Insight Securities, Inc.

Allegations: SEC RULE 17A-3, NASD RULES 2110,3110,6230 - HORWITZ & ASSOCATES, INC. FAILED TO ACCURATELY OR TIMELY REPORT TRACE-ELIGIBLE SECURITIES TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE). Status: Final Sanction Detail: PAID $7500.00 ON 3-15-2007 Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, HORWITZ & ASSOCIATES INC., CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS.

Allegations: FINRA RULE 6730(A): THE MEMBER FIRM FAILED TO ACCURATELY REPORT SOME TRANSACTIONS TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) THAT WERE TRACE-ELIBGIBLE TRANSACTIONS. IN EACH OF THE INACCURATELY REPORTED TRANSACTIONS, THE FIRM IMPROPERLY BUNCHED TRANSACTIONS TOGETHER. FOR EXAMPLE, IN ONE INSTANCE, THE FIRM REPORTED IT AS TWO SEPARATE TRANSACTIONS: THE SALE OF 150 BONDS TO ONE CUSTOMER AND THE SALE OF 100 BONDS TO A DIFFERENT CUSTOMER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS FINED $5000.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM'S PRICING OF CORPORATE BOND TRANSACTIONS TRADED FOR ITS OWN ACCOUNT FAILED TO BE FAIR. THE FINDINGS STATED THAT THE FIRM FAILED TO TAKE INTO CONSIDERATION ALL RELEVANT CIRCUMSTANCES, INCLUDING MARKET CONDITIONS WITH RESPECT TO EACH BOND AT THE TIME OF THE TRANSACTION, THE EXPENSE INVOLVED, AND THE FACT THAT THE FIRM WAS ENTITLED TO A PROFIT. SOME OF THE TRADES INVOLVED MARK-UPS OR MARK-DOWNS GREATER THAN FIVE PERCENT. THE FOREGOING CONDUCT WAS LIMITED TO ONE BRANCH OFFICE OF THE FIRM AND STEMMED FROM INSUFFICIENT TRAINING. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $30,000. Summary: INSIGHT SECURITIES CONTINUALLY WORKS TO IDENTIFY AND MITIGATE RISK THROUGHOUT THE FIRM. AS SUCH, THE INDIVIDUALS LOCATED WITHIN THIS BRANCH HAVE ALL BEEN ORDERED TO COMPLETE ADDITIONAL TRAINING TO ENSURE THAT A SIMILAR INSTANCE DOES NOT OCCUR AGAIN. RESTITUTION HAD ALREADY BEEN PAID TO THE AFFECTED CLIENTS ONCE WE BECAME AWARE OF THIS ISSUE. THE FIRM BELIEVES THIS TO BE AN ISOLATED INCIDENT AND FIRM POLICIES AND PROCEDURES HAVE ALREADY BEEN PUT INTO EFFECT AND WILL CONTINUALLY BE SUBJECT TO RISK ASSESSMENTS TO ENSURE THAT POLICY'S AND PROCEDURES REMAIN APPROPRIATE.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT THE FIRM RETENTION AND REVIEW OF INSTANT MESSAGING FAILED TO BE ADEQUATE Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $50,000 Summary: INSIGHT SECURITIES CONTINUALLY WORKS TO IDENTIFY AND MITIGATE RISK THROUGHOUT THE FIRM. IN A REVIEW OF ITS POLICIES, IT WAS DISCOVERED THAT SOME MEMBERS OF THE FIRM HAD BEEN COMMUNICATING WITH CLIENTS USING INSTANT MESSAGING. THE FIRM BEGAN MONITORING INSTANT MESSAGING IN 2019 AND HAS ALSO ASKED FOR AND RECEIVED THE HISTORICAL MESSAGES BETWEEN FIRM AND CLIENT IN ORDER TO ENSURE THAT THE BOOKS AND RECORDS ARE COMPLETE. THROUGHOUT THE FIRM'S 51-YEAR HISTORY, THERE HAVE BEEN NO OTHER POTENTIAL ISSUES BROUGHT BY REGULATORS IN REGARDS TO COMMUNICATION. AS SUCH, THE FIRM BELIEVES THAT THIS IS AN ISOLATED INCIDENT WHICH WAS RECTIFIED BY THE FIRM NEARLY THREE YEARS BEFORE THIS REGULATOR RESPONSE. THE FIRM WILL CONTINUALLY MONITOR AND TEST ITS POLICIES AND PROCEDURES TO ENSURE THAT EACH IS APPROPRIATE AND EFFECTIVE.

Allegations: THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASEAND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST INSIGHT SECURITIES, INC. ("INSIGHT" OR "RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. THE COMMISSION FINDS THAT THIS MATTER INVOLVES FAILURES BY INSIGHT, A REGISTERED INVESTMENT ADVISER, TO COMPLY WITH AMENDMENTS TO ADVISERS ACT RULE 206(4)-1 THAT THE COMMISSION ADOPTED IN DECEMBER 2020 (THE "AMENDED MARKETING RULE"). FROM NOVEMBER 4, 2022, THE COMPLIANCE DEADLINE FOR THE AMENDED MARKETING RULE, THROUGH JUNE 8, 2023 (THE "RELEVANT PERIOD"), INSIGHT ADVERTISED HYPOTHETICAL PERFORMANCE ON ITS PUBLIC WEBSITE WITHOUT ADOPTING AND IMPLEMENTING POLICIES AND PROCEDURES REASONABLY DESIGNED TO ENSURE THAT THE HYPOTHETICAL PERFORMANCE WAS RELEVANT TO THE LIKELY FINANCIAL SITUATION AND INVESTMENT OBJECTIVES OF THE INTENDED AUDIENCE. AS A RESULT OF ITS CONDUCT, INSIGHT WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-1(D) THEREUNDER Status: Final Sanction Detail: THE FIRM IS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-1 THEREUNDER, IS CENSURED, SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER, AND SHALL PAY A CIVIL MONEY PENALTY OF $20,000. Summary: THE FIRM ACKNOWEDGED, RECOGNIZED AND ADDRESSSED THE VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-1 (MARKETING RULE), THE FIRM WAS CENSURED, REQUIRED TO PAY A CIVIL MONEY PENALTY OF $20,000 AND COMPLY WITH CERTAIN UNDERTAKINGS AND ORDRED TO CEASE & DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE MARKETING RULE.

Allegations: WITHOUT ADMITING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND ENTRY OF FINDINGS THAT INSIGHT SECURITIES DID NOT HAVE A SYSTEM IN PLACE TO REASONABLY ASSURE THAT SOLICITED TRADES IN LEVERAGED AND INVERSE ETFS AND ETNS WERE NOT HELD BY CLIENT LONGER THAN ONE TRADING SESSION Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $25,000