The Putney Financial Group Llc

Allegations: IN RESPONSE TO A SELF REPORTING INITIATIVE, AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO JUNE 7, 2018, THE FIRM PURCHASED, RECOMMENDED, OR HELD FOR ITS ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH OUR CLIENTS WERE ELIGIBLE, ALTHOUGH THESE SHARES WERE ALWAYS DELIVERED AT NET ASSET VALUE (NAV). THE FIRM RECEIVED 12B-1 FEES AS A RESULT OF THESE INVESTMENTS. THIS PRACTICE SHOULD HAVE BEEN DISCLOSED TO THE FIRM'S CLIENTS IN ITS FORM ADV BUT WAS NOT. THE FIRM SELF-REPORTED ITS ERROR TO THE SEC AND SETTLED THE MATTER. THE SEC DID NOT IMPOSED ANY CIVIL PENALTIES UPON THE FIRM FOR ITS ERROR. Status: Final Sanction Detail: THE FIRM PAID DISGORGEMENT AND PREJUDGMENT INTEREST TOTALING $43,034.83 TO ITS AFFECTED CLIENTS. THIS WAS A RESPONSE TO A SELF-REPORTING INITIATIVE. Summary: THE MATTER IS FULLY SETTLED.

Allegations: IN 2024, THE SEC ALLEGED THAT RAYMOND LAWRENCE LENT (DBA THE PUTNEY FINANCIAL GROUP) ("PUTNEY"), A SOLE PROPRIETOR, VIOLATED SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") IN CONNECTION WITH THE RECEIPT OF THIRD-PARTY COMPENSATION IN THE FORM OF BOTH REVENUE SHARING AND SALES COMMISSIONS FROM ITS CLIENTS WITHOUT FULLY AND FAIRLY DISCLOSING THE CONFLICT OF INTERESTS, AND VIOLATED SECTION 206(4) OF THE ADVISERS ACT BY FAILING TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT. Status: Final Sanction Detail: TOTAL AMOUNT OF CIVIL PENALTIES AND DISGORGEMENT IS $1,065,366.18. THE DISGORGEMENT AMOUNT OF $890,360.18 WAS PAID MAY 28, 2024. THE CIVIL PENALTY OF $175,000.00 IS NOT DUE UNTIL NOVEMBER 18, 2024. Summary: ON FEBRUARY 28, 2024, PUTNEY SUBMITTED AN OFFER OF SETTLEMENT ("OFFER") TO THE SEC, WHICH THE SEC DETERMINED TO ACCEPT. ON MAY 20, 2024, PURSUANT TO THE OFFER, THE SEC ENTERED AN ORDER AGAINST PUTNEY INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. PUTNEY WAS CENSURED AND WAS REQUIRED TO PAY CIVIL PENALTIES AND DISGORGEMENT OF $1,065,366.18.