ITS ASSOCIATED PERSONS AND SUPERVISORS TO FOLLOW TO DETERMINE WHETHER A CUSTOMER PURCHASE QUALIFIED FOR A VOLUME DISCOUNT AND TO ENSURE THAT THE CUSTOMER WAS AWARE OF THE AVAILABLE DISCOUNT; FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' PURCHASES OF UNIT INVESTMENT TRUSTS (UIT), RESULTING IN AN AGGREGATE OF $322,000 IN EXCESSIVE SALES CHARGES ON 1,868 ELIGIBLE UIT PURCHASES; FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ENSURE THE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES; FAILED TO HAVE IN PLACE WRITTEN PROCEDURES FOR DETERMINING WHETHER A UIT PURCHASE WAS ELIGIBLE FOR A SALES CHARGE DISCOUNT AND FAILED TO IDENTIFY ANYONE RESPONSIBLE FOR REVIEWING UIT TRANSACTIONS FOR THE APPROPRIATE APPLICATION OF SALES CHARGE DISCOUNTS. WITHOUT ADMITTING OR DENYING THE FACTS DESCRIBED, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THE FINDINGS. THE FIRM WAS ORDERED TO REVIEW ALL NON-TRADED REIT AND BDC SALES IT MADE DURING THE TIME PERIOD OF APRIL 1, 2009 THROUGH APRIL 30, 2014, AND CERTIFY THAT IT HAS IDENTIFIED ALL TRANSACTIONS FOR WHICH A CUSTOMER DID NOT RECEIVE THE VOLUME DISCOUNT FOR WHICH IT WAS ELIGIBLE. THE FIRM IDENTIFIED ALL CUSTOMERS AND/OR TRANSACTIONS AND PAID RESTITUTION TO AFFECTED CUSTOMERS.

Allegations: THE COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. ("FIRM") VIOLATED THE MASSACHUSETTS UNIFORM SECURITIES ACT, MASS. GEN. LAWS CH. 110A ("ACT'), BY FAILING TO REGISTER TWO (2) OF ITS INVESTMENT ADVISER REPRESENTATIVES WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND PROVIDED INVESTMENT ADVISORY SERVICES TO RESIDENTS OF THE COMMONWEALTH BETWEEN AUGUST 24, 2012 TO JANUARY 30, 2017 (THE "RELEVANT PERIOD"). Status: Final Sanction Detail: THE FIRM AGREED TO PAY RESTITUTION OF ALL ASSET MANAGEMENT FEES PAID BY CLIENTS LOCATED IN THE COMMONWEALTH TO THE REPRESENTATIVES IN QUESTION DURING THE RELEVANT PERIOD ("ELIGIBLE CLIENTS"), WHICH WAS DETERMINED TO AMOUNT TO $10,936.47. THE FIRM PAID A FINE OF $75,000 Summary: THE FIRM ADMITTED TO THE FACTS DESCRIBED BUT NEITHER ADMITTED NOR DENIED ANY VIOLATIONS OF LAW. THE FIRM CONSENTED TO THE ENTRY OF A CONSENT ORDER THAT FOUND THAT THE FIRM VIOLATED SECTIONS 201(C) AND 201(D) OF THE ACT. THE FIRM AGREED TO I.) CEASE AND DESIST FROM ANY VIOLATIONS OF SECTIONS 201(C) AND 201(D) OF THE ACT IN THE COMMONWEALTH, II.) REGISTER ITS INVESTMENT ADVISER REPRESENTATIVES IN THE COMMONWEALTH PRIOR TO THEM PROVIDING INVESTMENT ADVISORY SERVICES IN THE COMMONWEALTH, III.) REVIEW ITS WRITTEN SUPERVISORY POLICIES AND PROCEDURES WITH RESPECT TO, AND PROVIDE COMPLIANCE WITH SECTIONS 201(C) AND 201(D) OF THE ACT, IV.) PAY RESTITUTION OF ALL ASSET MANAGEMENT FEES PAID BY CLIENTS LOCATED IN THE COMMONWEALTH TO THE REPRESENTATIVES IN QUESTION DURING THE RELEVANT PERIOD ("ELIGIBLE CLIENTS"), WHICH WAS DETERMINED TO AMOUNT TO $10,936.47, V.) MEMORIALIZE ITS RESTITUTION IN A LETTER ("RESTITUTION LETTER") TO EACH ELIGIBLE CLIENT WITHIN THIRTY (30) DAYS OF THE CONSENT ORDER, AND VI.) PROVIDE THE RESTITUTION LETTER TO THE DIVISION AT LEAST TEN (10 ) DAYS PRIOR TO THE SENDING OF THE RESTITUTION LETTER TO ELIGIBLE CLIENTS. THE FIRM FURTHER AGREED TO REIMBURSE THE ASSET MANAGEMENT FEES TO EACH ELIGIBLE CLIENT WITHIN FORTY-FIVE (45) DAYS OF THE CONSENT ORDER, AND SUBMIT TO THE DIVISION A REPORT DETAILING THE DISTRIBUTION OF ALL FUNDS TO ELIGIBLE CLIENTS WITHIN NINETY (90) DAYS OF THE CONSENT ORDER. THE FIRM PAID A FINE OF $75,000

Allegations: NEW JERSEY BUREAU OF SECURITIES ("BUREAU") ALLEGES THAT THE FIRM FAILED TO FOLLOW ITS PROCEDURES, OR THAT ITS PROCEDURES WERE INADEQUATE, WITH RESPECT TO DETECTING PRIOR UNDISCLOSED EMPLOYMENT DISCIPLINARY ISSUES, CUSTOMER FUND DISBURSEMENT PROCEDURES, AND TRADE REVIEW PROCEDURES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE BUREAU'S FINDINGS OF FACT AND CONCLUSIONS OF LAW, THE FIRM ENTERED INTO A CONSENT ORDER WITH THE BUREAU PURSUANT TO WHICH THE FIRM AGREED TO CEASE AND DESIST FROM FUTURE VIOLATIONS OF NEW JERSEY UNIFORM SECURITIES LAWS AND TO THE PAYMENT OF A $50,000 CIVIL MONETARY PENALTY WITH $30,000 OF THIS AMOUNT SUSPENDED BASED UPON THE FIRM VOLUNTARILY AND ON ITS OWN INITIATIVE: 1. PROMPTLY TERMINATING THE TWO SUBJECT REGISTERED REPRESENTATIVES UPON DISCOVERING THEIR MISCONDUCT, AND PLACING THEIR SUPERVISOR ON SUSPENSION; 2. PROMPTLY PAYING RESTITUTION TO CERTAIN AFFECTED CUSTOMERS, AND; 3. REVISING ITS SUPERVISORY PROCEDURES WITH RESPECT TO AUTHORIZATION OF THIRD-PARTY CHECKS. THE REMAINING CIVIL MONETARY PENALTY IN THE AMOUNT OF $20,000 IS DUE AND PAYABLE WITHIN 10 DAYS OF THE ENTRY OF THE CONSENT ORDER.

Allegations: THE FLORIDA OFFICE OF FINANCIAL REGULATION ALLEGED THAT VOYA FINANCIAL ADVISORS WAS IN VIOLATION OF RULE 69W-600.013(1)(H)(1)., FLORIDA ADMINISTRATIVE STATUTES, BY VIOLATING NASD RULE 3010(B)(1), BY FAILING TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES IN THE SUPERVISION OF VARIABLE ANNUITY PURCHASES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF A FINAL ORDER. IN THE FINAL ORDER, THE FLORIDA OFFICE OF FINANCIAL REGULATION STATED THAT THE FIRM'S TRADE REVIEW PRINCIPALS FAILED TO REQUEST ADDITIONAL INFORMATION TO DETERMINE SUITABILITY FOR SIX (6) CUSTOMER ANNUITY PURCHASES, FAILED TO OBTAIN FULL DOCUMENTATION OF VARIABLE ANNUITY PURCHASES FOR FOUR (4) CUSTOMER FILES, AND FAILED TO ADEQUATELY REVIEW SURRENDER CHARGES ON TWENTY-TWO (22) ANNUITY TRANSACTIONS, OF WHICH FOURTEEN (14) WERE IDENTIFIED BY THE FIRM. Status: Final Sanction Detail: THE FIRM AGREED TO CEASE AND DESIST FROM VIOLATIONS OF CHAPTER 517, FLORIDA STATUTES, AND THE OFFICE'S RULES PROMULGATED THEREUNDER, AND AGREED TO HENCEFORTH STRICTLY COMPLY WITH ALL PROVISIONS OF CHAPTER 517, FLORIDA STATUTES, AND THE OFFICE'S RULES PROMULGATED THEREUNDER. THE FIRM PAID AN ADMINISTRATIVE FINE OF $50,000.

Allegations: THE SECURITIES AND BUSINESS INVESTMENTS DIVISION OF THE CONNECTICUT DEPARTMENT OF BANKING ("DIVISION") ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. ("FIRM") VIOLATED SECTION 36B-31-6(F) OF THE REGULATIONS OF CONNECTICUT STATE AGENCIES (THE "REGULATIONS") BY FAILING TO ENFORCE AND MAINTAIN A SYSTEM FOR SUPERVISING THE ACTIVITIES OF ITS AGENTS, INVESTMENT ADVISER AGENTS AND CONNECTICUT OFFICE OPERATIONS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS. THE ALLEGATIONS PERTAIN TO FORMER FIRM AGENT DALE QUESNEL'S ("QUESNEL") SALE OF UNREGISTERED SECURITIES TO INVESTORS IN CONNECTICUT AND OTHER STATES ("INVESTORS"). THE DIVISION FOUND, THROUGH A MARCH 3, 2016 ORDER AGAINST QUESNEL, THAT QUESNEL PARTICIPATED IN PRIVATE SECURITIES TRANSACTIONS WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO THE FIRM. Status: Final Sanction Detail: 1) AN ADMINISTRATIVE FINE, PAYABLE TO THE TREASURER OF THE STATE OF CONNECTICUT, OF $100,000; 2) THE ESTABLISHMENT AND ADMINISTRATION OF A FUND (THE "FUND") TO REIMBURSE INVESTORS IN THE AMOUNT OF $915,000, AND THE USE OF ALL REASONABLE EFFORTS TO CONFIRM THAT THE CONTACT AND ADDRESS INFORMATION FOR THE INVESTORS IS UP TO DATE; 3) NO LATER THAN THIRTY DAYS FROM THE ORDER, DISTRIBUTION OF A COPY OF THE ORDER AND A WRITTEN NOTICE, PREAPPROVED BY THE DIVISION DIRECTOR, TO INVESTORS STATING THAT THE INVESTOR OR ITS ESTATE IS ENTITLED TO A PAYMENT FROM THE FUND IF HE OR SHE RESPONDS TO THE FIRM WITHIN SIXTY DAYS AND PROVIDES DISTRIBUTION INSTRUCTIONS SUFFICIENT TO MAKE A PAYMENT, AND 4) NO LATER THAN NINETY DAYS FROM THE ORDER, DISBURSEMENT OF MONEY OWED FROM THE FUND, ACCORDING TO THE AMOUNTS IDENTIFIED BY THE DIVISION, TO THE INVESTORS THAT REPLIED, AND PROVIDE PROOF OF DISBURSEMENT TO THE DIVISION VIA A COPY OF THE CHECK OR WIRE TRANSFER TO EACH INVESTOR. Summary: ON APRIL 23, 2018 THE CONNECTICUT DEPARTMENT OF BANKING, THROUGH THE SECURITIES AND BUSINESS INVESTMENTS DIVISION (THE "DIVISION"), ENTERED AN ORDER (THE "ORDER") TO CEASE AND DESIST, MAKE RESTITUTION, AND A NOTICE OF INTENT TO FINE AGAINST VOYA FINANCIAL ADVISORS, INC. ("VFA" OR THE "FIRM"). THE ORDER STATES THAT THE FIRM VIOLATED SECTION 36B-31-6F OF THE REGULATIONS UNDER THE CONNECTICUT UNIFORM SECURITIES ACT BY FAILING TO ESTABLISH, ENFORCE AND MAINTAIN A SYSTEM FOR SUPERVISING THE ACTIVITIES OF ITS AGENTS THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS. ON MAY 3, 2018, THE FIRM REQUESTED A HEARING ON THE MATTERS ALLEGED IN THE ORDER. ON NOVEMBER 13, 2018 THE DIVISION, ENTERED AN AMENDED ORDER (THE "AMENDED ORDER") TO CEASE AND DESIST, MAKE RESTITUTION, AND A NOTICE OF INTENT TO FINE AGAINST VOYA FINANCIAL ADVISORS, INC. THE LEGAL ALLEGATIONS IN THE AMENDED ORDER REMAIN THE SAME AS THOSE IN THE ORIGINAL ORDER. THE FIRM ACKNOWLEDGED THE DIVISION'S ALLEGATIONS AGAINST IT AND, WITHOUT ADMITTING OR DENYING THEM, ENTERED INTO A CONSENT ORDER. THE FIRM AGREED TO THE SANCTIONS DESCRIBED IN SECTION 12(C), AND TO IMMEDIATELY NOTIFY THE DIVISION IF ANY INVESTOR CANNOT BE LOCATED AFTER A DILIGENT SEARCH, FAILS TO PROVIDE SUFFICIENT DISBURSEMENT INSTRUCTIONS, FAILS TO TIMELY RESPOND TO THE NOTICE, OR UNEQUIVOCALLY DENIES DISBURSEMENT IN WRITING. THE ORDER WAS ENTERED ON MARCH 11, 2019.

Allegations: THE OHIO DEPARTMENT OF INSURANCE ALLEGED THAT THE FIRM VIOLATED OHIO REVISED CODE § 3905.22(A) BY FAILING TO TIMELY REPORT A REGULATORY ACTION, TAKEN BY FINRA ON JULY 20, 2015, FINING THE FIRM $325,000 AND ORDERING PAYMENT OF RESTITUTION IN THE AMOUNT OF $41,856.20 (THE "REGULATORY ACTION"). BY FAILING TO REPORT THE REGULATORY ACTION, THE FIRM ALSO VIOLATED OHIO REVISED CODE § 3905.14(B) (1) BY PROVIDING AN INCORRECT ANSWER ON THE FIRM'S LICENSE RENEWAL PAPERWORK. ON AUGUST 21, 2015 THE FIRM MARKED "NO" WHEN ASKED IF IT HAD BEEN INVOLVED IN AN ADMINISTRATIVE ACTION THAT HAD NOT BEEN PREVIOUSLY REPORTED TO THE DEPARTMENT. THE FIRM ADMITTED THAT THE AFOREMENTIONED ALLEGATIONS ARE TRUE AND ACCURATE AND THAT THE STATUTES CITED WERE VIOLATED. THE FIRM PAID A CIVIL PENALTY OF $400.00 AND ADMINISTRATIVE COSTS OF $100.00." Status: Final Sanction Detail: THE FIRM PAID A CIVIL PENALTY OF $400.00 AND ADMINISTRATIVE COSTS OF $100.00. Summary: THE OHIO DEPARTMENT OF INSURANCE ALLEGED THAT THE FIRM VIOLATED OHIO REVISED CODE § 3905.22(A) BY FAILING TO TIMELY REPORT A REGULATORY ACTION, TAKEN BY FINRA ON JULY 20, 2015, FINING THE FIRM $325,000 AND ORDERING PAYMENT OF RESTITUTION IN THE AMOUNT OF $41,856.20 (THE "REGULATORY ACTION"). BY FAILING TO REPORT THE REGULATORY ACTION, THE FIRM ALSO VIOLATED OHIO REVISED CODE § 3905.14(B) (1) BY PROVIDING AN INCORRECT ANSWER ON THE FIRM'S LICENSE RENEWAL PAPERWORK. ON AUGUST 21, 2015 THE FIRM MARKED "NO" WHEN ASKED IF IT HAD BEEN INVOLVED IN AN ADMINISTRATIVE ACTION THAT HAD NOT BEEN PREVIOUSLY REPORTED TO THE DEPARTMENT. THE FIRM ADMITTED THAT THE AFOREMENTIONED ALLEGATIONS ARE TRUE AND ACCURATE AND THAT THE STATUTES CITED WERE VIOLATED. THE FIRM PAID A CIVIL PENALTY OF $400.00 AND ADMINISTRATIVE COSTS OF $100.00."

