Crews & Associates, Inc.

Allegations: VIOLATION OF ARTICLE III SECTION 1, 21 AND 27 "RULES OF FAIR PRACTICE", DURING PERIOD 06/21/83-08/16/83 PERTAINING TO DISTRIBUTION OF DPP OFFERING; 02/28/85, 03/29/85, 04/12/85 DEPOSIT RELATING TO RESERVE 15C3-3 COMPUTATIONS; 11/01/84-04/18/85 - POSSESSION & CONTROL Status: Final Sanction Detail: $5,000.00 WAS FINED THE APPLICANT. THE AMOUNT WAS PAID BY APPLICANT ON RESOLUTION WITH NO PORTION WAIVED.

Allegations: NASD RULES 2110, 6230(A), 6230(C)(8) - CREWS & ASSOCIATES, INC. FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE (TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, CREWS & ASSOCIATES, INC. CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS THEREFORE, THE FIRM IS FINED $5,000

Status: Final Sanction Detail: $50,000 FINE - PAID ON 5-23-2023. CENSURE. UNDERTAKING TO CERTIFY REMEDIATION AND IMPLEMENT ADDITIONAL SUPERVISORY SYSTEM IN WSP - UNDERTAKING IS IN PROCESS AND WILL BE COMPLETED ON OR BEFORE JULY 15 2023. Summary: ALLEGATIONS THAT THE FIRM SOLD MUNI BONDS TO AN AFFILIATE BANK WITH MARKUP - IN CONFLICT WITH A SELLING ARRANGEMENT AND POTENTIAL VIOLATION OF MSRB RULES G-18 AND G-17. DISPOSITION, ON 05-23-2023 THE FIRM PAID THE FINE OF $50,000. BEFORE 60 DAYS FROM THE FINAL AWC THE FIRM WILL CERTIFY IN WRITING THAT THE FIRM HAS REMEDIATED THE ISSUES IN THE AWC AND IMPLEMENTED ADDITIONAL SUPERVISORY SYSTEMS IN ITS WSP REASONABLY DESIGNED TO ACHEIVE COMPLIANCE WITH MSRB RULES G-18 AND G-17.

Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT ERRONEOUSLY BELIEVED THAT THE LIST OFFERING PRICE/TAKEDOWN SPECIAL CONDITION INDICATOR (SCI) WAS ONLY NECESSARY FOR TRADES REPORTED OUTSIDE OF THE GENERAL 15-MINUTE REQUIREMENT. CONSEQUENTLY, BETWEEN JANUARY 1, 2013 AND DECEMBER 31, 2013, THE FIRM REPORTED 197 LIST OFFERING PRICE/TAKEDOWN TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD'S (MSRB) REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) WITHIN 15 MINUTES OF EXECUTION, BUT WITHOUT THE REQUIRED SPECIAL CONDITION INDICATOR. THE FINDINGS STATED THAT BETWEEN OCTOBER 1, 2013 AND DECEMBER 31, 2013, THE FIRM INCORRECTLY STATED ITS CAPACITY ON 50 CUSTOMER CONFIRMATIONS. IN ALL INSTANCES, THE FIRM INCORRECTLY STATED THE CAPACITY AS "BROKER ONLY" WHEN THE CAPACITY SHOULD HAVE BEEN STATED AS "PRINCIPAL." THE FINDINGS ALSO STATED THAT IN 2012, THE FIRM RECEIVED A LETTER OF CAUTION WITH REGARDS TO INACCURATE CAPACITY REPORTING TO MSRB'S RTRS. ALTHOUGH THE FIRM CORRECTED THE TRADE REPORTING OF ITS CAPACITY, THE FIRM NEVER CONDUCTED ANY TESTING OF THE ACCURACY OF ITS CUSTOMER CONFIRMATIONS. THE FIRM SHOULD HAVE HAD CONTROLS IN PLACE TO TEST ITS OWN CONFIRMATION PROCESS TO ENSURE THE ACCURACY OF INFORMATION ON THE CONFIRMATIONS AND ITS COMPLIANCE WITH MSRB RULE G-15. Status: Final Sanction Detail: THE FIRM WAS CENSURED AND FINED $15,000

