Ameritas Advisory Services, Llc

Allegations: AN AGENT SOLD, SOLICITED AND/OR NEGOTIATED AMERITAS INSURANCE PRODUCTS IN AN UNFAIR, DECEPTIVE, MISLEADING AND/OR FRAUDULENT MANNER IN VIOLATION OF INSURANCE LAWS OF THE STATE OF NEW JERSEY, AND THAT AMERITAS LIFE INSURANCE CORP. ASSISTED AND/OR FACILITATED THOSE ACTS. Status: Final Sanction Detail: AMERITAS LIFE INSURANCE CORP. SHALL OFFER PENALTY-FREE RESCISSIONS AND FULL REFUNDS OF ALL PAYMENTS AND PREMIUMS INCLUDING ANY WITHDRAWAL CHARGES AND OTHER PAYMENTS OR FEES PAID ON ALL POLICIES AND CONTRACTS IDENTIFIED IN THE ORDER. Summary: MATTER IS RESOLVED.

Allegations: AMERITAS LIFE INSURANCE CORP FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE STATE OF CONNECTICUT'S STATUTORY REQUIREMENTS IN REGARDS TO EIGHT PRODUCERS ACTING AS AGENTS OF AMERITAS WITHOUT THE REQUIRED APPOINTMENT. Status: Final Sanction Detail: MONETARY FINE PAID ON JUNE 25, 2015. Summary: MONETARY FINE PAID ON JUNE 25, 2015.

Allegations: THE KENTUCKY DEPARTMENT OF INSURANCE (THE "DEPARTMENT") ALLEGED THAT AMERITAS LIFE INSURANCE CORP. FAILED TO TIMELY RESPOND TO A CUSTOMER COMPLAINT AND THE DEPARTMENT'S QUESTIONS REGARDING THE SAME AND THEREFORE VIOLATED KENTUCKY REVISED STATUE CHAPTER 304 OF THE KENTUCKY INSURANCE CODE. Status: Final Sanction Detail: AMERITAS LIFE INSURANCE CORP. PAID A CIVIL PENALTY OF $8,000 ON JUNE 18, 2024. Summary: AMERITAS LIFE INSURANCE CORP. WAS ORDERED TO PAY A CIVIL PENALTY OF $8,000.

Allegations: AMERITAS LIFE INSURANCE CORP FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE STATE OF CONNECTICUT'S STATUTORY REQUIREMENTS IN REGARDS TO TWENTY-ONE PRODUCERS ACTING AS AGENT OF AMERITAS WITHOUT THE REQUIRED APPOINTMENT. Status: Final Sanction Detail: AMERITAS LIFE INSURANCE CORP PROVIDED THE INSURANCE COMMISSION WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE STATUTES IN THE AREA OF CONCERNS, AS REQUIRED BY THE STIPULATION/CONSENT AND PAID THE MONETARY FINE ON 3/1/22. Summary: AMERITAS LIFE INSURANCE CORP FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE STATE OF CONNECTICUT'S STATUTORY REQUIREMENTS IN REGARDS TO TWENTY-ONE PRODUCERS ACTING AS AGENT OF AMERITAS WITHOUT THE REQUIRED APPOINTMENT.

Allegations: AMERITAS LIFE INSURANCE CORP FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE STATE OF CONNECTICUT'S STATUTORY REQUIREMENTS IN REGARDS TO ONE PRODUCER ACTING AS AGENT OF AMERITAS WITHOUT THE REQUIRED APPOINTMENT. Status: Final Sanction Detail: AMERITAS LIFE INSURANCE CORP PROVIDED THE INSURANCE COMMISSION WITH A SUMMARY OF ACTIONS TAKEN TO COMPLY WITH THE STATUTES IN THE AREA OF CONCERNS, AS REQUIRED BY THE STIPULATION/CONSENT AND PAID THE MONETARY FINE. Summary: AMERITAS LIFE INSURANCE CORP FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH THE STATE OF CONNECTICUT'S STATUTORY REQUIREMENTS IN REGARDS TO ONE PRODUCER ACTING AS AGENT OF AMERITAS WITHOUT THE REQUIRED APPOINTMENT.

Allegations: AMERITAS ADVISORY SERVICES, LLC'S PREDECESSOR FIRM, AMERITAS INVESTMENT COMPANY, LLC, FAILED TO REGISTER AT LEAST ONE EMPLOYEE IN PA AS AN INVESTMENT ADVISER REPRESENTATIVE FROM JANUARY 2015 THROUGH JUNE 2019 IN VIOLATION OF THE PA SECURITIES ACT OF 1972. Status: Final Sanction Detail: AMERITAS INVESTMENT COMPANY, LLC WAS ORDERED TO PAY A $100,000 ADMINISTRATIVE ASSESSMENT TO BE PAID AS FOLLOWS: $8,333.33 WITHIN 30 DAYS OF THE EFFECTIVE DATE OF THE ORDER AND $8,333.33 BY 12/31/20, 1/31/21, 2/28/21, 3/31/21, 4/30/21, 5/31/21, 6/30/21, 7/31/21, 8/31/21, 9/30/21, AND $8,333.37 BY 10/31/21. Summary: CONSENT AGREEMENT AND ORDER ISSUED TO AMERITAS INVESTMENT COMPANY, LLC

