BrokerCheck Report CETERA ADVISOR NETWORKS LLC CRD# 13572

Section Title Page(s) Report Summary 1

Firm Profile 2 - 13

Firm History 14

Firm Operations 15 - 26

Disclosure Events 27

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This firm conducts 16 types of businesses. This firm is affiliated with financial or investment institutions. This firm has referral or financial arrangements with other brokers or dealers.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 1 www.finra.org/brokercheck User Guidance Firm Profile

This firm is classified as a limited liability company. This firm was formed in Delaware on 12/31/2012. Its fiscal year ends in December.

Firm Names and Locations This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailing addresses, telephone number, and any alternate name by which the firm conducts business and where such name is used.

CETERA ADVISOR NETWORKS LLC Doing business as CETERA ADVISOR NETWORKS LLC CRD# 13572 SEC# 8-29577

Main Office Location 200 N PACIFIC COAST HWY STE 1300 EL SEGUNDO, CA 90245-5672 Regulated by FINRA Los Angeles Office

Mailing Address 200 N PACIFIC COAST HWY STE 1300 EL SEGUNDO, CA 90245-5672

Business Telephone Number 310-326-3100

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 2 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to all direct owners and executive officers of the brokerage firm. Direct Owners and Executive Officers

Legal Name & CRD# (if any): CETERA FINANCIAL GROUP, INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Position SOLE MEMBER Position Start Date 12/2010 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): BOWMAN, TIMOTHY JOSEPH 2247374 Is this a domestic or foreign Individual entity or an individual?

Position PRINCIPAL FINANCIAL OFFICER Position Start Date 06/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): BUCHHEISTER, JEFFREY ROBERT 4709900 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF FINANCIAL OFFICER Position Start Date 05/2021 Percentage of Ownership Less than 5% ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 3 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): CHAFFIN, GARY LYNN 6819431 Is this a domestic or foreign Individual entity or an individual?

Position TAX OFFICER Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): COAXUM, KOFI SULE 5150018 Is this a domestic or foreign Individual entity or an individual?

Position VICE PRESIDENT Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): GILL, GEORGE ANDREW

©2021 FINRA. All rights reserved. Report about4498537 CETERA ADVISOR NETWORKS LLC 4 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) 4498537 Is this a domestic or foreign Individual entity or an individual?

Position VICE PRESIDENT Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): GOK, LISA ANNE 5059738 Is this a domestic or foreign Individual entity or an individual?

Position SECRETARY Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): GOOLEY, THOMAS ANDREW 4526760 Is this a domestic or foreign Individual entity or an individual?

Position MANAGER Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the©2021 firm? FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 5 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): HALEY, KRISTY MARIE 4022155 Is this a domestic or foreign Individual entity or an individual?

Position ADVISORY CHIEF COMPLIANCE OFFICER Position Start Date 11/2015 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): IYENGAR, JANANI RAVI 6780478 Is this a domestic or foreign Individual entity or an individual?

Position TREASURER Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): KESTERSON, BARBARA JO 2747533

Is©2021 this FINRA. a domestic All rights orreserved. foreign Report aboutIndividual CETERA ADVISOR NETWORKS LLC 6 entity or an individual? www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Is this a domestic or foreign Individual entity or an individual?

Position CHIEF OPERATING OFFICER AND PRINCIPAL OPERATIONS OFFICER Position Start Date 10/2018 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): KIM, DAVID 6228305 Is this a domestic or foreign Individual entity or an individual?

Position ASSISTANT SECRETARY Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): MCCALLOP, PATRICIA RUTHERFORD 5059176 Is this a domestic or foreign Individual entity or an individual?

Position BROKER DEALER CHIEF COMPLIANCE OFFICER Position Start Date 01/2019 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm? ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 7 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): MIZUGUCHI, MAURA RIE 5769181 Is this a domestic or foreign Individual entity or an individual?

Position CHIEF ACCOUNTING OFFICER Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): NEARY, JOSEPH DANIEL 2993505 Is this a domestic or foreign Individual entity or an individual?

Position MANAGER AND VICE PRESIDENT Position Start Date 05/2019 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): RAMOS, RAMON 2160203

Is©2021 this FINRA. a domestic All rights orreserved. foreign Report aboutIndividual CETERA ADVISOR NETWORKS LLC 8 entity or an individual? www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Is this a domestic or foreign Individual entity or an individual?

Position MONEY LAUNDERING REPORTING OFFICER Position Start Date 02/2013 Percentage of Ownership Less than 5% Does this owner direct the No management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): SMILEY, STANLEY ROBERT 3004604 Is this a domestic or foreign Individual entity or an individual?

Position VICE PRESIDENT Position Start Date 11/2007 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): STINSON, TIMOTHY EARL MCCOY 2272183 Is this a domestic or foreign Individual entity or an individual?

Position VICE PRESIDENT Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm? ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 9 www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): STONE, TIMOTHY PATRICK 3038963 Is this a domestic or foreign Individual entity or an individual?

Position VICE PRESIDENT Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): TAYLOR, THOMAS BYRON 2193426 Is this a domestic or foreign Individual entity or an individual?

Position PRESIDENT, MANAGER AND CHIEF EXECUTIVE OFFICER Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

Legal Name & CRD# (if any): VAN HAVERMAAT, DAVID JAMES 7042846

Is©2021 this FINRA. a domestic All rights orreserved. foreign Report aboutIndividual CETERA ADVISOR NETWORKS LLC 10 entity or an individual? www.finra.org/brokercheck User Guidance Firm Profile

Direct Owners and Executive Officers (continued) Is this a domestic or foreign Individual entity or an individual?

Position ASSISTANT SECRETARY Position Start Date 05/2021 Percentage of Ownership Less than 5% Does this owner direct the Yes management or policies of the firm?

Is this a public reporting No company?

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 11 www.finra.org/brokercheck User Guidance Firm Profile This section provides information relating to any indirect owners of the brokerage firm. Indirect Owners

Legal Name & CRD# (if any): ARETEC GROUP, INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which CETERA FINANCIAL HOLDINGS, INC. indirect ownership is established Relationship to Direct Owner SOLE MEMBER Relationship Established 04/2014 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm? Is this a public reporting No company?

Legal Name & CRD# (if any): CETERA FINANCIAL HOLDINGS, INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which CETERA FINANCIAL GROUP, INC. indirect ownership is established Relationship to Direct Owner SHAREHOLDER; 100% OF COMMON STOCK Relationship Established 11/2009 Percentage of Ownership 75% or more Does this owner direct the Yes management or policies of the firm? Is this a public reporting No company?

Legal Name & CRD# (if any): GC TWO HOLDINGS, INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which GC TWO INTERMEDIATE HOLDINGS, INC. indirect©2021 FINRA. ownership All rights reserved. is Report about CETERA ADVISOR NETWORKS LLC 12 established www.finra.org/brokercheck User Guidance Firm Profile

Indirect Owners (continued) Company through which GC TWO INTERMEDIATE HOLDINGS, INC. indirect ownership is established Relationship to Direct Owner OWNER Relationship Established 10/2018 Percentage of Ownership Other General Partners Does this owner direct the Yes management or policies of the firm? Is this a public reporting No company?

Legal Name & CRD# (if any): GC TWO INTERMEDIATE HOLDINGS, INC. Is this a domestic or foreign Domestic Entity entity or an individual?

Company through which ARETEC GROUP, INC. indirect ownership is established Relationship to Direct Owner OWNER Relationship Established 10/2018 Percentage of Ownership Other General Partners Does this owner direct the Yes management or policies of the firm? Is this a public reporting No company?

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 13 www.finra.org/brokercheck User Guidance Firm History This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 14 www.finra.org/brokercheck User Guidance Firm Operations

Registrations This section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatory organizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered and licensed, the date the license became effective, and certain information about the firm's SEC registration. This firm is currently registered with the SEC, 1 SRO and 53 U.S. states and territories. Federal Regulator Status Date Effective SEC Approved 05/18/1983

SEC Registration Questions This firm is registered with the SEC as: A broker-dealer: Yes A broker-dealer and government securities broker or dealer: Yes A government securities broker or dealer only: No This firm has ceased activity as a government securities broker or dealer: No

Self-Regulatory Organization Status Date Effective FINRA Approved 06/08/1983

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 15 www.finra.org/brokercheck User Guidance Firm Operations

Registrations (continued) U.S. States & Status Date Effective U.S. States & Status Date Effective Territories Territories Alabama Approved 12/16/1983 North Carolina Approved 12/07/1983 Alaska Approved 11/04/1983 North Dakota Approved 09/10/1986 Arizona Approved 06/24/1983 Ohio Approved 10/20/1983 Arkansas Approved 10/01/1986 Oklahoma Approved 02/22/1984 California Approved 06/15/1983 Oregon Approved 06/23/1983 Colorado Approved 08/25/1983 Pennsylvania Approved 11/15/1983 Connecticut Approved 11/01/1983 Puerto Rico Approved 07/01/1997 Delaware Approved 08/06/1985 Rhode Island Approved 02/02/1987 District of Columbia Approved 08/19/1983 South Carolina Approved 10/31/1983 Florida Approved 11/04/1983 South Dakota Approved 05/08/1984 Georgia Approved 11/18/1983 Tennessee Approved 08/22/1983 Hawaii Approved 08/19/1985 Texas Approved 07/28/1983 Idaho Approved 09/14/1984 Utah Approved 01/06/1984 Illinois Approved 10/18/1983 Vermont Approved 05/21/1984 Indiana Approved 11/22/1983 Virgin Islands Approved 03/17/2009 Iowa Approved 10/13/1983 Virginia Approved 08/08/1983 Kansas Approved 10/18/1983 Washington Approved 07/01/1983 Kentucky Approved 11/30/1983 West Virginia Approved 11/07/1983 Louisiana Approved 11/07/1983 Wisconsin Approved 01/03/1984 Maine Approved 05/18/1984 Wyoming Approved 03/19/1984 Maryland Approved 09/23/1983 Massachusetts Approved 02/01/1984 Michigan Approved 09/22/1983 Minnesota Approved 09/23/1983 Mississippi Approved 04/05/1984 Missouri Approved 06/11/1984 Montana Approved 01/02/1985 Nebraska Approved 11/16/1983 Nevada Approved 08/26/1983 New Hampshire Approved 09/17/1985 New Jersey Approved 03/08/1984 New Mexico Approved 10/26/1983 New York Approved 11/28/1983

