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BrokerCheck Report KYLE PATRICK HARRINGTON Section Title Report Summary Broker Qualifications Registration and Employment History Disclosure Events CRD# 2282328 1 2 - 3 5 - 6 7 Page(s)

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Page 1: KYLE PATRICK HARRINGTON · KYLE P. HARRINGTON CRD# 2282328 This broker is not currently registered. Report Summary for this Broker This report summary provides an overview of the

BrokerCheck Report

KYLE PATRICK HARRINGTON

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 2282328

1

2 - 3

5 - 6

7

Page(s)

Page 2: KYLE PATRICK HARRINGTON · KYLE P. HARRINGTON CRD# 2282328 This broker is not currently registered. Report Summary for this Broker This report summary provides an overview of the

About BrokerCheck®

BrokerCheck offers information on all current, and many former, registered securities brokers, and all current and formerregistered securities firms. FINRA strongly encourages investors to use BrokerCheck to check the background ofsecurities brokers and brokerage firms before deciding to conduct, or continue to conduct, business with them.

· What is included in a BrokerCheck report?· BrokerCheck reports for individual brokers include information such as employment history, professional

qualifications, disciplinary actions, criminal convictions, civil judgments and arbitration awards. BrokerCheckreports for brokerage firms include information on a firm’s profile, history, and operations, as well as many of thesame disclosure events mentioned above.

· Please note that the information contained in a BrokerCheck report may include pending actions orallegations that may be contested, unresolved or unproven. In the end, these actions or allegations may beresolved in favor of the broker or brokerage firm, or concluded through a negotiated settlement with no admissionor finding of wrongdoing.

· Where did this information come from?· The information contained in BrokerCheck comes from FINRA’s Central Registration Depository, or

CRD® and is a combination of: o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers and

brokerage firms to submit as part of the registration and licensing process, and o information that regulators report regarding disciplinary actions or allegations against firms or brokers.

· How current is this information?· Generally, active brokerage firms and brokers are required to update their professional and disciplinary

information in CRD within 30 days. Under most circumstances, information reported by brokerage firms, brokersand regulators is available in BrokerCheck the next business day.

· What if I want to check the background of an investment adviser firm or investment adviserrepresentative?

· To check the background of an investment adviser firm or representative, you can search for the firm orindividual in BrokerCheck. If your search is successful, click on the link provided to view the available licensingand registration information in the SEC's Investment Adviser Public Disclosure (IAPD) website athttps://www.adviserinfo.sec.gov. In the alternative, you may search the IAPD website directly or contact your statesecurities regulator at http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/P455414.

· Are there other resources I can use to check the background of investment professionals?· FINRA recommends that you learn as much as possible about an investment professional before deciding

to work with them. Your state securities regulator can help you research brokers and investment adviserrepresentatives doing business in your state.

·Thank you for using FINRA BrokerCheck.

For more information aboutFINRA, visit www.finra.org.

Using this site/information meansthat you accept the FINRABrokerCheck Terms andConditions. A complete list ofTerms and Conditions can befound at

For additional information aboutthe contents of this report, pleaserefer to the User Guidance orwww.finra.org/brokercheck. Itprovides a glossary of terms and alist of frequently asked questions,as well as additional resources.

brokercheck.finra.org

Page 3: KYLE PATRICK HARRINGTON · KYLE P. HARRINGTON CRD# 2282328 This broker is not currently registered. Report Summary for this Broker This report summary provides an overview of the

KYLE P. HARRINGTON

CRD# 2282328

This broker is not currently registered.

Report Summary for this Broker

This report summary provides an overview of the broker's professional background and conduct. Additionalinformation can be found in the detailed report.

Disclosure Events

All individuals registered to sell securities or provideinvestment advice are required to disclose customercomplaints and arbitrations, regulatory actions,employment terminations, bankruptcy filings, andcriminal or civil judicial proceedings.

Are there events disclosed about this broker? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 2

Customer Dispute 9

Termination 2

Investment Adviser RepresentativeInformation

https://www.adviserinfo.sec.gov

The information below represents the individual'srecord as a broker. For details on this individual'srecord as an investment adviser representative,visit the SEC's Investment Adviser PublicDisclosure website at

Broker Qualifications

This broker is not currently registered.

This broker has passed:

1 Principal/Supervisory Exam

2 General Industry/Product Exams

2 State Securities Law Exams

Registration History

This broker was previously registered with thefollowing securities firm(s):

AURORA CAPITAL LLCCRD# 37924BRIDGEHAMPTON,, NY12/2016 - 07/2018

B

NATIONAL SECURITIES CORPORATIONCRD# 7569SAN DIEGO, CA07/2012 - 11/2016

B

BANNOCKBURN PARTNERS, LLCCRD# 109761SYOSSET, NY03/2012 - 07/2012

B

www.finra.org/brokercheck User Guidance

1�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Broker Qualifications

Registrations

This section provides the self-regulatory organizations (SROs) and U.S. states/territories the broker is currently registered and licensed with, thecategory of each license, and the date on which it became effective. This section also provides, for every brokerage firm with which the broker iscurrently employed, the address of each branch where the broker works.

This broker is not currently registered.

2�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Broker Qualifications

Industry Exams this Broker has Passed

This individual has passed 1 principal/supervisory exam, 2 general industry/product exams, and 2 state securities law exams.

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a broker may attain a registrationafter receiving an exam waiver based on exams the broker has passed and/or qualifying work experience. Any exam waivers that the broker hasreceived are not included below.

Exam Category Date

Principal/Supervisory Exams

General Securities Principal Examination 07/14/2009Series 24B

Exam Category Date

General Industry/Product Exams

Securities Industry Essentials Examination 07/18/2018SIEB

General Securities Representative Examination 08/13/1993Series 7B

Exam Category Date

State Securities Law Exams

Uniform Investment Adviser Law Examination 10/30/2002Series 65IA

Uniform Securities Agent State Law Examination 09/20/1993Series 63B

Additional information about the above exams or other exams FINRA administers to brokers and other securities professionals can be found atwww.finra.org/brokerqualifications/registeredrep/.

3�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Broker Qualifications

Professional Designations

This section details that the representative has reported 0 professional designation(s).