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (SEC) ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. (FIRM), IN ITS ROLE AS A REGISTERED INVESTMENT ADVISER, FAILED TO DISCLOSE TO ITS CLIENTS THE COMPENSATION IT RECEIVED THROUGH AN ARRANGEMENT WITH A THIRD PARTY BROKER-DEALER (CLEARING FIRM), AND CONFLICTS OF INTEREST ARISING FROM THAT COMPENSATION. THROUGH AN ADDENDUM TO THE FULLY-DISCLOSED CLEARING AGREEMENT BETWEEN CLEARING FIRM AND THE FIRM, CLEARING FIRM SHARED WITH THE FIRM CERTAIN REVENUES IT RECEIVED FROM THE MUTUAL FUNDS IN CLEARING FIRM'S NO-TRANSACTION-FEE MUTUAL FUND PROGRAM (NTF PROGRAM). IN A SEPARATE AGREEMENT, CLEARING FIRM AGREED TO PAY THE FIRM A CERTAIN PERCENTAGE OF SERVICE FEES THAT CLEARING FIRM RECEIVED FROM CERTAIN MUTUAL FUNDS IN THE NTF PROGRAM IN EXCHANGE FOR THE FIRM PERFORMING CERTAIN ADMINISTRATIVE SERVICES ON CLEARING FIRM'S BEHALF. THE SEC ALLEGED THAT THESE PAYMENTS CREATED A CONFLICT OF INTEREST IN THAT THEY PROVIDED A FINANCIAL INCENTIVE FOR THE FIRM TO FAVOR THE MUTUAL FUNDS IN THE NTF PROGRAM OVER OTHER INVESTMENTS WHEN GIVING INVESTMENT ADVICE TO ITS ADVISORY CLIENTS. THE SEC ALLEGED THAT THE FIRM DID NOT DISCLOSE THE AFOREMENTIONED ARRANGEMENTS OR THE RESULTING CONFLICT OF INTEREST TO ITS ADVISORY CLIENTS, RESULTING IN A VIOLATION OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. THE SEC ALSO ALLEGED THAT BY NOT ADEQUATELY IMPLEMENTING POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE PROPER DISCLOSURE OF CONFLICTS OF INTERESTS, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Status: Final Sanction Detail: THE FIRM AGREED TO A CENSURE AND DISGORGEMENT OF $2,621,324 AND PREJUDGMENT INTEREST OF $174,629.78 AND A CIVIL MONETARY PENALTY OF $300,000. Summary: THE FIRM AGREED TO COMPLY WITH THE FOLLOWING UNDERTAKINGS: THE FIRM WILL PROVIDE A COPY OF THE ORDER TO EACH OF THE FIRM'S EXISTING ADVISORY CLIENTS WITHIN FORTY-FIVE DAYS OF THE ENTRY OF THE ORDER AND FURTHER COMPLY WITH ALL DISCLOSURE OBLIGATIONS CONCERNING THE ORDER UNDER THE ADVISERS ACT. THE FIRM WILL CERTIFY ITS COMPLIANCE WITH THE PREVIOUS UNDERTAKING NO LATER THAN SIXTY DAYS FROM THE COMPLETION OF THE UNDERTAKING.

