KYLE PATRICK HARRINGTON - Israels Neuman, PLC...capital management insurance services, llc, 5370...

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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 4 - 5 6 Page(s)

Transcript of KYLE PATRICK HARRINGTON - Israels Neuman, PLC...capital management insurance services, llc, 5370...

BrokerCheck Report

KYLE PATRICK HARRINGTON

Section Title

Report Summary

Broker Qualifications

Registration and Employment History

Disclosure Events

CRD# 2282328

1

2 - 3

4 - 5

6

Page(s)

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.

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· BrokerCheck reports for individual brokers include information such as employment history, professionalqualifications, 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.

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o information FINRA and/or the Securities and Exchange Commission (SEC) require brokers andbrokerage 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.

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KYLE P. HARRINGTON

CRD# 2282328

Currently employed by and registered with thefollowing Firm(s):

AURORA CAPITAL LLC354 WIDOW GAVITS ROADPO BOX 1167BRIDGEHAMPTON,, NY 11932-1167CRD# 37924Registered with this firm since: 12/07/2016

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

Investigation 1

Customer Dispute 9

Termination 2

Financial 1

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 registered with:

1 Self-Regulatory Organization

2 U.S. states and territories

This broker has passed:

1 Principal/Supervisory Exam

1 General Industry/Product Exam

2 State Securities Law Exams

Registration History

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

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

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

MATRIX CAPITAL GROUP, INC.CRD# 33364NEW YORK, NY12/2009 - 11/2011

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Broker Qualifications

Registrations

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

This individual is currently registered with 1 SRO and is licensed in 2 U.S. states and territories through his orher employer.

Employment 1 of 1Firm Name:

Main Office Address:

Firm CRD#:

AURORA CAPITAL LLC

37924

354 WIDOW GAVITS ROADPO BOX 1167BRIDGEHAMPTON,, NY 11932-1167

SRO Category Status Date

FINRA General Securities Representative APPROVED 12/07/2016

U.S. State/Territory

Category Status Date

California Agent APPROVED 12/07/2016

New York Agent APPROVED 12/07/2016

Branch Office Locations

This individual does not have any registered Branch Office where the individual is located.

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Broker Qualifications

Industry Exams this Broker has Passed

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

This section includes all securities industry exams that the broker has passed. Under limited circumstances, a brokermay attain a registration after receiving an exam waiver based on exams the broker has passed and/or qualifying workexperience. Any exam waivers that the broker has received are not included below.

Exam Category Date

Principal/Supervisory Exams

General Securities Principal Examination 07/14/2009Series 24

Exam Category Date

General Industry/Product Exams

General Securities Representative Examination 08/13/1993Series 7

Exam Category Date

State Securities Law Exams

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

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

Additional information about the above exams or other exams FINRA administers to brokers and other securitiesprofessionals can be found at www.finra.org/brokerqualifications/registeredrep/.

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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:

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

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

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

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

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

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

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

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

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

09/1998 - 05/1999 BANCBOSTON ROBERTSON STEPHENS INC. 41271 SAN FRANCISCO, CA

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

12/1997 - 01/1998 MERRILL LYNCH, PIERCE, FENNER & SMITHINCORPORATED

7691 NEW YORK, NY

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

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

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

08/1993 - 02/1994 MERRILL LYNCH, PIERCE, FENNER & SMITHINCORPORATED

7691 NEW YORK, NY

Employment History

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Registration and Employment History

Employment History, continued

Employment Dates Employer Name Employer Location

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

Please note that the broker is required to provide this information only while registered with FINRA or a nationalsecurities exchange and 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 Bridgehampton, NY

02/2008 - Present HARRINGTON CAPITAL MANAGEMENT, LLC SAN DIEGO, CA

08/2012 - 11/2016 NATIONAL ASSET MANAGEMENT, INC. SAN DIEGO, CA

06/2012 - 11/2016 NATIONAL SECURITIES CORP SAN DIEGO, CA

02/2012 - 06/2012 BANNOCKBURN PARTNERS, LLC NEW YORK, NY

12/2009 - 11/2011 MATRIX CAPITAL GROUP NEW YORK, NY

02/2008 - 12/2009 FIRST ALLIED SECURITIES INC. SAN DIEGO, CA

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

Other Business Activities

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

(1) HARRINGTON CAPITAL MANAGEMENT, LLC ("HCM") REGISTERED INVESTMENT ADVISOR, 5370 Toscana Way#H115 San Diego CA 92122, KYLE HARRINGTON, FOUNDER & MANAGING MEMBER. START DATE: 02/2008.HOURS PER WEEK: APPROXIMATELY 0...(2)La JOLLA YMCA NOT INVESTMENT RELATED, MEMBER OF THEBOARD OF DIRECTORS START 1/2016 2 HRS PER MONTH ZERO DURING TRADING HRS...(3) HARRINGTONCAPITAL 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 INVESTMENT RELATED. STARTED 2000,TIME DEVOTED 4HRS/MTH DURING NON-TRADING HOURS.RESIDENTIAL REAL ESTATE PROPERTY. (5) Appearances on Television & Radio. RECEIVES NOMINALAPPEARANCE FEES. ACTIVITY IS MONITORED AS IF INTERNAL. INVESTMENT RELATED. 2 HOURS PER WEEK.NOT DURING TRADING HOURS.

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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 customercomplaints and arbitrations, regulatory actions, employment terminations, bankruptcy filings, and criminal or civiljudicial 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 samedisclosure event, all versions of the event will appear in the BrokerCheck report. The different versionswill 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 partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter. Pleasenote that brokers and brokerage firms may choose to settle customer disputes or regulatorymatters for business or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding of wrongdoingon 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 information regarding these events can be found in the subsequent pages of this report. You also maywish to contact the broker to obtain further information regarding these events.

Final On AppealPending

Regulatory Event 1 1 0

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Customer Dispute 3 6 N/A

Investigation 1 N/A N/A

Termination N/A 2 N/A

Financial 0 1 N/A

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Disclosure Event Details

When evaluating this information, please keep in mind that a discloure event may be pending or involve allegationsthat are contested and have not been resolved or proven. The matter may, in the end, be withdrawn, dismissed,resolved in favor of the broker, or concluded through a negotiated settlement for certain business reasons (e.g., tomaintain customer relationships or to limit the litigation costs associated with disputing the allegations) with noadmission or finding of wrongdoing.

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

Regulatory - Final

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

Disclosure 1 of 1

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: 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)

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

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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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Regulatory - Pending

This type of disclosure event involves a pending formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulatory agency such as the Securities and ExchangeCommission, foreign financial regulatory body) for alleged violations of investment-related rules or regulations.

Disclosure 1 of 1

Reporting Source: Broker

Regulatory Action InitiatedBy:

Financial Industry Regulatory Authority (FINRA)

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

Date Initiated: 12/01/2016

Docket/Case Number: 2015047303901

Employing firm when activityoccurred which led to theregulatory action:

National Securities

Product Type: Other: Private Securities Transaction

Allegations: Neither claims nor charges have yet been brought, but I believe the allegations arethat I engaged in a private securities transaction not reported, that be redacting adocument, I fraudulently falsified it and conversion of customer funds.

Current Status: Pending

Broker Statement Actual claims have not yet been made as of December 7, 2016. I intend tovigorously defend myself against any charges or claims brought by FINRApursuant to this matter.

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Investigation

This type of disclosure event involves any ongoing formal investigation by an entity such as a grand jury state or federalagency, self-regulatory organization or foreign regulatory authority. Subpoenas, preliminary or routine regulatory inquiries,and general requests by a regulatory entity for information are not considered investigations and therefore are notincluded in a BrokerCheck report.

Disclosure 1 of 1

Reporting Source: Broker

Initiated By: Financial Industry Regulatory Authority (FINRA)

Notice Date: 12/01/2016

Details: In FINRA Matter Number 2015047303901 FINRA indicated that it has made apreliminary determination to recommend disciplinary action related to potentialviolations of Rules 3040, 8210 and 2010.

Is Investigation pending? Yes

Broker Statement Actual claims have not yet been made as of December 7, 2016. I intend tovigorously defend myself against any charges or claims brought by FINRApursuant to this matter.

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Customer Dispute - Award / Judgment

This type of disclosure event involves a final, consumer-initiated, investment-related arbitration or civil suit containingallegations of sales practice violations against the broker that resulted in an arbitration award or civil judgment for thecustomer.

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

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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

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: $150,000.00

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:

$150,000.00

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 civilsuit containing allegations of sale practice violations against the broker that resulted in a monetary settlement to thecustomer.

Disclosure 1 of 3

Reporting Source: Broker

Employing firm whenactivities occurred which ledto the complaint:

Allegations:

HARRINGTON CAPITAL MANAGEMENT, LLC / MATRIX CAPITAL GROUP, INC

MISREPRESENTATION, OMISSIONS

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 2 of 3

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.

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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:

Status Date: 07/01/2001

Settlement Amount: $15,000.00

Individual ContributionAmount:

$0.00

Customer Complaint Information

Settled

Disclosure 3 of 3

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

Customer Complaint Information

Settled

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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.

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

20©2017 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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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.

21©2017 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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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 containingallegations of sales practice violations against the individual broker that was dismissed, withdrawn, or denied; or (2) aconsumer-initiated, investment-related written complaint containing allegations that the broker engaged in sales practiceviolations resulting in compensatory damages of at least $5,000, forgery, theft, or misappropriation, or conversion of fundsor 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

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.

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Allegations: 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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Customer Dispute - Pending

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

Disclosure 1 of 3

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? Yes

Arbitration Information

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

FINRA

Docket/Case #: 16-03547

Disclosure 2 of 3

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.

Annuity-VariableDirect Investment-DPP & LP InterestsEquipment Leasing

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

Alleged Damages: $2,400,000.00

Date Complaint Received: 06/22/2016

Complaint Pending? Yes

Settlement Amount:

Individual ContributionAmount:

Customer Complaint Information

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

Alleged Damages: $2,400,000.00

Is this an oral complaint? 25©2017 FINRA. All rights reserved. Report about KYLE P. HARRINGTON.

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Date Complaint Received: 07/12/2016

Complaint Pending? Yes

Settlement Amount:

Individual ContributionAmount:

Broker Statement The statement of claim filed by the Eichelbergers, which does not include expressclaims against me, contains an inaccurate description of facts that erroneouslyidentifies me as the registered representative that handled the Eichelbergers'account. In fact,I was not involved at First Allied in the handling of this accountand was not involved in the transactions complained of. The balance of thearbitration claim, which includes allegations by other customers, does not pertainto me at all.

Customer Complaint Information

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 3

i

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

Alleged Damages AmountExplanation (if amount notexact):

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Date Complaint Received: 06/28/2011

Complaint Pending? Yes

Settlement Amount:

Individual ContributionAmount:

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 permittedto resign after being accused of (1) violating investment-related statutes, regulations, rules or industry standards ofconduct; (2) fraud or the wrongful taking of property; or (3) failure to supervise in connection with investment-relatedstatutes, 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

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: 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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Financial - Final

This type of disclosure event involves a bankruptcy, compromise with one or more creditors, or Securities InvestorProtection Corporation liquidation involving the broker or an organization/brokerage firm the broker controlled thatoccurred within the last 10 years.

Disclosure 1 of 1

Reporting Source: Broker

Action Type: Bankruptcy

Action Date: 06/15/2009

Organization Investment-Related?

Action Pending? No

Disposition: Dismissed

Disposition Date: 01/29/2015

BANKRUPTCY DISMISSED 1-29-2015Broker Statement

Bankruptcy: Chapter 11

Type of Court: Federal Court

Name of Court: US BANKRUPTCY COURT

Location of Court: SOUTHERN DISTRICT NY, MANHATTAN

Docket/Case #: 09-13845

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