Allegations: PLACEMENT OF SECURITIES IN A CUSTOMER LIEU A SPECIAL HOUSE ACCOUNT (PROVIDED BY AN AGREEMENT CREWS WITH DISTRICT 5) VIOLATED CONDUCT RULE 2110 FORMERLY ARTICLE III SECTION 1, NASD "RULES OF FAIR PRACTICE". Status: Final Sanction Detail: $5,000.00 WAS FINED APPLICANT AND PAID ON RESOLUTION NO PORTION WAIVED. Summary: DURING PERIOD 02/25/94-12/20/94, CREWS EXECUTED A SERIES OF TRANSACTIONS PLACING DEBT SECURITIES INTO AN INDIVIDUAL PUBLIC ACCOUNT RATHER THAN A SPECIAL HOUSE ACCOUNT TO BE USED PURSUANT TO TERMS OF TRADING GUIDELINES DATED 6/25/93. THIS PLACEMENT WAS DESIGNED TO REMOVE PERCEIVED APPEARANCE OF INTERPOSING OR IMPLICATION OF SPECIAL CONSIDERATION.

Allegations: ALLEDGED VIOLATION MSRV RULE G12 REQUIRED PROCEDURES IN CLEARING TRADES NOT FOLLOWED PROVIDING TIMELY AND ACCURATE INFORMATION, RESULTING IN VIOLATION MSRB RULE G14 REPORTING TO SHOW EQUALITY TO INDUSTRY T-INPUT PERCENTAGE Status: Final Sanction Detail: AWC ACCEPTED NASD REGULATION INC. AND NATIONAL ADJUDICATORY COUNCIL. $1000.OO FINED APPLICANT, PAID AS BILLED. NONE WAIVED.

