Ars Investment Partners, Llc

Allegations: BOOKS AND RECORDS VIOLATION(S) EXCESSIVE MARK-UPS OR COMMISSION Status: Final Sanction Detail: DISPOSITION RESULTED IN A FINE OF $2902.00 WHICH WAS PAID IN MARCH 1976. Summary: DISPOSITION RESULTED IN A FINE OF $2500.00 PLUS ASSESSED COSTS IN THE AMOUNT OF $402.00.RESPONDENT TOOK IMMEDIATE ACTION TO COMPLY WITH THE FINDINGS OF THE BOARD AT THE TIME OF THE DECISION AND PAID THE AMOUNT OF $2902.00 IN MARCH 1976.

Allegations: IN 2008, THE FIRM FAILED TO REPORT ON A TIMELY BASIS, AND OR FAILED TO REPORT THE CORRECT TIME OF TRADE, AND FAILED TO SUPERVISE THE REPORTING OF CERTAIN BOND TRANSACTIONS PURSUANT TO THE TRACE CORPORATE BOND REPORTING RULES AS PROMULGATED BY FINRA. SUBSEQUENT TO FINRA'S FINDINGS, A.R. SCHMEIDLER & CO. INC. HAS REVISED ITS POLICIES AND PROCEDURES TO ADDRESS THE TRACE REPORTING DEFICIENCIES. Status: Final Sanction Detail: THE FINE OF $15,000 WAS PAID ON NOVEMBER 5, 2010 BY A.R. SCHMEIDLER & CO. INC. Summary: -IN 2008, THE FIRM FAILED TO REPORT ON A TIMELY BASIS, AND OR FAILED TO REPORT THE CORRECT TIME OF TRADE, AND FAILED TO SUPERVISE THE REPORTING OF CERTAIN BOND TRANSACTIONS PURSUANT TO THE TRACE CORPORATE BOND REPORTING RULES AS PROMULGATED BY FINRA. SUBSEQUENT TO FINRA'S FINDINGS, A.R. SCHMEIDLER & CO. INC. HAS REVISED ITS POLICIES AND PROCEDURES TO ADDRESS THE TRACE REPORTING DEFICIENCIES. -SANCTIONS ORDERED INCLUDED: A CENSURE; A FINE OF $10,000 FOR THE TRACE REPORTING VIOLATIONS AND $5,000 FOR THE SUPERVISION VIOLATIONS; AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE AREA OF TRACE REPORTING AND THE SUPERVISORY PROCEDURES RELATED TO TRACE REPORTING. -THE FINE OF $15,000 WAS PAID ON NOVEMBER 5, 2010 BY A.R. SCHMEIDLER & CO. INC.

