St. Bernard Financial Services, Inc.

Allegations: DURING NASD EXAM THE EXAMINER FELT THAT THERE WAS A POTENTIAL OF A LIEN AGAINST ST BERNARD'S NET CAPITAL, WHICH WOULD CAUSE US TO BE UNDERCAPITALIZED. NO LIEN EXISTED, BUT THERE WAS A POTENTIAL FOR ONE. Status: Final Sanction Detail: FINE OF $2500 AGAINST PAID 6/03/2003. Summary: SENT PENALTY MONEY IN 06/03/2003

Allegations: FIRM ALLOWED NET CAPITAL TO FALL BELOW MINIMUMS DUE TO AN ACCOUNTING ERROR Status: Final Sanction Detail: THROUGH AN ACCOUNTING ERROR, ST BERNARD ALLOWED ITS NET CAPITAL TO FALL BELOW MINIMUMS FOR MONTHS ENDING 01/05, 02/05, 03/05, 04/05, 12/05, 01/06, 02/06, 03/06, 04/06, AND 05/06. Summary: FIRM AND ROBERT KEENAN, FINOP WERE FINED $5,000 JOINTLY

Allegations: FAILED TO PROPERLY DISCLOSE REGULATORY HISTORY OF A PERSON IN ANOTHER STATE THAT WAS NOT REGISTERING IN TENNESSEE. Status: Final Sanction Detail: REGISTRATION APPLICATION AS AN INVESTMENT ADVISORY FIRM IN TENNESSEE WAS DENIED. Summary: THE PERSON IN QUESTION LIVES AND WORKS IN TEXAS AND WAS NOT REGISTERING IN TENNESSEE. THE DISCIPLINARY HISTORY WAS PROPERLY DISCLOSED ON FORM U-4. TENNESSEE HAD IT IN THEIR HEAD THAT HE NEEDED TO BE LISTED NOT ONLY AS AN EMPLOYEE BUT ALSO AS A CONTROL PERSON. HE DOES NOT MET THE DEFINITION OF EITHER IN THE INSTRUCTIONS TO FORM ADV. WHEN WE ASKED THE SEC ABOUT THIS, THEY SAID A STATE CAN DO WHATEVER THEY WANT. IN RETROSPECT WE SHOULD HAVE JUST WITHDRAWN THE APPLICATION.

Allegations: FAILED TO MAKE CERTAIN DISCLOSURES. Status: Final Sanction Detail: DENIED THE FIRM'S APPLICATION FOR REGISTRATION. Summary: WHEN APPLYING FOR REGISTRATION AS AN INVESTMENT ADVISORY FIRM, THE STATE OF TENNESSEE REQUIRED US TO LIST AN ASSOCIATED PERSON LOCATED IN TEXAS, WHO WAS NOT REGISTERED IN TENNESSEE, AS A CONTROL PERSON AND AN EMPLOYEE. THE ASSOCIATED PERSON IS JUST A COMMISSION BASED REP AND DOES NO ADVISORY WORK, AND DOES NOT MEET THE DEFINITION OF A CONTROL PERSON NOR AN EMPLOYEE PER THE INSTRUCTIONS ON FORM ADV. WE REFUSED DUE TO LEGAL CONCERNS. THE STATE OF TENNESSEE THEN DENIED OUR APPLICATION. THE SEC SAID A STATE CAN DO WHATEVER THEY WANT, IRREGARDLESS OF WHAT THE DEFINITIONS ARE IN THE INSTRUCTIONS TO FORM ADV. IN RETROSPECT, WE SHOULD HAVE JUST WITHDRAWN THE APPLICATION.