No information reported.

4�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Registration and Employment History

Registration History

Registration Dates Firm Name CRD# Branch Location

The broker previously was registered with the following firms:

B 12/2016 - 07/2018 AURORA CAPITAL LLC 37924 BRIDGEHAMPTON,, NY

B 07/2012 - 11/2016 NATIONAL SECURITIES CORPORATION 7569 SAN DIEGO, CA

B 03/2012 - 07/2012 BANNOCKBURN PARTNERS, LLC 109761 SYOSSET, NY

B 12/2009 - 11/2011 MATRIX CAPITAL GROUP, INC. 33364 NEW YORK, NY

B 02/2008 - 12/2009 FIRST ALLIED SECURITIES, INC. 32444 LA JOLLA, CA

B 07/2007 - 02/2008 ROBERT B. AUSDAL & CO. INC. 7995 LA JOLLA, CA

B 06/2005 - 06/2007 DEUTSCHE BANK SECURITIES INC. 2525 SAN FRANCISCO, CA

B 07/2003 - 06/2005 WACHOVIA SECURITIES, LLC 19616 ST. LOUIS, MO

B 07/2002 - 07/2003 PRUDENTIAL SECURITIES INCORPORATED 7471 NEW YORK, NY

B 07/1999 - 07/2002 CIBC WORLD MARKETS CORP. 630 NEW YORK, NY

B 09/1998 - 05/1999 BANCBOSTON ROBERTSON STEPHENSINC.

41271 SAN FRANCISCO, CA

B 07/1998 - 09/1998 BANCAMERICA ROBERTSON STEPHENS 17977 SAN FRANCISCO, CA

B 12/1997 - 01/1998 MERRILL LYNCH, PIERCE, FENNER &SMITH INCORPORATED

7691 NEW YORK, NY

B 08/1997 - 09/1997 MORGAN STANLEY & CO., INCORPORATED 8209 NEW YORK, NY

B 08/1996 - 09/1996 GOLDMAN, SACHS & CO. 361 NEW YORK, NY

B 05/1994 - 01/1995 PUTNAM, LOVELL & THORNTON INC. 22698 NEW YORK, NY

B 08/1993 - 02/1994 MERRILL LYNCH, PIERCE, FENNER &SMITH INCORPORATED

7691 NEW YORK, NY

Employment History

5�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Registration and Employment History

Employment History, continued

Employment Employer Name Investment RelatedPosition Employer Location

This section provides up to 10 years of an individual broker's employment history as reported by the individual broker on the most recently filedForm U4.

Please note that the broker is required to provide this information only while registered with FINRA or a national securities exchangeand the information is not updated via Form U4 after the broker ceases to be registered. Therefore, an employment end date of"Present" may not reflect the broker's current employment status.

12/2016 - Present Aurora Capital LLC RegisteredRepresentative

Y Bridgehampton, NY, UnitedStates

02/2008 - Present HARRINGTON CAPITAL MANAGEMENT,LLC

MANAGING MEMBERAND CHIEFCOMPLIANCEOFFICER

Y SAN DIEGO, CA, UnitedStates

08/2012 - 11/2016 NATIONAL ASSET MANAGEMENT, INC. INVESTMENTADVISERREPRESENTATIVE

Y SAN DIEGO, CA, UnitedStates

06/2012 - 11/2016 NATIONAL SECURITIES CORP REGISTEREDREPRESENTATIVE

Y SAN DIEGO, CA, UnitedStates

02/2012 - 06/2012 BANNOCKBURN PARTNERS, LLC REGISTEREDREPRESENTATIVE

Y NEW YORK, NY, UnitedStates

12/2009 - 11/2011 MATRIX CAPITAL GROUP REGISTEREDREPRESENTATIVE

Y NEW YORK, NY, UnitedStates

Other Business Activities

This section includes information, if any, as provided by the broker regarding other business activities the broker is currently engaged in either asa proprietor, partner, officer, director, employee, trustee, agent or otherwise. This section does not include non-investment related activity that isexclusively charitable, civic, religious or fraternal and is recognized as tax exempt.

(1) HARRINGTON CAPITAL MANAGEMENT, LLC ("HCM") REGISTERED INVESTMENT ADVISOR, 5370 Toscana Way #H115 San Diego CA92122, KYLE HARRINGTON, FOUNDER & MANAGING MEMBER. START DATE: 02/2008. HOURS PER WEEK: APPROXIMATELY 0...(2)LaJOLLA YMCA NOT INVESTMENT RELATED, MEMBER OF THE BOARD OF DIRECTORS START 1/2016 2 HRS PER MONTH ZERO DURINGTRADING HRS...(3) HARRINGTON CAPITAL MANAGEMENT INSURANCE SERVICES, LLC, 5370 Toscana Way #H115 San Diego CA. 92122.PRODUCT: INSURANCE/FIXED ANNUITIES. KYLE HARRINGTON, AGENT. START DATE: 04/2012. HOURS PER WEEK:APPROXIMATELY 1 (4)RESIDENTIAL REAL ESTATE INVESTMENT. OWNER OF THE RESIDENTIAL PROPERTIES, NON INVESTMENTRELATED. STARTED 2000,TIME DEVOTED 4HRS/MTH DURING NON-TRADING HOURS. RESIDENTIAL REAL ESTATE PROPERTY. (5)Appearances on Television & Radio. RECEIVES NOMINAL APPEARANCE FEES. ACTIVITY IS MONITORED AS IF INTERNAL. INVESTMENTRELATED. 2 HOURS PER WEEK. NOT DURING TRADING HOURS.

6�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Disclosure Events

What you should know about reported disclosure events:

1. All individuals registered to sell securities or provide investment advice are required to disclose customer complaints and arbitrations,regulatory actions, employment terminations, bankruptcy filings, and criminal or civil judicial proceedings.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a broker is required to disclose a particular criminal event. o A customer dispute must involve allegations that a broker engaged in activity that violates certain rules or conduct governing the

industry and that the activity resulted in damages of at least $5,000. o

3. Disclosure events in BrokerCheck reports come from different sources: o As mentioned at the beginning of this report, information contained in BrokerCheck comes from brokers, brokerage firms and

regulators. When more than one of these sources reports information for the same disclosure event, all versions of the event willappear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled.

o4. There are different statuses and dispositions for disclosure events:

o A disclosure event may have a status of pending, on appeal, or final.§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter, or (2) an administrative

panel in an action brought by a regulator that is contested by the party charged with some alleged wrongdoing.§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Please note that brokers and

brokerage firms may choose to settle customer disputes or regulatory matters for business or other reasons.§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoing on the part of the

individual broker. Such matters generally involve customer disputes.