Allegations: THE SEC ALLEGED THAT THE ADVISORY FIRM FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING CONFLICTS ASSOCIATED WITH CERTAIN THIRD-PARTY COMPENSATION RECEIVED WHEN THE ADVISORY BUSINESS WAS PART OF AMERITAS INVESTMENT COMPANY, LLC ("AIC"). THE CONFLICTS INCLUDED (1) AIC'S RECEIPT OF REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED CLEARING BROKER ("CLEARING BROKER") AS A RESULT OF ADVISORY CLIENTS' INVESTMENTS IN CERTAIN MUTUAL FUNDS AND MONEY MARKET FUNDS THAT PAID REVENUE SHARING TO THE CLEARING BROKER; (2) MARKUPS ON CLEARING BROKER FEES FOR ADVISORY CLIENTS' TRANSACTION FEES; (3) REVENUE RECEIVED FROM THE CLEARING BROKER ON THE RATE OF MARGIN INTEREST CHARGED TO ADVISORY CLIENTS; AND (4) AN ANNUAL BUSINESS DEVELOPMENT CREDIT FROM THE CLEARING BROKER BASED ON AIC MAINTAINING, WITHIN A RANGE, MINIMUM ACCOUNTS, ASSET BALANCES, AND TRADING VOLUMES IN CERTAIN REVENUE SHARING PAYING MUTUAL FUND PROGRAMS AND MARGIN ACCOUNTS. THE SEC FURTHER ALLEGED THAT THE ADVISORY FIRM BREACHED ITS DUTY TO SEEK BEST EXECUTION BY CAUSING CERTAIN 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 AT A LOWER COST AND BREACHED ITS DUTY OF CARE 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, THE ORDER STATED THAT THE ADVISORY FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND RULES THERE UNDER IN CONNECTION WITH ITS PRACTICES REGARDING MUTUAL FUND AND MONEY MARKET SHARE CLASS SELECTION, FEE MARKUPS, MARGIN INTEREST, BUSINESS DEVELOPMENT CREDITS, AND BEST EXECUTION. Status: Final Sanction Detail: DISGORGEMENT AMOUNT OF $3,334,804 AND PREJUDGMENT INTEREST OF $543,390 PAID TO FAIR FUND ON MARCH 1, 2022. Summary: WITHIN 45 DAYS OF ENTRY OF THE ORDER, THE FIRM MUST EVALUATE WHETHER EXISTING CLIENTS SHOULD BE MOVED TO A LOWER-COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; WITHIN 30 DAYS OF THE ENTRY OF THE ORDER, THE FIRM MUST NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; WITHIN 10 DAYS OF THE ENTRY OF THE ORDER, THE FIRM MUST DEPOSIT $4,628,194 INTO A FAIR FUND FOR DISBURSEMENT TO AFFECTED INVESTORS.

Allegations: AMERITAS ADVISORY SERVICES, LLC'S PREDECESSOR FIRM, AMERITAS INVESTMENT COMPANY, LLC AIC), SELF REPORTED TO THE SEC POTENTIAL VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT BY FAILING TO ADEQUATELY DISCLOSE THE FACT THAT AIC RECEIVED 12B-1 FEES FROM MUTUAL FUNDS HELD IN ADVISORY ACCOUNTS. Status: Final Sanction Detail: AIC WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE INVESTMENT ADVISERS ACT. AIC WAS CENSURED, ORDERED TO PAY DISGORGEMENT OF $3,056,804 AND PREJUDGMENT INTEREST OF $332,370, AND COMPLY WITH UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. Summary: AIC CONSENTED TO AN SEC ORDER STATING THAT AIC WILLFULLY VIOLATED SECTION 206(2) AND SECTION 207 OF THE ADVISERS ACT BY FAILING TO EXPLICITLY DISCLOSE AIC'S CONFLICTS OF INTEREST RELATED TO RECEIPT OF 12B-1 FEES AND ITS RECOMMENDATION OR SELECTION OF 12B-1 FEE PAYING MUTUAL FUNDS IN ADVISORY ACCOUNTS. AIC SELF-REPORTED THIS CONDUCT TO THE SHARE CLASS SELECTION DISCLOSURE (SCSD) INITIATIVE. AIC WAS CENSURED, AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT, ORDERED TO PAY DISGORGEMENT OF $3,056,804 AND PREJUDGMENT INTEREST OF $332,370 TO AFFECTED INVESTORS, AND COMPLY WITH CERTAIN UNDERTAKINGS INCLUDING REVIEWING AND UPDATING, WHERE NECESSARY, THE ADEQUACY OF ALL RELEVANT DISCLOSURE DOCUMENTS CONCERNING MUTUAL FUND SHARE CLASS SELECTION AND 12B-1 FEES. EVALUATING WHETHER EXISTING CLIENTS SHOULD BE MOVED TO LOWER COST SHARE CLASSES, AS WELL AS REVIEWING ITS POLICIES AND PROCEDURES TO ENSURE THAT THEY ARE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT IN CONNECTION WITH THE DISCLOSURES REGARDING MUTUAL FUND SHARE CLASS SELECTION. THE SCSD INITIATIVE WAS A VOLUNTARY INITIATIVE IN WHICH THE SEC ENCOURAGED INVESTMENT ADVISERS TO SELF-REPORT VIOLATIONS INVOLVING RECEIPT OF 12B-1 FEES AND ADEQUACY OF THE DISCLOSURES ARISING FROM THE RESULTING CONFLICTS OF INTEREST.