Allegations: A CONSENT ORDER ("ORDER") APPROVED BY THE ARKANSAS SECURITIES COMMISSIONER ON JULY 9, 2013, FOUND THAT CREWS & ASSOCIATES, INC. ("CREWS") (CRD# 8052) VIOLATED THE ARKANSAS SECURITIES ACT ("ACT"), THE RULES OF THE ARKANSAS SECURITIES COMMISSIONER ("RULES"), AND CERTAIN FINRA RULES IN ITS RECOMMENDATION OF AND ROLE SPECIFICALLY AS THE PLACEMENT AGENT FOR PRIVATE PLACEMENT SECURITIES OFFERINGS REGARDING DEBENTURES FOR BAMCO GAS, LLC ("BAMCO"), IN 2005 ("SENIOR DEBENTURE OFFERING") AND 2008 ("SUBORDINATE DEBENTURE OFFERING"). CREWS NEITHER ADMITTED NOR DENIED THE FINDINGS OF FACT OR CONCLUSIONS OF LAW IN THE ORDER. THE ORDER FOUND THAT CREWS VIOLATED NASD CONDUCT RULE 2310 (RECOMMENDATIONS TO CUSTOMERS - SUITABILITY), ARK. CODE ANN. § 23-42-308(A)(2)(G), AND RULES 308.01(D) AND (X) OF THE RULES BY RECOMMENDING ITS CUSTOMERS PURCHASE THE BAMCO DEBENTURES AFTER CREWS FAILED TO CONDUCT A REASONABLE DUE DILIGENCE INVESTIGATION FOR THE SENIOR DEBENTURE OFFERING OR THE SUBORDINATE DEBENTURE OFFERING. CREWS DID NOT HAVE AN ADEQUATE AND REASONABLE BASIS FOR BELIEVING THAT THE RECOMMENDATIONS OF THE BAMCO DEBENTURES WERE SUITABLE FOR AT LEAST SOME CUSTOMERS OF CREWS. AS A RESULT, THE BAMCO DEBENTURES WERE NOT SUITABLE FOR CREWS' CUSTOMERS UNDER A REASONABLE-BASIS SUITABILITY ANALYSIS. FURTHER, CREWS VIOLATED ARK. CODE ANN. § 23-42-308(A)(2)(G) AND RULE 308.01(Y) OF THE RULES WHEN CREWS FAILED TO DISCLOSE CERTAIN INFORMATION ABOUT BAMCO, BAMCO'S CONTROL PERSONS, AND THE BAMCO DEBENTURES IN THE PRIVATE PLACEMENT MEMORANDA FOR THE BAMCO DEBENTURES, WHICH WERE DRAFTED BY CREWS, CREWS' OUTSIDE COUNSEL, AND BAMCO. ON THIS OFFERING CREWS FAILED TO ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENABLE CREWS AND ITS AGENTS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS, RULES, AND REGULATIONS IN THE BAMCO DEBENTURE OFFERINGS. CREWS' VIOLATIONS RESULTED, IN PART, FROM CREWS' SUPERVISORY FAILURES. CREWS' FAILURE TO REASONABLY SUPERVISE THE BAMCO DEBENTURE OFFERINGS WAS FOUND TO BE IN VIOLATION OF NASD CONDUCT RULE 3010 (SUPERVISION), ARK. CODE ANN. § 23-42-308(A)(2)(G) AND (J), AND RULE 308.01(X) OF THE RULES. PURSUANT TO ARK. CODE ANN. § 23-42-209(A)(1)(A), CREWS WAS ORDERED TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF ARK. CODE ANN. § 23-42-308(A)(2)(G) AND (J); AND RULE 308.01(D), (X), AND (Y) OF THE RULES. IN RECOGNITION OF CREWS' SUCCESSFUL EFFORTS TO REPURCHASE THE BAMCO DEBENTURES FROM ITS CUSTOMERS AND ITS DONATION OF $150,000.00 ON JULY 8, 2013, TO THE NORTH AMERICAN SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") TO ADVANCE THE TRAINING AND INVESTOR-PROTECTION PROGRAMS OFFERED BY NASAA, NO FINE WAS LEVIED AGAINST CREWS. CREWS WAS FURTHER ORDERED TO, UPON REQUEST BY THE DEPARTMENT, NOTIFY THE DEPARTMENT IN WRITING OF ANY PRIVATE PLACEMENT OFFERINGS FOR WHICH IT ACTS AS THE PLACEMENT AGENT AND PROVIDE CERTAIN SUPPORTING DOCUMENTATION TO THE DEPARTMENT. ADDITIONALLY, CREWS WAS ORDERED TO RETAIN AN INDEPENDENT BROKER-DEALER SUPERVISORY COMPLIANCE EXPERT TO EVALUATE AND SUBMIT AN OPINION THAT THE PORTION OF CREWS' WRITTEN SUPERVISORY PROCEDURES ADDRESSING PRIVATE PLACEMENT OFFERINGS IS IN A FORM CONSISTENT WITH INDUSTRY STANDARDS AND COMPLIANT WITH RELEVANT FINRA CONDUCT RULES, THE ACT, AND THE RULES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE ORDER, PURSUANT TO ARK. CODE ANN. § 23-42-209(A)(1)(A), CREWS WAS ORDERED TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF ARK. CODE ANN. § 23-42-308(A)(2)(G) AND (J); AND RULE 308.01(D), (X), AND (Y) OF THE RULES. CREWS WAS FURTHER ORDERED TO, UPON REQUEST BY THE DEPARTMENT, NOTIFY THE DEPARTMENT IN WRITING OF ANY PRIVATE PLACEMENT OFFERINGS FOR WHICH IT ACTS AS THE PLACEMENT AGENT AND PROVIDE CERTAIN SUPPORTING DOCUMENTATION TO THE DEPARTMENT. ADDITIONALLY, CREWS WAS ORDERED TO RETAIN AN INDEPENDENT BROKER-DEALER SUPERVISORY COMPLIANCE EXPERT TO EVALUATE AND SUBMIT AN OPINION THAT THE PORTION OF CREWS' WRITTEN SUPERVISORY PROCEDURES ADDRESSING PRIVATE PLACEMENT OFFERINGS IS IN A FORM CONSISTENT WITH INDUSTRY STANDARDS AND COMPLIANT WITH RELEVANT FINRA CONDUCT RULES, THE ACT, AND THE RULES.

Allegations: SEC ADMIN RELEASES 33-9953; 34-76050; 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 CREWS & ASSOCIATES, 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 $250,000.00 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: IN ANTICIPATION OF THESE PROCEEDINGS, RESPONDENT 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 CONSENTED 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 DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS ALREADY AGREED TO IN OUR OFFER. RESPONDENT WILL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF 17(A)(2)OF THE SECURITIES ACT; RESPONDENT PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $250,000.00 TO THE COMMISSION; AND RETAINED AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.