Allegations: NEELY TRADED IN THE ACCOUNT OF TWO CUSTOMERS WITHOUT HAVING WRITTEN PERMISSION. HE DID HAVE VERBAL PERMISSION. Status: Final Sanction Detail: ONE MONTH SUSPENSION STARTING 11/19/2018 Summary: NEELY WAS EXECUTING TRADES FOR CLIENTS IN THEIR ACCOUNTS WITHOUT WRITTEN PERMISSION. HE HAD VERBAL PERMISSION TO EXERCISE DISCRETION BUT NOT WRITTEN PERMISSION

Allegations: FIRM FAILED TO HAVE ADEQUATE SUPERVISORY PROCEDURES IN PLACE PRIOR TO 2012 TO DETECT AN ADVISOR'S USE OF AN OUTSIDE EMAIL ACCOUNT. Status: Final Sanction Detail: FIRM HAD A REGISTERED REP USING AN OUTSIDE EMAIL ACCOUNT THAT HE HID THE USE OF FROM THE FIRM. HIS ANNUAL ATTESTATIONS CERTIFIED THAT HE WAS NOT USING ANY OUTSIDE EMAIL ACCOUNTS. Summary: FIRM TERMINATED THE REP AND PAID A FINE OF $25,000

Allegations: ST BERNARD FAILED TO HAVE ADEQUATE EMAIL SUPERVISION PROCEDURES PRIOR TO 2012. THIS WAS ABOUT A REP USING A PERSONAL EMAIL ACCOUNT THAT THE FIRM DID NOT DETECT. THE FIRM CHANGED THEIR EMAIL SUPERVISION PROCEDURES Status: Final Sanction Detail: ST BERNARD PAID A PENALTY OF $25,000 FOR HAVING INADEQUATE POLICIES IN PLACE PRIOR TO 2012 TO DETECT AND MONITOR THE USE OF OUTSIDE EMAIL SYSTEMS. Summary: IT WAS CHEAPER FOR ST BERNARD TO PAY THE FINE THAN TO FIGHT THE ALLEGATIONS.

Allegations: FOUR INVESTMENT ADVISOR REPS WERE UNREGISTERED IN ARKANSAS DURING 2008 AND 2009 DUE TO A FAILURE OF THE REGISTRATION COORDINATOR TO PROPERLY UPDATE REGISTRATIONS. BEING UNREGISTERED AND CONDUCTING BUSINESS IS A VIOLATION OF THE ARKANSAS SECURITIES ACT Status: Final Sanction Detail: FIRM PAID A $6500 FINE AND SIGNED A CONSENT ORDER. THE FOUR AFFECTED REPS SIGNED A CONSENT ORDER. Summary: OUR REGISTRATION COORDINATOR INADVERTENTLY DELETED THE FIRM'S IA REGISTRATION IN ARKANSAS DURING 2007. THIS CAUSED FOUR OF OUR IA REPS TO BE UNREGISTERED FOR ALL OF 2008 AND 2009.

Allegations: WHEN RENEWING THE FIRM'S INSURANCE LICENSE THE REGISTRATION COORDINATOR ANSWERED A QUESTION WRONG ON AN APPLICATION. Status: Final Sanction Detail: FIRM ANSWERED A QUESTION WRONG ON A RENEWAL APPLICATION. FIRM WAS FINED FOR THAT Summary: WHEN RENEWING THE FIRM'S INSURANCE LICENSE THE REGISTRATION COORDINATOR ANSWERED A QUESTION WRONG ON AN APPLICATION. THE FIRM WAS FINED $250 FOR THAT

Allegations: PROVIDED INCORRECT, OR MISLEADING, OR INCOMPLETE, OR FALSE INFORMATION, IN AN INSURANCE LICENSING RENEWAL. Status: Final Sanction Detail: NONE Summary: WHEN RENEWING OUR INSURANCE LICENSE, WE MISREAD ONE OF THE QUESTIONS RELATING TO PAST SANCTIONS. WE READ THE QUESTION AS "HAS ANY INSURANCE REGULATOR SANCTIONED YOU?", THE CORRECT ANSWER BEING "NO". THE LOUISIANA INSURANCE DEPT MEANT ANY REGULATOR, INCLUDING FINRA. THEREFORE WE ANSWERED THE QUESTION IN AN INCOMPLETE WAY AND WAS FINED $250.