Allegations: SEC ADMIN RELEASE 34-84288; IA RELEASE 40-5048, SEPTEMBER 26, 2018: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST VOYA FINANCIAL ADVISORS, INC. ("VFA" OR "RESPONDENT"). THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF VFA'S FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION S-P (THE "SAFEGUARDS RULE"), AND VFA'S FAILURE TO DEVELOP AND IMPLEMENT A WRITTEN IDENTITY THEFT PREVENTION PROGRAM AS REQUIRED BY RULE 201 OF REGULATION S-ID (THE "IDENTITY THEFT RED FLAGS RULE"). FROM AT LEAST 2013 THROUGH OCTOBER 2017 (THE "RELEVANT PERIOD"), VFA GAVE ITS INDEPENDENT CONTRACTOR REPRESENTATIVES ("CONTRACTOR REPRESENTATIVES") ACCESS TO ITS BROKERAGE CUSTOMER AND ADVISORY CLIENT (HEREINAFTER, "CUSTOMER") INFORMATION THROUGH A PROPRIETARY WEB PORTAL. THROUGH THE PORTAL, THE CONTRACTOR REPRESENTATIVES ACCESSED THE PERSONALLY IDENTIFIABLE INFORMATION ("PII") OF VFA CUSTOMERS AND MANAGED THE CUSTOMERS' BROKERAGE ACCOUNTS. THE PORTAL WAS SERVICED AND MAINTAINED BY VFA'S PARENT COMPANY, VOYA FINANCIAL, INC. ("VOYA"). OVER SIX DAYS IN APRIL 2016, ONE OR MORE PERSONS IMPERSONATING VFA CONTRACTOR REPRESENTATIVES CALLED VFA'S TECHNICAL SUPPORT LINE AND REQUESTED A RESET OF THREE REPRESENTATIVES' PASSWORDS FOR THE WEB PORTAL USED TO ACCESS VFA CUSTOMER INFORMATION, IN TWO INSTANCES USING PHONE NUMBERS VOYA HAD PREVIOUSLY IDENTIFIED AS ASSOCIATED WITH PRIOR FRAUDULENT ACTIVITY. ALTHOUGH VFA TOOK CERTAIN STEPS TO RESPOND TO THE INTRUSION, THOSE STEPS DID NOT PREVENT THE INTRUDERS FROM OBTAINING PASSWORDS AND GAINING ACCESS TO VFA'S PORTAL BY IMPERSONATING TWO ADDITIONAL REPRESENTATIVES OVER THE NEXT SEVERAL DAYS. NOR DID VFA TERMINATE THE INTRUDERS' ACCESS TO THE THREE REPRESENTATIVES' ACCOUNTS DUE TO DEFICIENT CYBERSECURITY CONTROLS AND AN ERRONEOUS UNDERSTANDING OF THE OPERATION OF THE PORTAL. THE INTRUDERS USED THE VFA CONTRACTOR REPRESENTATIVES' USERNAMES AND PASSWORDS TO LOG IN TO THE PORTAL AND GAIN ACCESS TO PII FOR AT LEAST 5,600 OF VFA'S CUSTOMERS, AND SUBSEQUENTLY TO OBTAIN ACCOUNT DOCUMENTS CONTAINING PII OF AT LEAST ONE VOYA CUSTOMER. THE INTRUDERS ALSO USED CUSTOMER INFORMATION TO CREATE NEW VOYA.COM CUSTOMER PROFILES, WHICH GAVE THEM ACCESS TO PII AND ACCOUNT INFORMATION OF TWO ADDITIONAL CUSTOMERS. THERE HAVE BEEN NO KNOWN UNAUTHORIZED TRANSFERS OF FUNDS OR SECURITIES FROM VFA CUSTOMER ACCOUNTS AS A RESULT OF THE ATTACK. VFA VIOLATED THE SAFEGUARDS RULE BECAUSE ITS POLICIES AND PROCEDURES TO PROTECT CUSTOMER INFORMATION AND TO PREVENT AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES. AMONG OTHER THINGS, VFA'S POLICIES AND PROCEDURES WITH RESPECT TO RESETTING VFA CONTRACTOR REPRESENTATIVES' PASSWORDS, TERMINATING WEB SESSIONS IN ITS PROPRIETARY GATEWAY SYSTEM FOR VFA CONTRACTOR REPRESENTATIVES, IDENTIFYING HIGHER-RISK REPRESENTATIVES AND CUSTOMER ACCOUNTS FOR ADDITIONAL SECURITY MEASURES, AND CREATION AND ALTERATION OF VOYA.COM CUSTOMER PROFILES, WERE NOT REASONABLY DESIGNED. IN ADDITION, A NUMBER OF VFA'S CYBERSECURITY POLICIES AND PROCEDURES WERE NOT REASONABLY DESIGNED TO BE APPLIED TO ITS CONTRACTOR REPRESENTATIVES. ALTHOUGH VFA ADOPTED A WRITTEN IDENTITY THEFT PREVENTION PROGRAM IN 2009, VFA VIOLATED THE IDENTITY THEFT RED FLAGS RULE BECAUSE IT DID NOT REVIEW AND UPDATE THE IDENTITY THEFT PREVENTION PROGRAM IN RESPONSE TO CHANGES IN RISKS TO ITS CUSTOMERS OR PROVIDE ADEQUATE TRAINING TO ITS EMPLOYEES. IN ADDITION, THE IDENTITY THEFT PREVENTION PROGRAM DID NOT INCLUDE REASONABLE POLICIES AND PROCEDURES TO RESPOND TO IDENTITY THEFT RED FLAGS, SUCH AS THOSE THAT WERE DETECTED BY VFA DURING THE APRIL 2016 INTRUSION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, THE FIRM WAS CENSURED, FINED $1,000,000 , ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION S-P (17 C.F.R.