For your convenience, below is a matrix of the number and status of disclosure events involving this broker. Further informationregarding these events can be found in the subsequent pages of this report. You also may wish to contact the broker to obtain furtherinformation regarding these events.

Final On AppealPending

Regulatory Event 0 2 0

Customer Dispute 1 8 N/A

Termination N/A 2 N/A

7�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegations that are contested and havenot been resolved or proven. The matter may, in the end, be withdrawn, dismissed, resolved in favor of the broker, or concluded through anegotiated settlement for certain business reasons (e.g., to maintain customer relationships or to limit the litigation costs associated with disputingthe allegations) with no admission or finding of wrongdoing.

This report provides the information exactly as it was reported to CRD and therefore some of the specific data fields contained in the report maybe blank if the information was not provided to CRD.

Regulatory - Final

This type of disclosure event may involve (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulatory such as the Securities and Exchange Commission, foreign financial regulatory body) for a violation ofinvestment-related rules or regulations; or (2) a revocation or suspension of a broker's authority to act as an attorney, accountant, or federalcontractor.

Disclosure 1 of 2

Reporting Source: Regulator

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought: Other: N/A

Date Initiated: 06/23/2017

Docket/Case Number: 2015047303901

Employing firm when activityoccurred which led to theregulatory action:

National Securities Corporation

Product Type: Other: Private Securities Transactions

Allegations: Harrington was named a respondent in a FINRA complaint alleging that heconverted customer funds by intentionally and without authorization taking andexercising ownership over $19,874.64 belonging to one of his customers when heneither owned the property nor was entitled to possess it. The complaint allegesthat Harrington engaged in a series of private securities transactions with at leasttwo individuals through which he sold over 300,000 shares of restricted stock hehad purportedly received as compensation from a company for approximately$276,000. Harrington failed to provide his member firm with prior written notice ofhis private securities transactions, including his proposed role as seller in thetransactions. The complaint also alleges that Harrington lied to his firm when hemischaracterized the purpose of payments received into his bank accounts.Specifically, Harrington falsely characterized three payments received from one ofthe individuals for the purchase of the stock as vacation-rental-by-owner (VRBO)income. Harrington also falsely characterized the $100,000 payment he receivedfrom the other individual for the purchase of stock as a payment from his formerbroker-dealer. In addition, Harrington knowingly caused at least two falsified VRBOrental contracts to be sent to his firm in order to conceal the true purpose of fundshe had received in private securities transactions. The complaint further allegesthat as FINRA began investigating him, Harrington continued to actively concealhis misconduct with the knowing assistance of his assistant. Specifically, atHarrington's direction or with his knowledge and consent, his assistant alteredcertain bank statements requested by FINRA in order to conceal the originator of apayment Harrington received for the stock. Harrington, by and through his attorney,submitted the altered bank statement to FINRA as if it were an authentic, non-altered document. In addition, during his investigative testimony, Harrington falselyand repeatedly insisted that the fake VRBO agreements he had created wereauthentic and represented legitimate rental transactions. Additionally, Harringtonsubmitted to FINRA a written response which falsely stated that he was entitled tothe approximately $20,000 he took from the customer, as payment for investmentadvisory services rendered to her. In addition, the complaint alleges that after helearned that FINRA was investigating his conversion of the customer's funds,Harrington contacted the customer and attempted to have her sign a falsedocument stating that he was entitled to the money he stole.

8�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Harrington was named a respondent in a FINRA complaint alleging that heconverted customer funds by intentionally and without authorization taking andexercising ownership over $19,874.64 belonging to one of his customers when heneither owned the property nor was entitled to possess it. The complaint allegesthat Harrington engaged in a series of private securities transactions with at leasttwo individuals through which he sold over 300,000 shares of restricted stock hehad purportedly received as compensation from a company for approximately$276,000. Harrington failed to provide his member firm with prior written notice ofhis private securities transactions, including his proposed role as seller in thetransactions. The complaint also alleges that Harrington lied to his firm when hemischaracterized the purpose of payments received into his bank accounts.Specifically, Harrington falsely characterized three payments received from one ofthe individuals for the purchase of the stock as vacation-rental-by-owner (VRBO)income. Harrington also falsely characterized the $100,000 payment he receivedfrom the other individual for the purchase of stock as a payment from his formerbroker-dealer. In addition, Harrington knowingly caused at least two falsified VRBOrental contracts to be sent to his firm in order to conceal the true purpose of fundshe had received in private securities transactions. The complaint further allegesthat as FINRA began investigating him, Harrington continued to actively concealhis misconduct with the knowing assistance of his assistant. Specifically, atHarrington's direction or with his knowledge and consent, his assistant alteredcertain bank statements requested by FINRA in order to conceal the originator of apayment Harrington received for the stock. Harrington, by and through his attorney,submitted the altered bank statement to FINRA as if it were an authentic, non-altered document. In addition, during his investigative testimony, Harrington falselyand repeatedly insisted that the fake VRBO agreements he had created wereauthentic and represented legitimate rental transactions. Additionally, Harringtonsubmitted to FINRA a written response which falsely stated that he was entitled tothe approximately $20,000 he took from the customer, as payment for investmentadvisory services rendered to her. In addition, the complaint alleges that after helearned that FINRA was investigating his conversion of the customer's funds,Harrington contacted the customer and attempted to have her sign a falsedocument stating that he was entitled to the money he stole.

