Stoker Ostler Wealth Advisors, Inc.

Allegations: THE U.S. COMMODITY FUTURE TRADING COMMISSION ("CFTC") ALLEGED THAT, FROM AT LEAST 2019 THROUGH THEDATE OF THE ORDER, BANK OF MONTREAL ("BMO") (I) FAILED TO KEEP CERTAIN REQUIRED RECORDS IN VIOLATIONOF SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTCREGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1), (II) FAILED TO KEEP RECORDS IN THE MANNER REQUIRED BYCFTC REGULATION 1.31, AND (III) FAILED TO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY INVIOLATION OF SECTION 4S(H)(1)(B) OF THE CEA AND CFTC REGULATION 23.602(A). Status: Final Sanction Detail: BANK OF MONTREAL ("BMO") ADMITTED TO THE FACTS IN THE CFTC'S ORDER, ACKNOWLEDGED ITS CONDUCT VIOLATED THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS, AND AGREED TO (I) THE ENTRY OF THE CFTC'S FINDINGS; (II) CEASE AND DESIST FROM VIOLATING SECTIONS4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE CEA AND CFTC REGULATIONS 1.31, 23.201(A), 23.202(A) Summary: ON AUGUST 8, 2023, THE U.S. COMMODITY FUTURES TRADING COMMISSION ("CFTC") ALLEGED THAT BANK OFMONTREAL ("BMO") (I) FAILED TO KEEP CERTAIN REQUIRED RECORDS IN VIOLATION OF SECTIONS 4S(F)(1)(C) AND4S(G)(1) AND (3) OF THE COMMODITY EXCHANGE ACT ("CEA") AND CFTC REGULATIONS 23.201(A) AND 23.202(A)(1)AND (B)(1), (II) FAILED TO KEEP RECORDS IN THE MANNER REQUIRED BY CFTC REGULATION 1.31, AND (III) FAILEDTO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY IN VIOLATION OF SECTION 4S(H)(1)(B) OF THECEA AND CFTC REGULATION 23.602(A). BMO ADMITTED TO THE FACTS IN THE CFTC'S ORDER, ACKNOWLEDGED THATITS CONDUCT VIOLATED THE CEA AND CFTC REGULATIONS, AND AGREED TO (I) THE SERVICE OF THE CFTC'S ORDER;(II) CEASE AND DESIST FROM VIOLATING SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE CEAAND CFTC REGULATIONS 1.31, 23.201(A), 23.202(A)(1) AND (B)(1), AND 23.602(A); (III) PAY A CIVIL MONETARYPENALTY IN THE AMOUNT OF $35,000,000; AND (IV) COMPLY WITH CERTAIN UNDERTAKINGS.