§248.30(A))AND OF RULE 201 OF REGULATION S-ID (17 C.F.R. § 248.201). Summary: THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS ("ORDER"), A CENSURE, AND CIVIL MONEY PENALTY IN THE AMOUNT OF $1,000,000. THE FIRM AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FUTURE VIOLATIONS OF RULE 30(A) OR REGULATION S-P AND OF RULE 201 OF REGULATION S-ID. THE FIRM FURTHER AGREED TO COMPLY WITH THE FOLLOWING UNDERTAKINGS. THE FIRM SHALL RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT ("CONSULTANT") TO CONDUCT A COMPREHENSIVE REVIEW OF THE FIRM'S POLICIES AND PROCEDURES FOR COMPLIANCE WITH REGULATION S-P AND REGULATION S-ID. THE FIRM WILL FULLY COOPERATE WITH THE CONSULTANT, AND REQUIRE THE CONSULTANT SUBMIT A WRITTEN INITIAL REPORT TO THE FIRM AND THE SEC WITHIN NINETY DAYS OF THIS ORDER. THE FIRM AGREES TO ADOPT THE RECOMMENDATIONS FROM THE INITIAL REPORT, SUBJECT TO ADOPTION OF ALTERNATIVE POLICIES, PROCEDURES, OR SYSTEMS, WITHIN 90 DAYS OF ITS ISSUANCE. THE CONSULTANT SHALL COMPLETE ITS REVIEW AND ISSUE A WRITTEN FINAL REPORT WITHIN NINE MONTHS OF THE ORDER, AND THE FIRM SHALL TAKE NECESSARY AND APPROPRIATE STEPS TO IMPLEMENT ALL RECOMMENDATIONS AND ALTERNATIVE POLICIES, PROCEDURES OR SYSTEMS. THE FIRM WILL CERTIFY ITS COMPLIANCE WITH EACH OF THE PREVIOUS UNDERTAKINGS. THE ORDER WAS EXECUTED ON SEPTEMBER 26, 2018.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. (FIRM) FAILED TO (A) IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY OF ITS MULTI-SHARE CLASS VARIABLE ANNUITIES SOLD TO CUSTOMERS, (B) IDENTIFY AND INVESTIGATE RED FLAGS IN VARIABLE ANNUITY SALES, (C) SUPERVISE VARIABLE ANNUITY SALES, AND (D) IMPLEMENT AN ADEQUATE SUPERVISORY SYSTEM AND PROCEDURES FOR VARIABLE ANNUITY EXCHANGE TRANSACTIONS. THE FIRM'S FAILURES INCLUDED, BUT WERE NOT LIMITED TO SUPERVISION AND OVERSIGHT, AND THE MAINTENANCE OF POLICIES AND PROCEDURES REGARDING THE SALE OF L-SHARE VARIABLE ANNUITIES WITH LONG-TERM INCOME RIDERS AND NO PERSISTENCY CREDITS TO INVESTORS WITH LONG-TERM TIME HORIZONS. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS, THE FIRM ACCEPTED AND CONSENTED TO THE ENTRY OF FINDINGS AND THE SANCTIONS DESCRIBED BELOW BY AGREEING TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) THAT WAS ACCEPTED BY FINRA ON NOVEMBER 2, 2016. THE AWC INCLUDED A FIRM CENSURE AND FINE IN THE AMOUNT OF $2,750,000. THE FIRM AGREED TO PAY RESTITUTION TO CUSTOMERS IN ACCORDANCE WITH A PLAN NOT UNACCEPTABLE TO FINRA IN AN AMOUNT THAT WILL TOTAL NOT LESS THAN $1,800,000. THE FIRM ADDITIONALLY AGREED TO REVIEW AND REVISE, AS NECESSARY, ITS SYSTEMS, POLICIES AND PROCEDURES AND TRAINING WITH RESPECT TO MULTI-SHARE CLASS VARIABLE ANNUITY SALES. THE FIRM WILL CERTIFY TO FINRA THAT IT HAS ESTABLISHED POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FINRA AND NASD RULES.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT VOYA FINANCIAL ADVISORS, INC. (FIRM) FAILED TO REPORT TO TRACE 100 TRANSACTIONS IN TRACE AGENCY/SECURITIZED PRODUCTS (SP) WITHIN THE TIME PERMITTED BY FINRA RULE 6730, CONSTITUTING 26.25 PERCENT OF THE TRANSACTIONS IN TRACE-ELIGIBLE SP (381) THAT THE FIRM REPORTED TO TRACE DURING THE FOURTH QUARTER OF 2015. THIS CONDUCT CONSTITUTED SEPARATE AND DISTINCT VIOLATIONS OF FINRA RULE 6730(A) AND A PATTERN OR PRACTICE OF LATE REPORTING WITHOUT EXCEPTIONAL CIRCUMSTANCES IN VIOLATION OF FINRA RULE 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING FINRA'S FINDINGS, THE FIRM ACCEPTED AND CONSENTED TO THE DESCRIBED FINDINGS AND TO THE ENTRY OF A CENSURE AND FINE IN THE AMOUNT OF $7,500 BY AGREEING TO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA. FINRA ACCEPTED THE AWC ON MARCH 1, 2017.

