Northland Securities, Inc.

Allegations: NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM Status: Final Sanction Detail: $10,000 PAID IN FULL ON 1/7/2007

Allegations: NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS. Status: Final Sanction Detail: $5,000 FINE

Allegations: THE FIRM WAS CITED FOR VARIOUS TRADE REPORTING VIOLATIONS DUE TO INCORRECT TRADE INDICATORS AND FAILURE TO DISCLOSE TRADE CAPACITY AND MARKET MAKER STATUS ON CUSTOMER CONFIRMATIONS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WERE ALSO FOUND TO BE INADEQUATE. Status: Final Sanction Detail: FINE WAS PAID BY APPLICANT VIA CHECK ON JULY 19,2010 Summary: THE FIRM FOUND THAT MOST OF THE TRADE REPORTING VIOLATIONS WERE DUE TO MISUNDERSTANDING OF HOW THE SYSTEM WAS REPORTING TRADES AND ALSO THE REPORTS PROVIDED WERE NOT GOOD INDICATORS OF REPORTING PROBLEMS. THE FIRM HAS CORRECTED SYSTEM ISSUES AND HAVE SUBSCRIBED TO NASDAQ'S SYSTEM IN ORDER TO TRACK REPORTS IN REAL TIME. THE WRITTEN SUPERVISORY PROCEDURES WERE UPDATED AND PROVIDED TO FINRA FOR REVIEW AND WERE FOUND TO BE SATISFACTORY.

Allegations: THE FIRM FAILED TO CORRECTLY INDICATE WHETHER ORDERS WERE A BUY, SHORT SALE OR LONG SALE WHICH ARE VIOLATIONS OF NASDAQ RULE 4755. Status: Final Sanction Detail: APPLICANT WILL PAY THE FINE VIA CHECK AS SOON AS INVOICE IS RECEIVED FROM NASDAQ IN AUGUST 2010. Summary: THE FIRM CORRECTED SYSTEM ISSUES AND UPDATED AND SUBSRIBED TO NASDAQ'S SERVICE TO BETTER MONITOR REPORTING, AS WELL AS, UPDATING WRITTEN SUPERVISORY PROCEDURES.

Allegations: NASD RULE 606 NORTHLAND FAILED TO MAKE PUBLICLY AVAILABLE FOR THE 4TH CALENDAR QUARTER OF 2004 THROUGH THE THIRD CALENDAR QUARTER OF 2005 A COMPLETE REPORT ON ITS ROUTING OF NON-DIRECTED ORDERS IN COVERED SECURITEIS DURING THOSE QUARTERS. Status: Final Sanction Detail: $5,000 FINE Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM WAS FINED $5000.00 WHICH WAS PAID ON OR ABOUT 3/20/2007.