Allegations: FINRA ALLEGED THAT FROM JANUARY 1 TO JULY 22, 2010, CERTAIN REPORTABLE ORDER EVENTS WERE REPORTED TO FINRA'S ORDER AUDIT TRAIL SYSTEM UNDER A CLEARING FIRM'S IDENTIFIER, RATHER THAN THE FIRM'S IDENTIFIER, AND THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM FOR SUCH REPORTING. AS A RESULT, DURING THE REVIEW PERIOD, 135 DAYS, THE FIRM FAILED TO TRANSMIT 1,681 ROES WHICH CONSTITUTED 89.8% OF ALL ROES THAT THE FIRM WAS REQUIRED TO TRANSMIT TO OATS. THE AFOREMENTIONED IS A VIOLATION OF FINRA RULE 7450. THE SUPERVISORY PROCEDURES FAILED TO IDENTIFY A THE PERSON WHO WAS RESPONSIBLE FOR THE OATS REPORTING; THE STEPS TO BE TAKEN TO MONITOR OATS REPORTING; THE FREQUENCY OF THE OATS SUPERVISION; AND A STATEMENT OF HOW THE SUPERVISORY PROCEDURES WOULD BE DOCUMENTED. THE AFORMENTIONED IS A VIOLATION OF NASD RULE 3010 AND FINRA RULE 2010. Status: Final Sanction Detail: A CENSURE AND AN $11,000 FINE (CONSISTING OF A $6,0000 FINE FOR OATS REPORTING VIOLATIONS AND A $5,000 FINE FOR SUPERVISION VIOLATIONS)THE FINE WAS PAID ON MAY 23, 2012 Summary: FINRA ALLEGED THAT FROM JANUARY 1 TO JULY 22, 2010, CERTAIN REPORTABLE ORDER EVENTS WERE REPORTED TO FINRA'S ORDER AUDIT TRAIL SYSTEM UNDER A CLEARING FIRM'S IDENTIFIER, RATHER THAN THE FIRM'S IDENTIFIER, AND THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM FOR SUCH REPORTING. AS A RESULT, DURING THE REVIEW PERIOD, 135 DAYS, THE FIRM FAILED TO TRANSMIT 1,681 ROES WHICH CONSTITUTED 89.8% OF ALL ROES THAT THE FIRM WAS REQUIRED TO TRANSMIT TO OATS. THE AFOREMENTIONED IS A VIOLATION OF FINRA RULE 7450. THE SUPERVISORY PROCEDURES FAILED TO IDENTIFY A THE PERSON WHO WAS RESPONSIBLE FOR THE OATS REPORTING; THE STEPS TO BE TAKEN TO MONITOR OATS REPORTING; THE FREQUENCY OF THE OATS SUPERVISION; AND A STATEMENT OF HOW THE SUPERVISORY PROCEDURES WOULD BE DOCUMENTED. THE AFORMENTIONED IS A VIOLATION OF NASD RULE 3010 AND FINRA RULE 2010.

Allegations: WITHOUT ADMITTING OR DENYING THE VIOLATIONS, A.R. SCHMEIDLER & CO., INC. CONSENTED TO THE ENTRY OF AN SEC ORDER FINDING THAT A.R. SCHMEIDLER & CO., INC. FAILED TO SEEK BEST EXECUTION FOR CERTAIN CLIENTS AND FAILED TO IMPLEMENT PROCEDURES REASONABLY DESIGNED TO PREVENT BEST EXECUTION VIOLATIONS. Status: Final Sanction Detail: A.R. SCHMEIDLER & CO., INC. SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BY THE SEC ON JULY 31, 2013. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, A.R. SCHMEIDLER & CO., INC. WILL (I) PAY A CIVIL MONETARY PENALTY OF $175,000 AND (II) DISGORGEMENT OF $757,876.88 WITH PRE-JUDGMENT INTEREST OF $78,688.57. A.R. SCHMEIDLER & CO., INC. ALSO AGREED TO BE CENSURED AND AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER. FINALLY, A.R. SCHMEIDLER & CO., INC. AGREED TO ENGAGE A QUALIFIED INDEPENDENT CONSULTANT TO ASSIST IN DEVELOPING AND IMPLEMENTING POLICIES AND PROCEDURES DESIGNED TO PROMOTE COMPLIANCE WITH ITS DUTY TO SEEK BEST EXECUTION FOR ITS ADVISORY CLIENTS. Summary: A.R. SCHMEIDLER & CO., INC. SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BY THE SEC ON JULY 31, 2013. WITHOUT ADMITTING OR DENYING THE VIOLATIONS, A.R. SCHMEIDLER & CO., INC. WILL (I) PAY A CIVIL MONETARY PENALTY OF $175,000 AND (II) DISGORGEMENT OF $757,876.88 WITH PRE-JUDGMENT INTEREST OF $78,688.57. A.R. SCHMEIDLER & CO., INC. ALSO AGREED TO BE CENSURED AND AGREED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER. FINALLY, A.R. SCHMEIDLER & CO., INC. AGREED TO ENGAGE A QUALIFIED INDEPENDENT CONSULTANT TO ASSIST IN DEVELOPING AND IMPLEMENTING POLICIES AND PROCEDURES DESIGNED TO PROMOTE COMPLIANCE WITH ITS DUTY TO SEEK BEST EXECUTION FOR ITS ADVISORY CLIENTS.