Allegations: THE FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) ALLEGED THAT BETWEEN MARCH 2018 AND SEPTEMBER 2019, VOYA FINANCIAL ADVISORS, INC. (FIRM) PAID APPROXIMATELY $2.9 MILION TO AN UNREGISTERED ENTTIY IN CONNECTION WITH THE SALE OF VARIABLE UNIVERSAL LIFE INSURANCE (VUL), A SECURITIES PRODUCT. THE FIRM AND THE UNREGISTERED ENTITY WERE PARTIES TO A VARIABLE MARKETING AGREEMENT, WHICH PROVIDED THAT THE UNREGISTERED ENTITY WOULD PROVIDE A VARIETY OF SERVICES TO FACILITATE VUL SALES, INCLUDING DISTRIBUTING SALES MATERIALS AND ASSISTING WITH SALES PROMOTIONAL ACTIVITIES. FINRA ALLEGED THAT THESE PAYMENTS RESULTED IN THE FIRM VIOLATING FINRA RULE 2040 AND FINRA RULE 2010. Status: Final Sanction Detail: THE FIRM CONSENTED TO THE ENTRY OF A CENSURE AND TO PAY A FINE IN THE AMOUNT OF $500,000. THE FIRM PAID THIS FINE ON 1/30/2024. Summary: WITHOUT ADMITTING OR DENYING THESE FINDINGS, THE FIRM ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER AND CONSENT (AWC) WITH FINRA. THE FIRM FURTHER AGREED TO PAY THE MONETORY SANCTION OF $500,000 AT THE TIME THE AWC WAS ACCEPTED. FINRA ACCEPTED THE AWC ON JANUARY 25, 2024.

Allegations: THE FIRM ENTERED INTO A CONSENT ORDER WITH THE NEW JERSEY BUREAU OF SECURITIES ON DECEMBER 13, 2011 THAT IT FAILED TO FOLLOW ITS PROCEDURES, OR THAT ITS PROCEDURES WERE INADEQUATE, WITH RESPECT TO DETECTING PRIOR UNDISCLOSED EMPLOYMENT DISCIPLINARY ISSUES, CUSTOMER FUND DISBURSEMENT PROCEDURES, AND TRADE REVIEW PROCEDURES. AS A RESULT OF THIS NEW JERSEY MATTER, THE MINNESOTA DEPARTMENT OF COMMERCE STATED THAT SUCH CONDUCT IN NEW JERSEY WOULD BE A VIOLATION OF MINNESOTA STATUES 80A.67 (D)(9) AND SUBJECT TO DISCIPLINARY ACTION. Status: Final Sanction Detail: THE FIRM AGREED TO RESOLVE THIS MATTER WITH THE MINNESOTA DEPARTMENT OF COMMERCE BY PAYMENT OF A $5,000 CIVIL PENALTY AND ACKNOWLEDGMENT OF THE FINDINGS OF FACT AND CONCLUSIONS OF LAW AS SET FORTH IN THE CONSENT ORDER ISSUED BY THE NEW JERSEY BUREAU OF SECURITIES.

Allegations: THE COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION (THE "DIVISION") ALLEGED THAT THE FIRM VIOLATED SECTION 204(A)(2)(J) OF THE MASSACHUSETTS UNIFORM SECURITIES ACT BY FAILING TO INCLUDE SPECIFIC POLICIES REGARDING VOTING SHAREHOLDER PROXIES IN ITS WRITTEN SUPERVISORY PROCEDURES OR OTHER MANUALS. Status: Final Sanction Detail: THE COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION (THE "DIVISION") ALLEGED THAT THE FIRM VIOLATED SECTION 204(A)(2)(J) OF THE MASSACHUSETTS UNIFORM SECURITIES ACT BY FAILING TO INCLUDE SPECIFIC POLICIES REGARDING VOTING SHAREHOLDER PROXIES IN ITS WRITTEN SUPERVISORY PROCEDURES OR OTHER MANUALS. THE DIVISION FOUND THAT TWO FIRM REPRESENTATIVES VOTED SHAREHOLDER PROXIES ON BEHALF OF CUSTOMERS DESPITE VFA'S POSITION THAT IT DOES NOT PERMIT REGISTERED REPRESENTATIVES TO VOTE SHAREHOLDER PROXIES ON BEHALF OF CUSTOMERS. VFA ENTERED INTO A CONSENT ORDER WITH THE DIVISION ON JUNE 22, 2016. VFA ADMITTED THE DIVISION'S STATEMENT OF FACTS BUT NEITHER ADMITTED NOR DENIED THE VIOLATIONS OF LAW CONTAINED THEREIN. VFA WAS CENSURED AND PAID AN ADMINISTRATIVE FINE OF $100,000.00 TO THE COMMONWEALTH OF MASSACHUSETTS. VFA WAS ALSO REQUIRED TO CERTIFY THAT IT HAD REVIEWED ITS WRITTEN SUPERVISORY POLICIES AND PROCEDURES WITH RESPECT TO BROKER-DEALER REPRESENTATIVE PROXY VOTING. VFA AGREED TO REPORT TO THE DIVISION WITHIN THIRTY (30) DAYS OF THE CONSENT ORDER REGARDING THE STEPS TAKEN BY VFA DURING ITS REVIEW, ALONG WITH CONCLUSIONS AND RECOMMENDATIONS RESULTING FROM THE REVIEW.