Current Status: Final

Resolution: Decision

Resolution Date: 12/31/2018

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Bar (Permanent)DisgorgementMonetary Penalty other than FinesRestitution

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

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(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

10�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

Capacities Affected: All Capacities

Duration: Indefinite

Start Date: 12/31/2018

End Date:

Sanction 1 of 1

Sanction Type: Bar (Permanent)

Monetary Related Sanction: Restitution

Total Amount: $105,000.00

Portion Levied againstindividual:

$105,000.00

Date Paid by individual:

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 1 of 3

Payment Plan: Plus Interest

Is Payment Plan Current:

Monetary Sanction 2 of 3

11�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Regulator Statement Extended Hearing Panel Decision Rendered November 12, 2018. The sanctionsare based on the findings that Harrington converted customer funds, intentionallycausing the customer to wire $19,874.64 of her funds into his account. Thefindings stated that Harrington took the funds for his own use, without thecustomer's authorization, and never returned them. Harrington attempted toobstruct FINRA's investigation into his conversion by contacting the customer andasking her to sign a false document stating that she had stayed at his vacationrental property. The findings also stated that Harrington engaged in privatesecurities transactions, which he was compensated for, without giving prior noticeto or receiving prior written approval from, his member firm. Harrington sold privatesecurities transactions that were outside the regular scope or course of hisemployment to at least two individuals. Harrington did not sell the securitiesthrough his firm and it did not supervise the sales. Further, Harrington wascompensated for charging approximately $276,000 in sales to two purchasers. Thefindings also included that Harrington provided false documents to his firm inconnection with its investigation into whether he had engaged in outside businessactivities. Harrington intentionally misrepresented the nature of payments hereceived and deposited into his bank accounts as rental income and a paymentfrom his former broker dealer. In fact, the payments were for the purchase of stockin Harrington's outside business. Harrington knowingly caused falsified rentalcontracts to be sent to his firm in order to conceal the true purpose of the funds hehad received. FINRA found that Harrington also provided false and misleadingdocuments and information to FINRA in connection with its investigation of theprivate securities transactions and the conversion. Harrington produced a bankstatement to FINRA that his sales assistant, under his direction, altered to removea customer's name as the originator of a wire transfer. Harrington also submitted awritten response to FINRA that falsely represented he was entitled to the funds hedirected the customer to wire to him claiming it was payment for investmentadvisory fees rendered to the customer. Harrington also falsely testified that thepurported rental agreements with another customer were authentic andrepresented legitimate rental transactions. The decision became final onDecember 31, 2018.

Monetary Related Sanction: Monetary Penalty other than Fines

Total Amount: $10,453.21

Portion Levied againstindividual:

$10,453.21

Date Paid by individual:

Was any portion of penaltywaived?

No

Amount Waived:

Payment Plan:

Is Payment Plan Current:

Monetary Related Sanction: Disgorgement

Total Amount: $190,974.64

Portion Levied againstindividual:

$190,974.64

Date Paid by individual:

Was any portion of penaltywaived?

No

Amount Waived:

Monetary Sanction 3 of 3

Payment Plan: Plus Interest

Is Payment Plan Current:

12�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Extended Hearing Panel Decision Rendered November 12, 2018. The sanctionsare based on the findings that Harrington converted customer funds, intentionallycausing the customer to wire $19,874.64 of her funds into his account. Thefindings stated that Harrington took the funds for his own use, without thecustomer's authorization, and never returned them. Harrington attempted toobstruct FINRA's investigation into his conversion by contacting the customer andasking her to sign a false document stating that she had stayed at his vacationrental property. The findings also stated that Harrington engaged in privatesecurities transactions, which he was compensated for, without giving prior noticeto or receiving prior written approval from, his member firm. Harrington sold privatesecurities transactions that were outside the regular scope or course of hisemployment to at least two individuals. Harrington did not sell the securitiesthrough his firm and it did not supervise the sales. Further, Harrington wascompensated for charging approximately $276,000 in sales to two purchasers. Thefindings also included that Harrington provided false documents to his firm inconnection with its investigation into whether he had engaged in outside businessactivities. Harrington intentionally misrepresented the nature of payments hereceived and deposited into his bank accounts as rental income and a paymentfrom his former broker dealer. In fact, the payments were for the purchase of stockin Harrington's outside business. Harrington knowingly caused falsified rentalcontracts to be sent to his firm in order to conceal the true purpose of the funds hehad received. FINRA found that Harrington also provided false and misleadingdocuments and information to FINRA in connection with its investigation of theprivate securities transactions and the conversion. Harrington produced a bankstatement to FINRA that his sales assistant, under his direction, altered to removea customer's name as the originator of a wire transfer. Harrington also submitted awritten response to FINRA that falsely represented he was entitled to the funds hedirected the customer to wire to him claiming it was payment for investmentadvisory fees rendered to the customer. Harrington also falsely testified that thepurported rental agreements with another customer were authentic andrepresented legitimate rental transactions. The decision became final onDecember 31, 2018.

iReporting Source: Broker

Regulatory Action InitiatedBy:

Financial Industry Regulatory Authority (FINRA)

Sanction(s) Sought: Other: Not yet known. Investigation ongoing.

Date Initiated: 06/23/2017

Docket/Case Number: 2015047303901

Employing firm when activityoccurred which led to theregulatory action:

National Securities

Product Type: Other: Private Securities Transaction

Allegations: Harrington was named a respondent in a FINRA complaint alleging that heconverted customer funds by intentionally and without authorization taking andexercising ownership over $19,874.64 belonging to one of his customers when heneither owned the property nor was entitled to possess it. The complaint allegesthat Harington engaged in a series of private securities transactions with at leasttwo individuals through which he sold over 300,000 shares of restricted stock hehad purportedly received as compensation from a company for approximately$276,000. Harrington failed to provide his member firm with prior written notice ofhis private securities transactions, including his proposed role as seller in thetransactions. The complaint also alleges that Harrington lied to his firm when hemischaracterized the purpose of payments received into his bank accounts.Specifically, Harrington falsely characterized three payments received from one ofthe individuals for the purchase of the stock as vacation-rental-by-owner (VRBO)income. Harrington also falsely characterized the $100,000 payment he receivedfrom the other individual for the purchase of stock as a payment from his formerbroker-dealer. In addition, Harrington knowingly caused at least two falsified VRBOrental contracts to be sent to his firm in order to conceal the true purpose of fundshe had received in private securities transactions. The complaint further allegesthat as FINRA began investigating him, Harrington continued to actively concealhis misconduct with the knowing assistance of his assistant. Specifically, atHarrington's direction or with his knowledge and consent, his assistant alteredcertain bank statements requested by FINRA in order to conceal the originator of apayment Harrington received for the stock. Harrington, by and through his attorney,submitted the altered bank statement to FINRA as if it were an authentic, non-altered document. In addition, during his investigative testimony, Harrington falselyand repeatedly insisted that the fake VRBO agreements he had created wereauthentic and represented legitimate rental transactions. Additionally, Harringtonsubmitted to FINRA a written response which falsely stated that he was entitled tothe approximately $20,000 he took from the customer, as payment for investmentadvisory services rendered to her. In addition, the complaint alleges that after helearned that FINRA was investigating his conversion of the customer's funds,Harrington contacted the customer and attempted to have her sign a falsedocument stating that he was entitled to the money he stole.

