Holthouse Carlin & Van Trigt LLP

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09/13/2018 05:25 PM EDT

Order Instituting Public Administrative and Cease- And-Desist Proceedings Pursuant to Section 203(k) of the Investment Advisers Act of 1940, Sections 4C and 21C of the Securities Exchange Act of 1934, and Rule 102(e) of the Commission's Rules of Practice, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
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