First Kentucky Securities Corporation

Allegations: FAILURE TO CONDUCT AND EVIDENCE AN ADEQUATE INDEPENDENT TEST OF THE AML COMPLIANCE PROGRAM IN 2009, NASD CONDUCT RULE 3011 AND FINRA RULE 2010 AND MSRB RULE G-41 Status: Final Sanction Detail: JOINT AND SEVERAL FINE ($7,500 FINRA, $7,500 MSRB) AND CENSURE AGAINST FIRST KENTUCKY AND KRAMER. FKSC WILL UNDERTAKE TO PROVIDE FINRA'S CHICAGO OFFICE THE REPORTS OF 2010 AND 2011 INDEPENDENT TESTS OF ITS AML COMPLIANCE PROGRAM AND WILL COMPLETE THE 2012 REPORT AND PROVIDE IT TO FINRA, CHICAGO BY JANUARY 11, 2013. Summary: .

Allegations: FINRA RULE 2010, NASD RULES 2110, 3011, INTERPRETATIVE MATERIAL 3011-1, MSRB RULE G-41 - FIRST KENTUCKY SECURITIES CORPORATION FAILED TO CONDUCT AND EVIDENCE AN INDEPENDENT TEST OF TIS ANTI-MONEY LAUNDERING (AML) PROGRAM ONE CALENDAR YEAR IN VIOLATION OF FINRA AND MUNICIPAL SECURITIES RULEMAKING BOARD (MSRB) RULES. Status: Final Sanction Detail: FINE PAID 10/19/2010 VIA CREDIT CARD Summary: .

Allegations: FIRST KENTUCKY EXECUTED TRADES FOR THE CLIENTS BEFORE BEING REGISTERED IN NEBRASKA Status: Final Sanction Detail: FINE 8500.00 PAID 12/29/2015

Allegations: FIRST KENTUCKY SECURITIES EXECUTED TRADES IN ALABAMA BEFORE BEING REGISTERED IN ALABAMA. Status: Final Sanction Detail: FINE 12500.00 PAID 3/10/2016

Allegations: FIRST KENTUCKY EXECUTED TRADES FOR CLIENTS BEFORE BEING REGISTERED IN NORTH DAKOTA Status: Final Sanction Detail: FINE $4,000 PAID 8/18/2015

Allegations: IA RELEASE 40-5161 / MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST FIRST KENTUCKY SECURITIES CORPORATION ("RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT Status: Final Sanction Detail: THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $118,064.60 AND PREJUDGMENT INTEREST OF $14,586.40, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $118,064.60 AND PREJUDGMENT INTEREST OF $14,586.40, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENT.