American Portfolios Financial Services Inc.

12/31/2015: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2013035369502 TO: Department of Enforcement Financial lndustry Regulatory Authority (''FINRA") RE: American Portfolios Financial Services, Inc., Respondent BD No. 18487 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, Respondent, American Portfolios Financial Services, Inc. (''American Portfolios," the "Firm" or "Respondent"), submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose

Reference 2013035369502data-portal.finra.orgfinra.org

12/10/2021: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2018060968102 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: American Portfolios Financial Services, Inc. (Respondent) Member Firm CRD No. 18487 Pursuant to FINRA Rule 9216, Respondent American Portfolios Financial Services, Inc. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

Reference 2018060968102data-portal.finra.orgfinra.org

05/28/2013: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER AND CONSENT NO. 2012033328301 TO: Department of Enforcement Financial Industry Regulatory Authority ("FINRA") RE: American Portfolios Financial Services Inc., Respondent Member Firm CRD No. 18487 Pursuant to FINRA Rule 9216 of FINRA's Code of Procedure, American Portfolios Financial Services, Inc., (" American Portfolios" or "Respondent") submits this Letter of Acceptance, Waiver and Consent ("AWC") for the purpose of proposing a

Reference 2012033328301data-portal.finra.orgfinra.org

12/29/2025: Between April 2018 and September 2022, APFS failed to calculate the per account fees for customers enrolled in its Bank Deposit Program (Sweep Program) according to the formula in disclosure documents that it distributed to Sweep Program customers. As a result, APFS’s communications with those customers inaccurately represented how the firm calculated its fees. The firm also did not disclose that it retained surplus interest earned from customers’ funds. By making inaccurate and incomplete disclosures in communications with customers, the firm violated FINRA Rule 2010, and by contravening content standards for public communications, the firm violated FINRA Rules 2210(d)(1) and 2010. From April 2018 to May 2023, APFS lacked a system, including written supervisory procedures (WSPs), reasonably designed to supervise the Sweep Program, in violation of FINRA Rules 3110 and 2010. For these and other violations, the firm agrees to a censure, fine of $550,000, and $4,629,115.80 in restitution.

Reference 2022076811601data-portal.finra.orgfinra.org

09/21/2026: Unit Investment Trusts (UITs) offer investors the opportunity to invest in a fixed portfolio of securities for a specified term. A recommendation to sell a UIT early causes the customer to forego part of the benefit of the investment for which the customer has already paid. From January 2018 to October 14, 2024, American Portfolios failed to reasonably supervise its registered representatives’ recommendations to sell UITs before maturity to achieve compliance with FINRA Rule 2111 and, beginning June 30, 2020, Regulation Best Interest (“Reg BI”). During this period, three representatives routinely recommended that their retail customers sell UITs prior to maturity, causing 295 customers to incur $1,232,939.09 in unnecessary costs and fees. Therefore, American Portfolios violated FINRA Rules 3110 and 2010. For these and other violations, the firm is censured, fined $400,000, and ordered to pay $1,232,939.09 in restitution...

Reference 2023078794701data-portal.finra.orgfinra.org

08/15/2024: FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2022074134801 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: American Portfolios Financial Services, Inc. (Respondent) Member Firm CRD No. 18487 Pursuant to FINRA Rule 9216, Respondent American Portfolios Financial Services, Inc. submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below. This AWC is submitted on the condition that, if accepted, FINRA will not bring any future actions against Respondent alleging violations based on the same factual findings described in this AWC.

Reference 2022074134801data-portal.finra.orgfinra.org