Landaas & Company, Llc

Allegations: LANDAAS & COMPANY WAS ALLEGED TO HAVE NOT BEEN PROPERLY REGISTERED AS A BROKER-DEALER IN THE STATE OF ALABAMA BEFORE PERFORMING BROKER-DEALER-RELATED ACTIVITIES FOR THE FIRM'S SINGLE ALABAMA-RESIDENT CLIENT. Status: Final Sanction Detail: LANDAAS WAS ORDERED TO PAY $2,500.00 TO THE ALABAMA SECURITIES DIVISION AS PARTIAL REIMBURSEMENT OF THE DIVISION'S INVESTIGATION AND A FINE OF $3,000.00 PAYABLE TO THE STATE OF ALABAMA. EACH AMOUNT WAS FULLY PAID BY CHECK ON 10/22/18. Summary: LANDAAS & COMPANY IS NOW REGISTERED IN THE STATE OF ALABAMA.

Allegations: FAILURE TO REGISTERED IN THE STATE OF ALABAMA FOR BROKER/DEALER ACTIVITIES RELATED TO A SINGLE CLIENT. Status: Final Sanction Detail: $3,000.00 PAID TO THE STATE OF ALABAMA $2,500.00 PAID TO THE ALABAMA SECURITIES COMMISSION

Allegations: FROM 1999 THROUGH MARCH 2017, LANDAAS & COMPANY ("L&C") AND ITS CHAIRMAN AND SOLE OWNER ("LANDAAS") RECEIVED UNDISCLOSED FINANCIAL COMPENSATION BY HAVING AN UNAFFILIATED CLEARING BROKER CHARGE L&C ADVISORY CLIENTS A $20 MARK-UP INCLUDED IN THE CLEARING BROKER'S CONFIRMATION FEE. WHILE L&C USED A PORTION OF THE MARK-UP TO DEFRAY CLEARING BROKER'S CLEARING AND EXECUTION CHARGES FOR ADVISORY CLIENT TRADES, IN SOME INSTANCES L&C RETAINED THE REMAINDER AS COMPENSATION FOR ACTING AS THE INTRODUCING BROKER. L&C DID NOT INFORM ADVISORY CLIENTS THAT IT RECEIVED ANY COMPENSATION FOR ACTING AS INTRODUCING BROKER FOR CLIENT TRADES OR THAT THIS COMPENSATION CREATED A CONFLICT OF INTEREST. TO THE CONTRARY, CERTAIN L&C REPRESENTATIVES MISUNDERSTOOD THE CONFIRMATION FEE AND AS A RESULT INCORRECTLY TOLD CLIENTS THAT THE FIRM DID NOT RECEIVE ANY PORTION OF THE CONFIRMATION FEE. THE MARKED-UP CONFIRMATION FEE ALSO CAUSED L&C TO BREACH ITS FIDUCIARY DUTY TO SEEK BEST EXECUTION FOR ITS ADVISORY CLIENTS. IN ADDITION, THE CLEARING BROKER SHARED WITH L&C REVENUES THAT THE CLEARING BROKER RECEIVED FROM MUTUAL FUNDS IN THE CLEARING BROKER'S NO-TRANSACTION-FEE MUTUAL FUND PROGRAM. THE RECEIPT OF THESE UNDISCLOSED PAYMENTS CREATED A FINANCIAL INCENTIVE FOR L&C TO FAVOR NO-TRANSACTION-FEE FUNDS OVER OTHER INVESTMENTS AND CREATED YET ANOTHER CONFLICT OF INTEREST WHICH L&C DID NOT DISCLOSE. L&C ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO MEET ITS BEST EXECUTION OBLIGATIONS. AS A RESULT, L&C AND LANDAAS WERE ALLEGED TO HAVE VIOLATED OR CAUSED VIOLATIONS OF SECTIONS 206(2), 206(4), AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Status: Final Sanction Detail: SANCTIONS AGAINST BOTH PARTIES: CENSURE AND THE FOLLOWING MONETARY PENALTIES: DISGORGEMENT OF $408,483.06; $60,458.14 IN PREJUDGMENT INTEREST; AND A $130,000 FINE (COLLECTIVELY, $598,941.20). SANCTIONS SOLELY AGAINST LANDAAS & COMPANY: RETAIN INDEPENDENT COMPLIANCE CONSULTANT; DISTRIBUTE PROCEEDS OF THE FAIR FUND TO AFFECTED CLIENTS. ALL AMOUNTS OWED HAVE BEEN FULLY SATISFIED AS FOLLOWS: $91,295.63 UNDER ORDER SECTION IV.D.(II), REC'D BY SEC: 12/13/18; $507,645.57 UNDER ORDER SECTION IV.D.(III) (THE FAIR FUND), FULLY FUNDED: 12/18/18. Summary: IN ANTICIPATION OF THE INSTITUTION OF THE PROCEEDINGS INITIATED BY THE SECURITIES AND EXCHANGE COMMISSION, MR. LANDAAS (JOINTLY WITH LANDAAS & COMPANY) SUBMITTED AN OFFER OF SETTLEMENT WHICH THE SEC ACCEPTED. SOLELY FOR THE PURPOSE OF THE PROCEEDINGS PERTAINING TO THE SEC'S ALLEGATIONS IN THIS MATTER AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE SEC, OR TO WHICH THE SEC IS A PARTY, AND WITHOUT ADMITTING OR DENYING ITS FINDINGS, EXCEPT AS TO THE SEC'S JURISDICTION OVER THE PARTIES AND THE SUBJECT MATTER OF THE PROCEEDINGS, WHICH ARE ADMITTED, AND EXCEPT AS PROVIDED IN SECTION V OF THE ORDER, MR. LANDAAS (AND LANDAAS & COMPANY) CONSENTED TO THE SEC'S ENTRY OF THE "ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E), 203(F), AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTIONS 15(B)(4) AND 15(B)(6) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER."