Bolton Securities Corp

Allegations: THE SECURITIES AND EXCHANGE COMMISSION CHARGED BOLTON SECURITIES CORPORATION D/B/A BOLTON GLOBAL ASSET MANAGEMENT, A REGISTERED INVESTMENT ADVISER AND BROKER-DEALER, WITH FAILING TO DISCLOSE MATERIAL CONFLICTS OF INTEREST RELATED TO MUTUAL FUND 12B-1 FEES AND PRINCIPAL TRADING COMPENSATION GENERATED FROM CLIENT INVESTMENTS. Status: Final Summary: THE FIRM, IN ITS CAPACITY AS A FEDERALLY-REGISTERED INVESTMENT ADVISER, WITHOUT ADMITTING OR DENYING ANY WRONGDOING, RESOLVED A MATTER WITH THE SEC CONCERNING THE DISCLOSURE OF COMPENSATED PAID TO THE FIRM OR AN AFFILIATE: (1) UNDER RULE 12B-1; AND (2) IN ITS PRINCIPAL CAPACITY IN CERTAIN TRANSACTIONS. THIS MATTER RESULTED FROM THE SEC'S GLOBAL SHARE CLASS SELECTION DISCLOSURE INITIATIVE AND NOT ANY ACTS OR PRACTICES UNIQUE TO THE FIRM.

Allegations: THE COMPLAINT GENERALLY ALLEGES THAT BOLTON SECURTIES CORP AND/OR RAYMOND GRENIER FILED AN INCOMPLETE, FALSE OR MISLEADING APPLICATION IN FILINGS OF ITS FORM ADV WITH THE MASSACHUSETTS DIVISION OF SECURITIES. Status: Final Sanction Detail: ADVISORY AFFILIATE MARY GRENIER WILL NOT ENGAGE IN ANY SUPERVISORY ACTIVITIES FOR A PERIOD OF 60 DAYS COMMENCING ON MARCH 22, 2007. Summary: ON MARCH 22, 2007, BOLTON SECURITIES CORPORATION ("BOLTON") AND THE MASSACHUSETTS DIVISION OF SECURITIES, AGREED TO A CONSENT ORDER RESOLVING THE ADMINISTRATIVE COMPLAINT FILED ON JULY 25, 2006 NAMING BOLTON AND RAYMOND L. GRENIER. THE ORDER OF MARCH 22, 2007 CONCLUDED THIS MATTER WITHOUT ANY FINDINGS OR THE IMPOSITION OF ANY SANCTIONS AGAINST RAYMOND L. GRENIER. IN THE CONSENT ORDER, BOLTON AGREED TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF THE MASSACHUSETTS UNIFORM SECURITIES ACT, TO HIRE AN INDEPENDENT CONSULTANT TO REVIEW ITS FORM ADV AND TO THE PAYMENT OF INVESTIGATION COSTS. IN ADDITION, ADVISORY AFFILIATE MARY GRENIER WILL NOT ENGAGE IN AN SUPERVISORY DUTIES OR ACTIVITIES FOR A PERIOD OF 60 DAYS.