Allegations: THE ARIZONA CORPORATION COMMISSION, SECURITIES DIVISION ALLEGED THAT VFA VIOLATED ARIZONA REVISED STATUTES SECTION 44-1961(A)(12) BY FAILING TO REASONABLY SUPERVISE ITS SALESMAN. THE SALESMAN, AN EMPLOYEE OF VFA, CONDUCTED BACK-OFFICE TRANSACTIONS IN SECURITIES ON BEHALF OF PORTFOLIO MANAGERS. IN 2019, THE EMPLOYEE MOVED FROM IOWA, WHERE HE MAINTAINED REGISTRATION AS A BROKER-DEALER AGENT AND INVESTMENT ADVISER REPRESENTATIVE, TO ARIZONA. THE EMPLOYEE NOTIFIED VFA WHEN HE MOVED TO ARIZONA, AND VFA UPDATED HIS ADDRESS BY FILING AN AMENDED FORM U-4. INADVERTENTLY AND CONTRARY TO VFA'S INTERNAL POLICIES, VFA FAILED TO SELECT ARIZONA AS AN ADDITIONAL JURISDICTION IN WHICH TO SEEK REGISTRATION. THE EMPLOYEE PERFORMED HIS JOB DUTIES AS A BACK-OFFICE TRADE PROCESSOR AND FACILITATED THE EXECUTION OF SECURITIES ORDERS WITHIN OR FROM ARIZONA FROM JUNE 2019 UNTIL MAY 2024. Status: Final Sanction Detail: ADMINISTRATIVE PENALTY OF $75,000 PAID ON SEPTEMBER 16, 2024.

Allegations: VOYA FINANCIAL ADVISORS, INC. ("FIRM") HAS SUBMITTED AN OFFER OF SETTLEMENT THAT THE SECURITIES AND EXCHANGE COMMISSION ("SEC") HAS AGREED TO ACCEPT. THE FIRM AGREES, WITHOUT ADMITTING OR DENYING SUCH FINDINGS, THAT IT VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO DISCLOSE CONFLICTS OF INTEREST ASSOCIATED WITH (A) THE FIRM'S MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FINANCIAL BENEFITS IT RECEIVED FOR ADVISING CLIENTS TO PURCHASE AND HOLD MUTUAL FUND SHARE CLASSES THAT CHARGED FEES PURSUANT TO INVESTMENT COMPANY ACT RULE 12B-1; (B) THE FIRM'S RECEIPT OF COMPENSATION IN CONNECTION WITH CERTAIN CASH SWEEP OPTIONS; AND (C) THE FIRM'S POLICY REQUIRING ADVISORY CLIENTS TO PAY AN UPFRONT BROKERAGE COMMISSION WHEN PURCHASING ILLIQUID ALTERNATIVE INVESTMENT PRODUCTS WHEN THE SAME INVESTMENT WAS AVAILABLE TO ADVISORY CLIENTS WITH THE BROKERAGE COMMISSIONS WAIVED. Status: Final Sanction Detail: THE FIRM CONSENTED TO PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY TOTALING $22,919,155 Summary: WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, AND SOLELY FOR THE PURPOSE OF SETTLING THIS PROCEEDING, THE FIRM CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS (THE "ORDER"), A CENSURE, TO PAY TO AFFECTED INVESTORS DISGORGEMENT OF $11,547,820 AND PREJUDGMENT INTEREST OF $2,371,335, AND TO PAY A $9 MILLION CIVIL MONETARY PENALTY. THE FIRM AGREED TO COMPLY WITH THE FOLLOWING UNDERTAKINGS: NOTIFY AFFECTED INVESTMENT ADVISORY CLIENTS WITHIN 30 DAYS OF THE ORDER, RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT WITHIN 30 DAYS OF THE ORDER TO CONDUCT A REVIEW OF THE FIRM'S COMPENSATION RECEIPT AND DISCLOSURE PRACTICES WITH RESPECT TO ADVISORY CLIENT INVESTMENTS, AND ADOPT ALL OF RECOMMENDATIONS CONTAINED IN THE INDEPENDENT COMPLIANCE CONSULTANT'S REPORTS. THE FIRM WILL CERTIFY ITS COMPLIANCE WITH THE PREVIOUS UNDERTAKINGS NO LATER THAN SIXTY DAYS FROM THE COMPLETION OF THE UNDERTAKING. THE ORDER WAS EXECUTED ON DECEMBER 21, 2020.