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Harrington was named a respondent in a FINRA complaint alleging that heconverted customer funds by intentionally and without authorization taking andexercising ownership over $19,874.64 belonging to one of his customers when heneither owned the property nor was entitled to possess it. The complaint allegesthat Harington engaged in a series of private securities transactions with at leasttwo individuals through which he sold over 300,000 shares of restricted stock hehad purportedly received as compensation from a company for approximately$276,000. Harrington failed to provide his member firm with prior written notice ofhis private securities transactions, including his proposed role as seller in thetransactions. The complaint also alleges that Harrington lied to his firm when hemischaracterized the purpose of payments received into his bank accounts.Specifically, Harrington falsely characterized three payments received from one ofthe individuals for the purchase of the stock as vacation-rental-by-owner (VRBO)income. Harrington also falsely characterized the $100,000 payment he receivedfrom the other individual for the purchase of stock as a payment from his formerbroker-dealer. In addition, Harrington knowingly caused at least two falsified VRBOrental contracts to be sent to his firm in order to conceal the true purpose of fundshe had received in private securities transactions. The complaint further allegesthat as FINRA began investigating him, Harrington continued to actively concealhis misconduct with the knowing assistance of his assistant. Specifically, atHarrington's direction or with his knowledge and consent, his assistant alteredcertain bank statements requested by FINRA in order to conceal the originator of apayment Harrington received for the stock. Harrington, by and through his attorney,submitted the altered bank statement to FINRA as if it were an authentic, non-altered document. In addition, during his investigative testimony, Harrington falselyand repeatedly insisted that the fake VRBO agreements he had created wereauthentic and represented legitimate rental transactions. Additionally, Harringtonsubmitted to FINRA a written response which falsely stated that he was entitled tothe approximately $20,000 he took from the customer, as payment for investmentadvisory services rendered to her. In addition, the complaint alleges that after helearned that FINRA was investigating his conversion of the customer's funds,Harrington contacted the customer and attempted to have her sign a falsedocument stating that he was entitled to the money he stole.

Current Status: Pending

Broker Statement Rep intends to vigorously defend himself against any charges or claims brought byFINRA pursuant to this matter.

Disclosure 2 of 2

i

Reporting Source: Regulator

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought: Other: N/A

Date Initiated: 12/28/2012

Docket/Case Number: 2011030176901

Employing firm when activityoccurred which led to theregulatory action:

FIRST ALLIED SECURITIES, INC.; MATRIX CAPITAL GROUP, INC.

Product Type:

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Product Type: No Product

Allegations: FINRA BY-LAWS ARTICLE V, SECTION 2(C), FINRA RULES 1122, 2010:HARRINGTON FILED A PERSONAL BANKRUPTCY PETITION AND FAILED TODISCLOSE THAT MATERIAL FACT ON HIS FORMS U4.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 12/28/2012

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Suspension

If the regulator is the SEC,CFTC, or an SRO, did theaction result in a finding of awillful violation or failure tosupervise?

No

(1) willfully violated anyprovision of the SecuritiesAct of 1933, the SecuritiesExchange Act of 1934, theInvestment Advisers Act of1940, the InvestmentCompany Act of 1940, theCommodity Exchange Act, orany rule or regulation underany of such Acts, or any ofthe rules of the MunicipalSecurities Rulemaking Board,or to have been unable tocomply with any provision ofsuch Act, rule or regulation?

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

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Regulator Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, HARRINGTONCONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS, THEREFORE HE IS SUSPENDED FROM ASSOCIATING WITH ANYFINRA MEMBER IN ANY CAPACITY FOR 30 DAYS. NO MONETARY SANCTIONWAS ASSESSED IN THIS MATTER. THE SUSPENSION IS IN EFFECT FROMJANUARY 22, 2013, THROUGH FEBRUARY 20, 2013.

(2) willfully aided, abetted,counseled, commanded,induced, or procured theviolation by any person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any of suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board? or

(3) failed reasonably tosupervise another personsubject to your supervision,with a view to preventing theviolation by such person ofany provision of theSecurities Act of 1933, theSecurities Exchange Act of1934, the InvestmentAdvisers Act of 1940, theInvestment Company Act of1940, the CommodityExchange Act, or any rule orregulation under any suchActs, or any of the rules ofthe Municipal SecuritiesRulemaking Board?

Capacities Affected: ALL CAPACITIES

Duration: 30 DAYS

Start Date: 01/22/2013

End Date: 02/20/2013

Sanction 1 of 1

Sanction Type: Suspension

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Regulator Statement WITHOUT ADMITTING OR DENYING THE FINDINGS, HARRINGTONCONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OFFINDINGS, THEREFORE HE IS SUSPENDED FROM ASSOCIATING WITH ANYFINRA MEMBER IN ANY CAPACITY FOR 30 DAYS. NO MONETARY SANCTIONWAS ASSESSED IN THIS MATTER. THE SUSPENSION IS IN EFFECT FROMJANUARY 22, 2013, THROUGH FEBRUARY 20, 2013.

iReporting Source: Broker

Regulatory Action InitiatedBy:

FINRA

Sanction(s) Sought: Other: N/A

Date Initiated: 12/28/2012

Docket/Case Number: 2011030176901

Employing firm when activityoccurred which led to theregulatory action:

FIRST ALLIED SECURITIES,INC; MATRIX CAPITAL GROUP, INC

Product Type: No Product

Allegations: FINRA BY-LAWS ARTICLE V,SECTION 2(C),FINRA RULES1122,2010:REGISTERED REPRESENTATIVE FILED A PERSONALBANKRUPTCY PETITION AND FAILED TODISCLOSE THAT MATERIAL FACT ON HIS FORMS U4.

