Cozad Asset Management Inc

Allegations: THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH OCTOBER 31, 2018, COZAD 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 THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE SEC'S ORDER ALSO FINDS THAT COZAD FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES. Status: Final Sanction Detail: CENSURE, THE ORDER ALSO INSTRUCTS US TO PAY A PENALTY, TO CEASE AND DESIST, AND TO DISGORGE. Summary: AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT COZAD WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND ORDERED COZAD TO PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, TOTALING $416,870.10, TO COMPENSATE AFFECTED INVESTORS, AND TO COMPLETE CERTAIN UNDERTAKINGS. COZAD CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, COZAD HAS TAKEN THE FOLLOWING ACTIONS: - NOTIFIED AFFECTED INVESTORS - UPDATED FORM ADV DISCLOSURES - UPDATED COMPANY POLICIES AND PROCEDURES - IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER-COST SHARE CLASSES - IDENTIFIED CLIENTS ELIGIBLE FOR REIMBURSEMENT OF THE 12B-1 FEES PAID DURING THE RELEVANT PERIOD