Allegations: NORTHLAND TRANSFERRED INVESTOR FUNDS FOR PRIVATE PLACEMENT OFFERINGS TO AN ESCROW ACCOUNT UNDER THE CONTROL OF AFFILATED COMPANY NORTHLAND TRUST SERVICES. NORTHLAND RELEASED INVESTOR FUNDS PRIOR TO CONTINGENCY BEING MET WITH BONA FIDE INVESTORS, AS DIRECTORS OR OFFICERS PARTICIPATED IN OFFERING AND THIS DISCLOSURE WAS NOT INCLUDED IN THE PPM Status: Final Sanction Detail: $10,000 PAID IN FULL ON 1/7/2007 Summary: WITHOUT OR ADMITTING OR DENYING THE FINDS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM ACCEPTED THE FINE OF $10000.00 WHICH WAS PAID IN FULL ON 1/7/2007.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 57 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BZX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BZX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BZX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE. Status: Final Sanction Detail: THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES. Summary: THE FIRM WAS CENSURED, FINED $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BZX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BZX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BZX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED ON 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REGISTER ONE ASSOCIATED PERSON AS BOTH A SERIES 7 GENERAL SECURITIES REPRESENTATIVE AND SERIES 24 GENERAL SECURITIES PRINCIPAL WITH BYX. THE SAME ASSOCIATED PERSON WAS ALSO NOT QUALIFIED OR REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX EVEN THOUGH THE PERSON HAD RESPONSIBILITY OVER SECURITIES TRADING ACTIVITIES ON BYX. ALTHOUGH THE PERSON HAD PASSED THE SERIES 24 EXAMINATION, THE PERSON HAD NOT PASSED THE SERIES 57 PREREQUISITE EXAMINATION. THE FINDINGS STATED THAT SEPARATELY, THE FIRM FAILED TO REGISTER A DIFFERENT ASSOCIATED PERSON, THE FIRM'S CHIEF COMPLIANCE OFFICER, AS A SERIES 7 GENERAL SECURITIES REPRESENTATIVE WITH BYX. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO FOLLOW ITS WRITTEN SUPERVISORY PROCEDURES TO ENSURE THAT ITS ASSOCIATED PERSONS WERE PROPERLY REGISTERED WITH THE EXCHANGE. Status: Final Sanction Detail: THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES. Summary: THE FIRM WAS CENSURED, FINED $7,500 AND REQUIRED TO ENSURE THAT THE ASSOCIATED PERSON DISCUSSED IN THE AWC BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX, ASSUMING THE FIRM INTENDS FOR THE ASSOCIATED PERSON TO HAVE A ROLE IN SUPERVISING THE TRADING ACTIVITIES OF THE FIRM ON BYX GOING FORWARD. UNTIL THIS ASSOCIATED PERSON BECOMES QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL, THE INDIVIDUAL SHALL HAVE NO ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX. THE FIRM SHALL INFORM FINRA THAT THE ASSOCIATED PERSON BECAME QUALIFIED AND REGISTERED AS A SERIES 24 SECURITIES TRADER PRINCIPAL WITH BYX. ALTERNATIVELY, IF THE FIRM DECIDES THAT THE ASSOCIATED PERSON SHALL NOT HAVE A ROLE IN SUPERVISING THE FIRM'S TRADING ACTIVITIES ON BYX GOING FORWARD, THE INFORMATION TO FINRA SHALL PROVIDE NOTICE OF THAT DECISION AND THE DATE OF THAT DECISION. THE DECISION IN THIS MATTER IS FINAL 20 BUSINESS DAYS AFTER THE ISSUANCE OF THE DECISION. THEREFORE, THIS AWC WILL BECOME FINAL AUGUST 14, 2018. PAYMENT WAS REMITTED 7/26/2018. THE SUPERVISORY STRUCTURE WAS REVISED AND A QUALIFIED SERIES 24 SECURITIES TRADER PRINCIPAL IS NOW SUPERVISING THE TRADING DESK ACTIVITIES.

Allegations: THE CFPB ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING AND ENROLLMENT PRACTICES WITH RESPECT TO DEBT CANCELLATION AND CREDIT MONITORING PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTIONS 1031 AND 1036 OF THE CONSUMER FINANCIAL PROTECTION ACT OF 2010. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE CFPB ALLEGATIONS, FNBO, PURSUANT TO THE ORDER, AGREED TO PAY A CIVIL MONETARY PENALTY OF $4,500,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF ADD-ON PRODUCTS, SERVICE PROVIDER MONITORING AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.

Allegations: THE OCC ALLEGED THAT FNBO ENGAGED IN UNFAIR BILLING PRACTICES WITH REGARD TO IDENTITY PROTECTION PRODUCTS THAT RESULTED IN VIOLATIONS OF SECTION S OF THE FEDERAL TRADE COMMISSION ACT. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE OCC ALLEGATIONS, FNBO AGREED TO CEASE AND DESIST FROM VIOLATING SECTION 5 OF THE FTC ACT AND TO PAY A CIVIL MONETARY PENALTY OF $3,000,000 AND MAKE FULL REIMBURSEMENTS TO ELIGIBLE CUSTOMERS. BOTH THE OCC AND CFPB TOGETHER HAVE JOINTLY ORDERED THE REPAYMENT TO CUSTOMERS WHICH IS ESTIMATED TO TOTAL $27.75 MILLION. FINALLY, FNBO AGREED TO THE IMPOSITION OF CERTAIN REMEDIAL MEASURES IN THE AREAS OF THIRD-PARTY VENDOR MANAGEMENT AND UNFAIR AND DECEPTIVE ACTS AND PRACTICES RISK MANAGEMENT. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS AS HIGHLIGHTED ABOVE IN ITEM 7, FNBO AGREED TO SANCTIONS IMPOSED AS DESCRIBED ABOVE IN ITEM 12.

Allegations: SEC ADMIN RELEASES 33-9946; 34-76043; SEPTEMBER 30, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST NORTHLAND SECURITIES, INC. ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE. Status: Final Sanction Detail: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $220,000 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN RESPONDENT'S OFFER. ACCORDINGLY, IT IS HEREBY ORDERED THAT RESPONDENT SHALL, CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $220,000 TO THE SECURITIES AND EXCHANGE COMMISSION; AND RETAIN AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.