Current Status: Final

Resolution: Acceptance, Waiver & Consent(AWC)

Resolution Date: 12/28/2012

Sanctions Ordered:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Suspension

Capacities Affected: ALL CAPACITIES

Duration: 30 DAYS

Sanction 1 of 1

Sanction Type: Suspension

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Duration: 30 DAYS

Start Date: 01/22/2013

End Date: 02/20/2013

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Customer Dispute - Award / Judgment

This type of disclosure event involves a final, consumer-initiated, investment-related arbitration or civil suit containing allegations of sales practiceviolations against the broker that resulted in an arbitration award or civil judgment for the customer.

Disclosure 1 of 1

Reporting Source: Regulator

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

National Securities Corporation

violation of section 10(b) of the Securities Exchange Act and SEC Rule 10b-5,common law fraud, negligent misrepresentation, breach of fiduciary duty, andviolations of California Corporations Code section 25210(a).

Product Type: Penny Stock

Alleged Damages: $0.00

Arbitration/Reparation Claimfiled with and Docket/CaseNo.:

FINRA - CASE #15-02368

Date Notice/Process Served: 09/10/2015

Arbitration Pending? No

Disposition: Award

Disposition Date: 12/06/2016

Disposition Detail: Respondent is jointly and severally liable for and shall pay to Claimant the sum of$105,000.00 in compensatory damages.

Arbitration Information

iReporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NATIONAL SECURIITES CORP

NEGLIGENT MISREPRESENTATION,BREACH OF FIDUCIARY DUTY

Product Type: Penny Stock

Alleged Damages: $200,000.00

Arbitration Information

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

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Date Notice/Process Served: 10/26/2015

Arbitration Pending? No

Disposition: Award to Customer

Disposition Date: 12/06/2016

Monetary CompensationAmount:

$105,000.00

Individual ContributionAmount:

$0.00

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

FINRA

Docket/Case #: 15-02368

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NATIONAL SECURITIES CORP

NEGLIGENT MISREPRESENTATION,BREACH OF FIDUCIARY DUTY,

Product Type: Penny Stock

Alleged Damages: $200,000.00

Date Complaint Received: 10/26/2015

Complaint Pending?

Customer Complaint Information

Is this an oral complaint?

Is this a written complaint?

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA office of dispute resolution

Docket/Case #: 15-02368

Filing date ofarbitration/CFTC reparationor civil litigation:

09/10/2015

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Complaint Pending? No

Status:

Status Date: 12/06/2016

Settlement Amount: $105,000.00

Individual ContributionAmount:

$0.00

Date Notice/Process Served: 10/26/2015

Arbitration Pending? No

Disposition: Award to Customer

Disposition Date: 12/06/2016

Monetary CompensationAmount:

$105,000.00

Disposition: Monetary Judgment to Customer

Disposition Date: 12/06/2016

Arbitration Information

Individual ContributionAmount:

$0.00

Civil Litigation Information

Arbitration Award/Monetary Judgment (for claimants/plaintiffs)

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

Financial Industry Regulatory Authority (FINRA)

Docket/Case #: 15-02368

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Customer Dispute - Settled

This type of disclosure event involves a consumer-initiated, investment-related complaint, arbitration proceeding or civil suit containing allegationsof sale practice violations against the broker that resulted in a monetary settlement to the customer.

Disclosure 1 of 5

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MATRIX CAPITAL/BANNOCKBURN PARTNERS/NATIONAL SECURITIES CORP

COMMON LAW FRAUD, AND MISREPRESENTATION,UNSUITABILITY,EXCESSIVE TRADING, CHURNING,OVERCONCENTRATION,BREACH OF FIDUCIARY DUTY, BREACH OFCONTRACT,NEGLIGENCE,FORGERY,CONVERSION AND AGENCY.

Product Type: Equity-OTCOther: PRIVATE PLACEMENT

Alleged Damages: $410,000.00

Date Notice/Process Served: 01/03/2017

Arbitration Pending? No

Disposition: Settled

Disposition Date: 07/06/2017

Monetary CompensationAmount:

$85,000.00

Arbitration Information

Individual ContributionAmount:

$0.00

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

FINRA

Docket/Case #: 16-03547

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MATRIX CAPITAL/ BANNOCKBURN PARTNERS/NATIONAL SECURITIES CORP

COMMON LAW FRAUD, MISREPRESENTATION, UNSUITABILITY, EXCESSIVETRADING, CHURNING, OVER CONCENTRATION, BREACH OF FIDUCIARYDUTY, BREACH OF CONTRACT, NEGLIGENCE, FORGERY

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Allegations: COMMON LAW FRAUD, MISREPRESENTATION, UNSUITABILITY, EXCESSIVETRADING, CHURNING, OVER CONCENTRATION, BREACH OF FIDUCIARYDUTY, BREACH OF CONTRACT, NEGLIGENCE, FORGERY

Product Type: Equity-OTCOther: PRIVATE PLACEMENT

Alleged Damages: $410,000.00

Date Notice/Process Served: 01/03/2017

Arbitration Pending? No

Disposition: Settled

Disposition Date: 07/06/2017

Monetary CompensationAmount:

$85,000.00

Arbitration Information

Individual ContributionAmount:

$0.00

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

FINRA

Docket/Case #: 16-03547

Disclosure 2 of 5

i

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

First Allied Securities, Inc.

Claimants allege that, from approximately 2005 to 2009, one of Claimants'registered representative recommended illiquid, speculative, and high-commissioninvestments. One claimant alleges that a different registered representativeengaged in excessive trading and unauthorized trades. Claimants allegeunsuitability, misrepresentation, churning, and failure to supervise.