Allegations: MSRB RULE G-36 - RESPONDENT MEMBER FAILED TO TIMELY REPORT MUNICIPAL SECURITIES RULEMAKING BOARD FORMS G-36S WITH THE MSRB. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, CREWS & ASSOCIATES, INC., CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS THEREFORE, THE FIRM IS FINED $5,000

Allegations: DURING THE CALENDAR YEARS 2003 AND 2004 FINRA DECIDED THERE WERE 14 INSTANCES CREWS EXECUTED TRANSACTIONS WITH CUSTOMERS AT PRICES DETERMINED BY FINRA TO BE UNFAIR AND UNREASONABLE WHILE TAKING INTO CONSIDERATION ALL RELEVANT FACTS SURROUNDING THE MARKET FOR SUCH TRANSACTIONS IN VIOLATION OF MSRB RULES G-17 AND G-30. AS A RESULT OF THESE TRANSACTIONS, FINRA CITED THE FIRM FOR FAILING TO MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH MSRB RULE G-27. CREWS FAILED TO REPORT CERTAIN MUNICIPAL SECURITIES TRANSACTIONS IN A TIMELY MANNER AS PRESCRIBED BY MSRB RULE G-14 RTRS PROCEDURES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR PRICING AND MARKUPS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.

Allegations: MSRB RULES G-8, G-14 - CREWS & ASSOCIATES, INC. DID NOT ACCURATELY CAPTURE THE CORRECT EXECUTION TIME FOR CERTAIN MUNICIPAL SECURITIES TRANSACTIONS AND, AS A RESULT, THE FIRM FAILED TO REPORT THE CORRECT TRADE TIME TO THE REAL-TIME TRANSACTION REPORTING SYSTEM (RTRS) IN MUNICIPAL SECURITIES TRANSACTIONS; AND FAILED TO SHOW THE CORRECT EXECUTION TIME ON THE TRADE MEMORANDUM FOR MUNICIPAL SECURITIES TRANSACTIONS. 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 $5,000 FOR MSRB RULE VIOLATIONS. Summary: IT WAS DETERMINED THAT THERE WERE 80 TRANSACTIONS WHICH WERE NOT IN SYNC WITH THE CONTRA-PARTIES' REPORTING TIMES. THE 80 TRADES WERE PART OF 2,736 REPORTED OVER A PERIOD OF 3 MONTHS. TO MITIGATE FUTURE MISMATCHES, CREWS CONDUCTED SPECIAL TRAINING FOR ITS TRADERS AND ASSISTANTS TO RE-EMPHASIZE RESPONSIBILITY AND IMPORTANCE OF RECORDING AND REPORTING THE CORRECT TIME OF EXECUTION FOR MUNICIPAL TRADES. TRAINING CONSISTED OF EACH TRADER TAKING OWNERSHIP OF THE 'TIME OF TRADE' (TOT) WITH THE CONTRA-PARTY AND UNDERSTANDING EXACTLY HOW OUR INTERNAL TRADING SYSTEMS MANAGE DATA INPUT. WE ALSO SOLICITED AND ENCOURAGED THOSE DEALERS WHICH PROVIDE ELECTRONIC NOTIFICATION TO TAKE RESPONSIBILITY FOR PROVIDING EMAIL NOTIFICATIONS TO TRADING AND SUPPORT PERSONNEL WHEN THERE IS AN AUTOMATIC EXECUTION. ADDITIONALLY, THE 'TIME OF EXECUTION' FOR EACH MUNICIPAL TRANSACTION IS BEING MONITORED DAILY BY CREWS MANAGEMENT AND OPERATIONS PERSONNEL USING THE MSRB DISCREPANCY ERROR CODE REPORT. IF ANY TRANSACTION SHOWS A 'TIME OF EXECUTION' DIFFERENCE GREATER THAN 15 MINUTES, THE TRADER IS IMMEDIATELY CONTACTED BY HIS SUPERVISOR AND REQUIRED TO PROVIDE A REASON FOR THE DIFFERENCE TO COMPLIANCE.

