G. A. Repple & Company

Allegations: FINRA ALLEGES THAT THE FIRM'S SYSTEM OF EMAIL MONITORING AND STORAGE DID NOT COMPLY WITH SEC RULE 17A-4 AND THAT WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO ASSURE COMPLIANCE. Status: Final Sanction Detail: FIRM PAID $25,000 FINE ON 9/25/2007. AWC ACCEPTED 10/22/2007. Summary: FIRM EMPLOYS INDEPENDENT CONTRACTOR REPRESENTATIVES. FIRM ATTEMPTED TO COMPLY BY ENGAGING THIRD PARTY EMAIL MONITORING VENDOR. DUE TO COMPLICATIONS IN CONVERTING UNIQUE EMAILS TO MONITORED SYSTEM THE PROJECT TOOK LONGER THAN PROJECTED AND WAS ONLY 90% COMPLETED AT THE TIME OF THE 2006 AUDIT. PROJECT WAS 100% COMPLETED WITHIN 30 DAYS AFTER AUDIT.

Allegations: FIRM'S WSP CALL FOR ALL OSJ OFFICES TO BE INSPECTED ANNUALLY. FIRM MISSED INSPECTING OFFICES IN 2003& 2004. FIRM ALSO FAILED TO REQUIRE CERTAIN REPRESENTATIVES TO ATTEND AN ANNUAL COMPLIANCE SESSION. Status: Final Sanction Detail: FIRM PAID FULL AMOUNT OF $5,000 FINE ON 1/13/2006. Summary: NASD AUDIT IN AUGUST 2004 FOUND THAT FIRM MISSED INSPECING ONE OFFICE IN 2002 AND FIVE OFFICES IN 2003. HOWEVER, TWO OF THESE OFFICES WERE NOT OSJ'S AT THAT TIME AND ONE ISPECTION WAS POSTPONED DUE TO THE HOSPITALIZATION OF BRANCH MANAGER AND COULD NOT BE COMPLETED WITHIN THE SAME CALENDAR YEAR. THIS INSPECTION WAS COMPLETED WITHIN 40 DAYS AFTER THE ORIGINALLY SCHEDULED DATE. ALL REQUIRED INSPECTIONS FOR 2004 AND 2005 WERE COMPLETED. NASD FOUND CERTAIN REPRESENTATIVES WERE NOT REQUIRED TO ATTEND MAKE-UP MEETINGS IN 2002 AND IN 2003, AFTER MISSING THE PRIMARY COMPLIANCE SESSION. ALL REPRESENTATIVES HAVE ATTENDED THE REQUIRED COMPLIANCE MEETINGS IN 2004 AND 2005. ATTENDANCE FOR BOTH YEARS HAS BEEN DOCUMENTED IN GOOD ORDER.

Allegations: G.A. REPPLE & COMPANY FAILED TO REPORT TO THE INSURANCE COMMISSIONER ANY ADMINISTRATIVE ACTION TAKEN AGAINST IT IN ANOTHER JURISDICTION OR BY ANOTHER GOVERNMENTAL AGENCY WITHIN 30 DAYS OF FINAL DISPOSITION AS REQUIRED BY 18 DEL.C. &1719(A). Status: Final Sanction Detail: G.A. REPPLE & COMPANY'S PRODUCER LICENSE SUSPENDED FOR A PERIOD OF ONE YEAR. DELAWARE INSURANCE DEPARTMENT AGREED TO WAIVE THE SUSPENSION PERIOD UPON PAYMENT OF A FINE OF $250.00. G.A. REPPLE & COMPANY PAID DELAWARE INSURANCE DEPARTMENT $250.00 WITH A CHECK DATED 9/13/10.

Allegations: ALLEGES G.A. REPPLE FAILED TO REASONABLY SUPERVISE ITS AGENT, ALAN SIEGEL, IN CONNECTION WITH FALSE INFORMATION POSTED TO HIS WEBSITE Status: Final Sanction Detail: FIRM PAID $25,000 WITH CHECK DATED 9/26/2018.

Allegations: IN 2011, G.A. REPPLE & COMPANY AND GLENN REPPLE PROVIDED MATERIALLY INCORRECT AND UNTRUE INFORMATION WITHIN THE MEANING OF SECTION 2110(A)(2) OF THE INSURANCE LAW ON THE RENEWAL APPLICATION FOR AN AGENT'S LICENSE BY FAILING TO DISCLOSE ADMINISTRATIVE ACTIONS, IMPOSITION OF MONETARY PENALTIES AGAINST G.A. REPPLE & COMPANY BY ANY OTHER STATE OR REGULATORY BODY. THE EVENTS AT ISSUE WITH NEW YORK OCCURRED BETWEEN OCTOBER 18, 2007 AND NOVEMBER 8, 2010. Status: Final Sanction Detail: G.A. REPPLE & COMPANY PAID $3,000.00 BY CHECK DATED OCT. 21, 2011.

Allegations: G.A. REPPLE & COMPANY FAILED TO TIMELY REPORT WITHIN 30 DAYS OF THE HAPPENING OF VARIOUS EVENTS, INCLUDING THE IMPOSITION OF A MONETARY FINE BY ANY OTHER STATE OR ANY VIOLATION OF THE INSURANCE OR RELATED LAWS OF THAT STATE AS REQUIRED BY RULE 482-1-054-.03 WITHIN ALABAMA INSURANCE REGULATION. IN ADDITION, FOR PURPOSES OF ALABAMA CODE 27-7-19(A)(9), G.A. REPPLE & COMPANY PROVIDED INCORRECT INFORMATION IN QUESTION (2) OF THE NAIC UNIFORM APPLICATION FOR BUSINESS ENTITY INSURANCE LICENSE RENEWAL/CONTINUATION SUBMITTED IN OCTOBER, 2010 RELATED TO BE NAMED OR INVOLVE IN ANY ADMINISTRATIVE PROCEEDING REGARDING ANY PROFESSIONAL, OCCUPATIONAL LICENSE OR REGISTRATION. Status: Final Sanction Detail: G.A. REPPLE PAID STATE OF ALABAMA DEPARTMENT OF INSURANCE $300.00 WITH A CHECK DATED NOV. 4, 2010.

Allegations: ON SEPTEMBER 30, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR, DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS. WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER-COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. Status: Final Sanction Detail: G. A. REPPLE & COMPANY PLACED THE FOLLOWING INTO ESCROW TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. Summary: ON SEPTEMBER 30, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR, DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS. WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER-COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.