Product Type: Annuity-VariableDirect Investment-DPP & LP InterestsEquipment Leasing

Alleged Damages: $250,000.00

Alleged Damages AmountExplanation (if amount notexact):

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Date Complaint Received: 06/22/2016

Complaint Pending? No

Status:

Status Date: 11/05/2017

Settlement Amount: $20,092.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

Alleged Damages AmountExplanation (if amount notexact):

Amount claimed against registered representative

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 16-01293

Filing date ofarbitration/CFTC reparationor civil litigation:

06/15/2016

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

First Allied Securities, Inc.

Claimants allege that, from approximately 2005 to 2009, one of Claimants'registered representative recommended illiquid, speculative, and high-commissioninvestments. One claimant alleges that a different registered representativeengaged in excessive trading and unauthorized trades. Claimants allegeunsuitability, misrepresentation, churning, and failure to supervise.

Product Type: Annuity-VariableDirect Investment-DPP & LP InterestsEquipment Leasing

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Annuity-VariableDirect Investment-DPP & LP InterestsEquipment Leasing

Alleged Damages: $2,400,000.00

Date Complaint Received: 07/12/2016

Complaint Pending? No

Status:

Status Date: 11/05/2017

Settlement Amount: $20,092.00

Individual ContributionAmount:

$0.00

Broker Statement The statement of claim filed by the [Redacted], which does not include expressclaims against me, contains an inaccurate description of facts that erroneouslyidentifies me as the registered representative that handled the [Redacted] account.In fact,I was not involved at First Allied in the handling of this account and was notinvolved in the transactions complained of. The balance of the arbitration claim,which includes allegations by other customers, does not pertain to me at all.

Customer Complaint Information

Settled

Is this an oral complaint? No

Is this a written complaint? No

Is this an arbitration/CFTCreparation or civil litigation?

Yes

Arbitration/Reparation forumor court name and location:

FINRA

Docket/Case #: 16-01293

Filing date ofarbitration/CFTC reparationor civil litigation:

06/15/2016

Disclosure 3 of 5

i

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

HARRINGTON CAPITAL MANAGEMENT, LLC / MATRIX CAPITAL GROUP, INC

MISREPRESENTATION, OMISSIONS

Real Estate Security25�2020 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Product Type: Real Estate Security

Alleged Damages: $75,066.88

Date Notice/Process Served: 05/10/2013

Arbitration Pending? No

Disposition: Settled

Disposition Date: 08/19/2014

Monetary CompensationAmount:

$15,000.00

Arbitration Information

Individual ContributionAmount:

$13,250.00

Arbitration/CFTC reparationclaim filed with (FINRA, AAA,CFTC, etc.):

FINRA

Docket/Case #: 12-03542

Disclosure 4 of 5

i

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

CIBC OPPENHEIMER

RR SET UP A 10B5-1 PLAN FOR [CUSTOMER]. IT WAS INTENDED TO BE ASYSTEMATIC SALE OF MOBI STOCK FOR THE COMPANY. THE TRADINGDES FOR CIBC ENTERED AN ORDER DURING A RESTRICTED PERIOD BYACCIDENT. THIS ENDED UP ON RR'S FILE AND CIBC PAID APPROXIMATELY$10,000-$25,000 TO [CUSTOMER]. THE COMPLAINT IS SETTLED AND NOLONGER PENDING.

Product Type: Equity - OTC

Alleged Damages: $25,000.00

Date Complaint Received: 05/01/2001

Complaint Pending? No

Status:

Customer Complaint Information

Settled

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Status Date: 07/01/2001

Settlement Amount: $15,000.00

Individual ContributionAmount:

$0.00

Disclosure 5 of 5

i

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

CIBC WORLD MARKETS CORP.

THE CLAIMANT ALLEGES THAT MR. HARRINGTON MADE UNAUTHORIZEDTRADES AND CHARGED EXCESSIVE COMMISSIONS. CLAIMANT SEEKSREIMBURSEMENT OF APPROXIMATELY $50,000 IN COMMISSIONS.

Product Type: Equity Listed (Common & Preferred Stock)

Alleged Damages: $50,000.00

Date Complaint Received: 12/16/2002

Complaint Pending? No

Status:

Status Date: 04/08/2004

Settlement Amount: $25,000.00

Individual ContributionAmount:

$0.00

Firm Statement IN 2002, THE CLAIMANT SUBMITTED A WRITTEN COMPLAINT ALLEGINGSALES PRACTICE VIOLATIONS AGAINST HIS ACCOUNT EXECUTIVE, KYLEHARRINGTON. MR. HARRINGTON'S U-5 WAS DULY UPDATED. BY LETTERIN 2003, CIBC DENIED THE CUSTOMER COMPLAINT. THE DENIAL WASDULY NOTED ON MR. HARRINGTON'S U-5. IN 2004, THE CLAIMANT'SATTORNEY CONTACTED CIBC, SEEKING TO SETTLE THE GRIEVANCEBEFORE FILING AN ARBITRATION CLAIM. CIBC SETTLED THE MATTER FOR$25,000 ON APRIL 8, 2004. MR. HARRINGTON WAS NOT INVOLVED IN THESETTLEMENT. ON APRIL 8, 2004, CIBC SETTLED THE COMPLAINT FOR$25,000. MR. HARRINGTON DID NOT PARTICIPATE IN THE SETTLEMENT.ALTHOUGH MR. HARRINGTON WAS NOT DISMISSED OR WITHDRAWNFROM THE COMPLAINT, HE DID NOT CONTRIBUTE TO THE SETTLEMENT.

Customer Complaint Information

Settled

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iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

CIBC WORLD MARKETS CORP.