Allegations: VIOLATIONS OF MSRB G-37 Status: Final Sanction Detail: $250.00 FINED THE APPLICANT, PAID ON RESOLUTION AND NONE WAS WAIVED. Summary: IN FIRTS MSRB REPORTING YR, TWO UNDERWRITINGS QTRLY PERIOD 9/30/95 1. ADFA SERIES 95 FROM SEQUENTIAL POSITION CO-MANAGER WITH THREE OTHERS AND SR-NO ADD ACTIVITY INCLUDING CLOSING NOTICE TO CREWS. 2. POCAHANTAS CNTY WV SERIES 95 A. B. C. WAS AN IN-PROCESS OMISSION. BOTH HAVE BEEN ADDRESSED IN ADDED CHECK OFF PROCEDURES TO ENSURE ACCURATE REPORTING.

Allegations: NON ALLOWABLE SALES PRIOR TO REGISTRATION Status: Final Sanction Detail: FINE OF $1700.00 WAS LEVIED AGAINST THE APPLICANT NONE WAS WAIVED, PAID IN FULL ON RESOLUTION. Summary: ALTHOUGH CREWS, WITH EXCEPTION OF SIX TRANSACTIONS IN EXEMPT SECURITIES WHICH IT BELIEVED PERMITTED BY THE MASSACHUSETTS ACT. BY INTERPRETATION, THE DIVISION APPLIED NO ALLOWANCE FOR SALES. ON THIS BASE, THE DIVISION ALLOWED CREWS ITS APPLICATION FOR REGISTRATION. NO ADDITIONAL ACTION OCCURED EXCEPT MONETARY FINE.

Allegations: IN THE MATTER OF CREWS & ASSOCIATES, INC.; ARKANSAS SECURITIES DEPARTMENT CASE NO. S-19-0005; ORDER NO. S-19-0005-19-OR01. CONSENT ORDER ENTERED WITH CREWS & ASSOCIATES, INC. FOR CERTAIN BOOKS AND RECORDS VIOLATIONS OF THE ARKANSAS SECURITIES ACT AND THE RULES OF THE ARKANSAS SECURITIES COMMISSIONER. CREWS SELF-REPORTED CRD FILING ISSUES TO THE STAFF OF THE ARKANSAS SECURITIES DEPARTMENT WHICH HAD CAUSED ITS APPLICATIONS FOR REGISTRATION IN ARKANSAS FOR TWO NON-SALES, FINRA-REGISTERED BROKER-DEALER AGENTS TO BE UNTIMELY FILED AFTER THE AGENTS PASSED THE SERIES 63 EXAMINATION. THE DEPARTMENT APPROVED THE APPLICATIONS OF BOTH AGENTS UPON ENTRY OF THIS CONSENT ORDER WITH CREWS. Status: Final Sanction Detail: FINE OF $5,000.00 PAID TO THE ARKANSAS SECURITIES DEPARTMENT DATED APRIL 11, 2019. Summary: IN THE MATTER OF CREWS & ASSOCIATES, INC.; ARKANSAS SECURITIES DEPARTMENT CASE NO. S-19-0005; ORDER NO. S-19-0005-19-OR01. CONSENT ORDER ENTERED WITH CREWS & ASSOCIATES, INC. FOR CERTAIN BOOKS AND RECORDS VIOLATIONS OF THE ARKANSAS SECURITIES ACT AND THE RULES OF THE ARKANSAS SECURITIES COMMISSIONER. CREWS SELF-REPORTED CRD FILING ISSUES TO THE STAFF OF THE ARKANSAS SECURITIES DEPARTMENT WHICH HAD CAUSED ITS APPLICATIONS FOR REGISTRATION IN ARKANSAS FOR TWO NON-SALES, FINRA-REGISTERED BROKER-DEALER AGENTS TO BE UNTIMELY FILED AFTER THE AGENTS PASSED THE SERIES 63 EXAMINATION. THE DEPARTMENT APPROVED THE APPLICATIONS OF BOTH AGENTS UPON ENTRY OF THIS CONSENT ORDER WITH CREWS.

Allegations: WILLFULL VIOLATION OF MSRB RULES G-17 AND G-27 AND BY REASON THEREOF, SECTION 15B(C)(1) OF THE EXCHANGE ACT. Status: Final Sanction Detail: N/A Summary: CIVIL MONEY PENALTY AND DISGORGEMENT PAID IN FULL ON AUGUST 26, 2021.