Sevenoneseven Capital Management, Ltd

Allegations: THE COMPLAINT ALLEGES THAT AMBASSADOR ADVISORS, LLC AND ITS PRINCIPALS WERE NEGLIGENT BECAUSE THEY DID NOT ADEQUATELY DISCLOSE A CONFLICT OF INTEREST, PROVIDE BEST EXECUTION, OR HAVE WRITTEN POLICIES OR PROCEDURES, IN CONNECTION WITH THE SELECTION OF MUTUAL FUNDS THAT PAID 12B-1 FEES. THE ALLEGED CLAIMS WERE MADE UNDER SECTION 206(2), SECTION 206(4) AND RULE 206(4)-7 OF THE INVESTMENT ADVISERS ACT OF 1940. Status: Final Summary: ON DECEMBER 20, 2021, THE ADVISORY FIRM WAS FOUND TO BE IN VIOLATION OF SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, WHICH REQUIRED THE FIRM TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATION OF THE ADVISERS ACT BY IT AND ITS SUPERVISED PERSONS. ON MARCH 23, 2022, REGISTRANT WAS FOUND TO HAVE VIOLATED SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940.

Allegations: THE COMPLAINT ALLEGES THAT AMBASSADOR ADVISORS, LLC AND ITS PRINCIPALS WERE NEGLIGENT BECAUSE THEY DID NOT ADEQUATELY DISCLOSE A CONFLICT OF INTEREST, PROVIDE BEST EXECUTION, OR HAVE WRITTEN POLICIES OR PROCEDURES, IN CONNECTION WITH THE SELECTION OF MUTUAL FUNDS THAT PAID 12B-1 FEES. THE ALLEGED CLAIMS WERE MADE UNDER SECTION 206(2), SECTION 206(4) AND RULE 206(4)-7 OF THE INVESTMENT ADVISERS ACT OF 1940. Status: Final Sanction Detail: ON SEPTEMBER 7, 2022, THE COURT ENTERED FINAL JUDGMENTS AGAINST AMBASSADOR AND ITS PRINCIPALS. THE JUDGMENTS ORDERED: (1)MR. BOSTWICK TO PAY $136,620 IN DISGORGEMENT, $35,273 IN PREJUDGMENT INTEREST, AND A $136,620 CIVIL PENALTY; (2) MR. KAUFFMAN TO PAY $349,395 IN DISGORGEMENT, $95,972 IN PREJUDGMENT INTEREST, AND A $349,395 CIVIL PENALTY; (3) MR. YOUNG TO PAY $136,627 IN DISGORGEMENT, $35,275 IN PREJUDGMENT INTEREST, AND A $136,627 CIVIL PENALTY; AND (4) AMBASSADOR TO PAY A $622,642 CIVIL PENALTY. IN ADDITION, THE JUDGMENTS ORDERED AMBASSADOR AND ITS PRINCIPALS TO CORRECT AND REMOVE MISLEADING STATEMENTS FROM THE FIRM'S WEBSITE AND FORM ADV MATERIALS, AS WELL AS TO SEND A CORRECTIVE NOTICE ABOUT THE CASE TO THE FIRM'S ADVISORY CLIENTS Summary: ON DECEMBER 20, 2021, THE ADVISORY FIRM WAS FOUND TO BE IN VIOLATION OF SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, WHICH REQUIRED THE FIRM TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATION OF THE ADVISERS ACT BY IT AND ITS SUPERVISED PERSONS. ON MARCH 23, 2022, REGISTRANT WAS FOUND TO HAVE VIOLATED SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940.