Willow Asset Management Llc

Allegations: THE SEC ORDER RELATED TO A SINGLE LEGACY VESSEL DECONSTRUCTION SECURITY OFFERING THAT WAS EXPOSED TO UNDERLYING BORROWER DEFAULTS. THE ORDER STATES THAT YIELDSTREET FAILED TO DISCLOSE TO INVESTORS A HEIGHTENED RISK THAT IT WOULD BE UNABLE TO SEIZE THE SHIP SERVING AS COLLATERAL FOR THE LOAN UNDERLYING THE OFFERING, IN THE EVENT OF A DEFAULT. ALTHOUGH YIELDSTREET REACHED A SETTLEMENT WITH THE SEC, YIELDSTREET NEITHER ADMITS NOR DENIES ANY WRONGDOING. WE FULLY COOPERATED WITH THE SEC'S INQUIRY AND ARE PLEASED TO HAVE REACHED A RESOLUTION OF THESE ISSUES. THE SEC'S ORDER ACKNOWLEDGES YIELDSTREET'S COOPERATION AND REMEDIAL EFFORTS. Status: Final Sanction Detail: YIELDSTREET AGREED TO PAY A FINE OF APPROXIMATELY $1.32 MILLION WHICH WILL BE PAID DIRECTLY TO INVESTORS THROUGH A FAIR FUND. YIELDSTREET DEPOSITED THE MONEY INTO THE FAIR FUND ON SEPTEMBER 22, 2023. YIELDSTREET ALSO AGREED TO WAIVE APPROXIMATELY $600,000 IN FEES RELATED TO THE SECURITIES OFFERING AT ISSUE. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. THE FULL AMOUNT OF THE DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL MONEY PENALTIES WAS PAID INTO THE ESCROW ACCOUNT WITHIN 10 DAYS OF THE ENTRY OF THE ORDER. WITHIN 90 DAYS FROM THE DATE OF THE ORDER, YIELDSTREET MUST SUBMIT A DISBURSEMENT CALCULATION TO THE COMMISSION FOR REVIEW AND APPROVAL. WITHIN 30 DAYS OF THE WRITTEN APPROVAL OF THE CALCULATION BY THE COMMISSION STAFF, YIELDSTREET MUST SUBMIT A PAYMENT FILE FOR REVIEW AND ACCEPTANCE BY THE COMMISSION STAFF DEMONSTRATING THE APPLICATION OF THE METHODOLOGY TO EACH AFFECTED ADVISORY CLIENT. TITAN MUST DISBURSE ALL AMOUNTS PAYABLE TO AFFECTED ADVISORY CLIENTS WITHIN 90 DAYS OF THE DATE THE COMMISSION STAFF ACCEPTS THE PAYMENT FILE.