Isc Advisors, Inc.

Allegations: THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES. Status: Final Sanction Detail: ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. Summary: THE SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.

Allegations: THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES. Status: Final Sanction Detail: ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. Summary: THE SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.