Bill Few Associates, Inc.

Allegations: BILL FEW ASSOCIATES, INC. WAS PREVIOUSLY DUALLY REGISTERED AS A BROKER/DEALER AND AN INVESTMENT ADVISER IN PENNSYLVANIA. AS SUCH, THE FIRM UTILIZED A REGISTRATION EXEMPTION AFFORDED DUALLY REGISTERED FIRMS TO ELIMINATE DUPLICATE REGISTRATIONS FOR INDIVIDUALS THAT WERE BOTH REPRESENTATIVES OF THE BROKER/DEALER AND REPRESENTATIVES OF THE INVESTMENT ADVISER. A SUBSEQUENT RESTRUCTURING OF THE FIRM CREATED A SEPARATE ENTITY, BILL FEW SECURITIES, INC., TO CONDUCT ITS BROKER/DEALER BUSINESS. AT THE TIME OF THIS RESTRUCTURING, THE REGISTRATION EXEMPTION PREVIOUSLY AFFORDED BILL FEW ASSOCIATES, INC. WAS NO LONGER APPLICABLE. AS A RESULT, BILL FEW ASSOCIATES, INC. INADVERTENTLY VIOLATED THE PENNSYLVANIA SECURITIES ACT OF 1972, SECTION 301(C.1)(1)(II), BY NOT HAVING ALL ADVISER REPRESENTATIVES PROPERLY REGISTERED WITH THE STATE. UPON DISCOVERING THE ERROR, BILL FEW ASSOCIATES, INC. PROMPTLY NOTIFIED THE PENNSYLVANIA BUREAU OF SECURITIES LICENSING AND SUBMITTED THE APPROPRIATE REGISTRATIONS. Status: Final Sanction Detail: N/A Summary: THE ADMINISTRATIVE ASSESSMENT WAS PAID IN FULL BY THE END OF 2014.

Allegations: BREACH OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES ITS AFFILIATED BROKER AND ITS ASSOCIATED PERSONS RECEIVED PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940. AT TIMES DURING THE PERIOD OF JANUARY 1, 2014 TO MARCH 29, 2019 (THE "REVELANT PERIOD"), BILL FEW ASSOCIATES, INC. (BFA) 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 FOR WHICH THE CLIENTS WERE ELIGIBLE. BFA FAILED TO ADEQUATELY DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, BFA'S AFFILIATED BROKER AND ITS ASSOCIATED PERSONS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. Status: Final Sanction Detail: BILL FEW ASSOCIATES, INC. SHALL PAY DISGORGEMENT OF $2,201,454.07 PLUS PREJUDGMENT INTEREST OF $191,850,74. ($2,393,304.81 TOTAL) IN THREE EQUAL INSTALLMENTS WITHIN THE NEXT 18 MONTHS. Summary: BILL FEW ASSOCIATES, INC. (BFA) SELF-REPORTED TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). BFA ACKNOWLEDGES THAT THE COMMISSION IS NOT IMPOSING A CIVIL PENALTY BASED UPON BFA'S SELF-REPORT IN THE SCSD INITIATIVE. BFA WAS ORDERED TO REVIEW AND CORRECT (AS NECESSARY) ALL RELEVANT DISCLOSURE DOCUMENTS AND ALL POLICIES AND PROCEDURES CONCERNING MUTUAL FUND SHARE CLASS SELECTION AND 12B-1 FEES, AND NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS OF THE SEC'S ORDER.