Pinnacle Investments, Llc

Allegations: NEGLIGENCE, UNSUITABLE INVESTMENTS AND STRATEGY, BREACH OF CONTRACT, BREACH OF FIDUCIARY DUTY, NEGLIGENCE AND GROSS NEGLIGENCE, NEGLIGENT MISREPRESENTATION, NEGLIGENT SUPERVISION/HIRING Status: Final Summary: CLIENT MADE THE ABOVE ALLEGATIONS BASED UPON INVESTMENTS IN PRIVATE PLACEMENTS AND UNSUITABLE INVESTMENT STRATEGY.

Allegations: WHETHER THERE WAS ADEQUATE DISCLOSURE ABOUT PINNACLE'S SUPERVISORY REVIEW OF ADVISORY ACCOUNTS THAT DID NOT HAVE ACTIVE TRADING BETWEEN 2015 AND 2018. BETWEEN 2017 AND 2020, PINNACLE DID NOT DISCLOSE A CONFLICT OF INTEREST INVOLVING AN INDIVIDUAL FINANCIAL ADVISOR WHO WORKED FOR BOTH PINNACLE INVESTMENTS AND PINNACLE CAPITAL MANAGEMENT. THAT PINNACLE PREVIOUSLY NEGLECTED TO DISTRIBUTE ITS FORM ADV PART 2B SUPPLEMENT TO CLIENTS. Status: Final Sanction Detail: RESPONDENT SHALL PAY DISGORGEMENT OF $83,462, PREJUDGMENT INTEREST OF $11,874 AND CIVIL PENALTIES OF $393,381 TO THE SECURITIES AND EXCHANGE COMMISSION. IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO SEC RULE OF PRACTICE 600. PAYMENT SHALL BE MADE IN THE FOLLOWING INSTALLMENTS: 1. DUE WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER: $122,179.25; 2. DUE WITHIN 90 DAYS OF THE ENTRY OF THIS ORDER: $122,179.25; 3. DUE WITHIN 180 DAYS OF THE ENTRY OF THIS ORDER: $122,179.25; AND 4. THE REMAINDER WITHIN 365 DAYS AFTER THE ENTRY OF THIS ORDER Summary: PINNACLE ALSO ENGAGED A COMPLIANCE CONSULTANT FOR A PERIOD OF ONE YEAR PER THE ORDER. THE CONSULTANT WILL PROVIDE 2 REPORTS TO THE SEC REGARDING PINNACLE'S POLICIES AND PROCEDURES AS IT RELATES TO ITEMS IN THE ORDER. THE REPORTS WILL BE SEMI-ANNUAL AND A FINAL REPORT AFTER THE ENGAGEMENT PERIOD HAS CONCLUDED.