Hancock Whitney Investment Services Inc.

Allegations: OUR AFFILIATE BROKER/DEALER UNCOVERED AN ISSUE WITH ITS EMAIL RETENTION SYSTEM AND SELF REPORTED THE MATTER TO FINRA. THE SYSTEM WAS NOT FULLY WORM COMPLIANT, BUT THERE WAS NO LOSS OF RECORDS. THE MATTER WAS SELF REPORTED AND CORRECTED BY THE BROKER/DEALER. Status: Final Sanction Detail: THE PENALTY WAS $100,000 AND WAS PAID ON 1/25/2018. THE FINE WAS NOT ATTRIBUTABLE IN ANY WAY TO THE INVESTMENT ADVISER. Summary: THE MATTER WAS RESOLVED AND THE FINE WAS PAID ON 1/25/2018

Allegations: AS PER THE SEC'S ORDER ,AT TIMES FROM JANUARY 2014 TO MAY 2017, HWIS FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST ARISING FROM THREE DIFFERENT SHARE CLASS SELECTION PRACTICES. FIRST, THE ORDER FINDS THAT HWIS SELECTED MUTUAL FUND SHARE CLASSES FOR CLIENTS THAT CHARGED 12B-1 FEES THAT FINANCIALLY BENEFITTED HWIS, INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS. SECOND, THE ORDER FINDS THAT HWIS SELECTED MUTUAL FUND SHARE CLASSES FOR WHICH IT RECEIVED REVENUE SHARING PAYMENTS, INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS. THIRD, THE ORDER FINDS THAT HWIS SELECTED A MONEY MARKET FUND USED AS A CASH SWEEP VEHICLE FOR WHICH HWIS RECEIVED REVENUE-SHARING PAYMENTS, INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUND. THE ORDER FURTHER FINDS THAT HWIS BREACHED ITS DUTY TO SEEK BEST EXECUTION FOR THESE TRANSACTIONS AND THAT IT FAILED TO ADOPT AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THESE VIOLATIONS. Status: Final Sanction Detail: THE SEC ORDER FOUND THE HWIS WILLFULLY VIOLATED SECTIONS 206(2), 206(4), AND 206 (4)-7 THEREUNDER OF THE ADVISER'S ACT. SANCTION INCLUDED RESTITUTION TOTALING $1,651,686.28, INTEREST OF $286,105.79, AND CIVIL PENALTY OF $400,000.