Cascade Investment Group, Inc.

Allegations: CASCADE INVESTMENT GROUP, INC. (FORMERLY BJR & ASSOCIATES, INC.) VIOLATED THE NET CAPITAL REQUIREMENT. Status: Final Sanction Detail: CASCADE INVESTMENT GROUP, INC. FORMERLY BJR & ASSOCIATES, INC. WAS FINED $2,500.00. Summary: DURING THE MONTH OF SEPTEMBER 1996. BJR & ASSOCIATES INCURRED NON-RECURRING EXPENSES ASSOCIATED WITH THE EXPANSION OF BOTH OUR DENVER OFFICE AND COLORADO SPRINGS OFFICE THAT RESULTED IN A NEGATIVE NET CAPITAL POSITION AT THE END OF SEPTEMBER. ON OCTOBER 4, 1996, KEIRA RAWLINGS, THE COMPANY'S FINANCIAL PRINCIPAL, NOTIFIED THE SEC AND NASD OF THIS CONDITION. SHORTLY THEREAFTER, A CAPITAL INFUSION WAS MADE TO BRING THE COMPANY UP TO QUALIFY AS A $50,000 BD AND WE HAVE CONTINUED TO IMPROVE SINCE.

Allegations: BREACH OF FIDUCIARY DUTY AND DUTY TO SEEK BEST EXECUTION IN CONNECTION WITH SHARE CLASS SELECTION PRACTICES. CASCADE RECOMMENDED POSITIONS CHARGING 12B-1 FEES INSTEAD OF THE LOWER COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO CLIENTS. THE FIRM AND ITS REPRESENTATIVES RECEIVED THESE 12B-1 FEES AND FAILED TO DISCLOSE THE CONFLICT THIS CREATED TO FIRM CLIENTS. Status: Final Sanction Detail: FINE OF $125,000 WAS PAID ON JULY 16, 2021. Summary: THE FINE WAS PAID WITHIN 10 DAYS OF THE ISSUE DATE OF THE SANCTION. CASCADE NO LONGER RECOMMENDS PURCHASES OF POSITIONS CHARGING 12B-1 FEES IN CLIENT ADVISORY ACCOUNTS. ANY REMAINING POSITIONS CHARGING 12B-1 FEES WILL HAVE THOSE FEES REBATED BACK TO THE CLIENT ACCOUNTS.