THE CLAIMANT ALLEGES THAT MR. HARRINGTON MADE UNAUTHORIZEDTRADES AND CHARGED EXCESSIVE COMMISSIONS. CLAIMANT SEEKSREIMBURSEMENT OF APPROXIMATELY $50,000 IN COMMISSIONS

Product Type: Equity Listed (Common & Preferred Stock)

Alleged Damages: $50,000.00

Date Complaint Received: 12/16/2002

Complaint Pending? No

Status:

Status Date: 04/08/2004

Settlement Amount: $25,000.00

Individual ContributionAmount:

$0.00

Broker Statement IN 2002, THE CLAIMANT SUBMITTED A WRITTEN COMPLAINT ALLEGINGSALES PRACTICE VIOLATIONS AGAINST HIS ACCOUNT EXECUTIVE, KYLEHARRINGTON. MR. HARRINGTON'S U-5 WAS DULY UPDATED. BY LETTER IN2003, CIBC DENIED THE CUSTOMER COMPLAINT. THE DENIAL WAS DULYNOTED ON MR. HARRINGTON'S U-5. IN 2004, THE CLAIMANT'S ATTORNEYCONTACTED CIBC, SEEKING TO SETTLE THE GRIEVANCE BEFORE FILINGAN ARBITRATION CLAIM. CIBC SETTLED THE MATTER FOR $25,000 ONAPRIL 8, 2004. MR. HARRINGTON WAS NOT INVOLVED IN THE SETTLEMENT.ON APRIL 8, 2004, CIBC SETTLED THE COMPLAINT FOR $25,000. MR.HARRINGTON DID NOT PARTICIPATE IN THE SETTLEMENT. ALTHOUGH MR.HARRINGTON WAS NOT DISMISSED OR WITHDRAWN FROM THECOMPLAINT, HE DID NOT CONTRIBUTE TO THE SETTLEMENT.

Customer Complaint Information

Settled

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Customer Dispute - Closed-No Action / Withdrawn / Dismissed / Denied

This type of disclosure event involves (1) a consumer-initiated, investment-related arbitration or civil suit containing allegations of sales practiceviolations against the individual broker that was dismissed, withdrawn, or denied; or (2) a consumer-initiated, investment-related written complaintcontaining allegations that the broker engaged in sales practice violations resulting in compensatory damages of at least $5,000, forgery, theft, ormisappropriation, or conversion of funds or securities, which was closed without action, withdrawn, or denied.

Disclosure 1 of 2

Reporting Source: Firm

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NATIONAL SECURITIES CORP

POOR RECOMMENDATON/POOR ADVICE

Product Type: Other: FANTEX

Alleged Damages: $15,000.00

Date Complaint Received: 05/08/2017

Complaint Pending? No

Status:

Status Date: 05/24/2017

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

Closed/No Action

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

No

iReporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

NATIONAL SECURITIES CORP

POOR RECOMMENDATION/ADVICE

Product Type: Other: FANTEX

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Alleged Damages: $15,000.00

Date Complaint Received: 05/08/2017

Complaint Pending? No

Status:

Status Date: 05/24/2017

Settlement Amount: $0.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Closed/No Action

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

No

Disclosure 2 of 2

i

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

CIBC WORLD MARKETS INC.

CUSTOMER ALLEGES THAT MR. HARRINGTON EFFECTED 10(B)18 RE-PURCHASES OF SHARES OF CUSTOMER'S STOCK WITHOUTAUTHORIZATION. CUSTOMER SEEKS THE CANCELLATION OF THESEPURCHASES AT A COST OF $12,500.

Product Type: Equity Listed (Common & Preferred Stock)

Alleged Damages: $12,500.00

Date Complaint Received: 06/26/2001

Complaint Pending? No

Status:

Status Date: 11/07/2001

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

Denied

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Individual ContributionAmount:

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Customer Dispute - Pending

This type of disclosure event involves (1) a pending consumer-initiated, investment-related arbitration or civil suit that contains allegations of salespractice violations against the broker; or (2) a pending, consumer-initiated, investment-related written complaint containing allegations that thebroker engaged in, sales practice violations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, orconversion of funds or securities.

Disclosure 1 of 1

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

MATRIX CAPITAL GROUP

IN 2011 CUSTOMER CLAIMS RR DID UNAUTHORIZE TRADES, WANTSTRADES CANCELED

Product Type: Equity-OTCEquity Listed (Common & Preferred Stock)

Alleged Damages: $5,001.00

Date Complaint Received: 06/28/2011

Complaint Pending? Yes

Settlement Amount:

Individual ContributionAmount:

Broker Statement ***SHOULD BE ARCHIVED, OVER 24 MONTHS OLD***

Customer Complaint Information

Alleged Damages AmountExplanation (if amount notexact):

WANTS ALL TRADES CANCELLED

Is this an oral complaint? No

Is this a written complaint? Yes

Is this an arbitration/CFTCreparation or civil litigation?

No

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Employment Separation After Allegations

This type of disclosure event involves a situation where the broker voluntarily resigned, was discharged, or was permitted to resign after beingaccused of (1) violating investment-related statutes, regulations, rules or industry standards of conduct; (2) fraud or the wrongful taking ofproperty; or (3) failure to supervise in connection with investment-related statutes, regulations, rules, or industry standards of conduct.

Disclosure 1 of 2

Reporting Source: Firm

Employer Name: NATIONAL SECURITIES CORP

Termination Type: Discharged

Termination Date: 11/18/2016

Allegations: Internal Review regarding the appearance of conversion of client funds.

Product Type: No Product

iReporting Source: Broker

Employer Name: NATIONAL SECURITIES CORP

Termination Type: Discharged

Termination Date: 11/18/2016

Allegations: INTERNAL REVIEW REGARDING THE APPEARANCE OF CONVERSION OFCLIENT FUNDS

Product Type: No Product

Disclosure 2 of 2

i

Reporting Source: Firm

Employer Name: MATRIX CAPITAL GROUP, INC.

Termination Type: Permitted to Resign

Termination Date: 11/17/2011

Allegations: RR WAS PERMITTED TO RESIGN UPON THE FIRM'S DETERMINATION THATHE HAD FAILED TO TIMELY DISCLOSE A REPORTABLE EVENT ON HIS FORMU4 AND ON AN INTERNAL ANNUAL CERTIFICATION.

Product Type: No Product

iReporting Source:

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Reporting Source: Broker

Employer Name: MATRIX CAPITAL GROUP

Termination Type: Permitted to Resign

Termination Date: 11/18/2011

Allegations: THE FIRM CLAIMS THAT I FAILED TO TIMELY DISCLOSE A REPORTABLEEVENT ON MY U-4 AND INTERNAL ANNUAL CERTIFICATION. I DISPUTE THISAS I TOLD THEM ABOUT MY BANKRUPTCY WHEN I WAS HIRED AND THEYSAID IT WASN'T A REPORTABLE EVENT AT THAT TIME

Product Type: No Product

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