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 16 www.finra.org/brokercheck User Guidance Firm Operations

Types of Business This section provides the types of business, including non-securities business, the brokerage firm is engaged in or expects to be engaged in. This firm currently conducts 16 types of businesses. Types of Business

Broker or dealer retailing corporate equity securities over-the-counter Broker or dealer selling corporate debt securities Underwriter or selling group participant (corporate securities other than mutual funds) Mutual fund retailer U S. government securities dealer U S. government securities broker Municipal securities dealer Municipal securities broker Broker or dealer selling variable life insurance or annuities Solicitor of time deposits in a financial institution Broker or dealer selling oil and gas interests Put and call broker or dealer or option writer Investment advisory services Broker or dealer selling tax shelters or limited partnerships in primary distributions Private placements of securities Broker or dealer involved in a networking, kiosk or similar arrangment with a: bank, savings bank or association, or credit union

Other Types of Business This firm does not effect transactions in commodities, commodity futures, or commodity options. This firm does engage in other non-securities business. Non-Securities Business Description: CETERA ADVISOR NETWORKS LLC IS ALSO AN INSURANCE AGENCY. SBS INSURANCE AGENCY

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 17 www.finra.org/brokercheck User Guidance Firm Operations

Clearing Arrangements This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers. Name: PERSHING LLC CRD #: 7560 Business Address: 777 S. FIGUEROA ST., #1310 LOS ANGELES, CA 90017 Effective Date: 07/01/1983 Description: "FULLY DISCLOSED" CLEARING ARRANGEMENT THAT GOVERNS THE INTRODUCTION OF ACCOUNTS TO THE ABOVE FIRM FOR ORDER EXECUTION AND CLEARING OF SELECT LISTED AND OTC ISSUES.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 18 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements

This firm does have books or records maintained by a third party. Name: MICROSOFT CORPORATION Business Address: ONE MICROSOFT WAY REDMOND, WA 98052 Effective Date: 12/01/2020 Description: THE FIRM WILL BEGIN UTILIZING MICROSOFT CORPORATION OR AN AFFILIATE OF MICROSOFT CORPORATION ("MICROSOFT"), ELECTRONIC STORAGE MEDIA EXCLUSIVELY FOR CERTAIN BOOKS AND RECORDS. Name: SITEQUEST, INC Business Address: 707 W 700 S SUITE 101 WOODS CROSS, UT 94087 Effective Date: 11/02/2020 Description: THE FIRM WILL BEGIN UTILIZING SITEQUEST, INC, ELECTRONIC STORAGE MEDIA EXCLUSIVELY FOR CERTAIN BOOKS AND RECORDS ON OR AFTER NOVEMBER 1, 2020. Name: BIZNEWS24.COM, INC. D/B/A PINPOINT GLOBAL COMMUNICATIONS Business Address: 9 TRAFALGAR SQUARE SUITE 150 NASHUA, NH 03063 Effective Date: 05/05/2020 Description: ELECTRONIC STORAGE MEDIA FOR CERTAIN BOOKS AND RECORDS ON OR AFTER MAY 1, 2020. Name: FMG SUITE, LLC Business Address: 12395 WORLD TRADE DR #200 SAN DIEGO, CA 92128 Effective Date: 03/02/2020 Description: ELECTRONIC RECORD KEEPER OF SUPERVISORY AND COMPLIANCE POLICIES AND PROCEDURES. Name: WELLS FARGO CLEARING SERVICES, LLC CRD #: 19616 Business Address: ONE NORTH JEFFERSON AVE ©2021 FINRA. All rights reserved. Report STabout LOUIS, CETERA MO ADVISOR 63103 NETWORKS LLC 19 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) Business Address: ONE NORTH JEFFERSON AVE ST LOUIS, MO 63103 Effective Date: 09/20/2019 Description: CERTAIN BOOKS AND RECORDS ARE MAINTAINED BY FIRST CLEARING, LLC PURSUANT TO A FULLY DISCLOSED AGREEMENT. Name: NATIONAL REGULATORY SERVICES, A DIVISION OF ACCUITY, INC. Business Address: 323 - A MAIN STREET LAKEVILLE, CT 06039 Effective Date: 07/10/2017 Description: BRANCH INSPECTION MODULES FOR MONITORING AND RECORD RETENTION Name: MARKETINGPRO, INC. Business Address: 14525 SW MILLIKAN WAY #78359 BEAVERTON, OR 97005 Effective Date: 05/24/2013 Description: WEB BASED SALES LITERATURE AND RECORD RETENTION SYSTEM

Name: SMARSH Business Address: 851 SW 6TH AVE # 800 PORTLAND, OR 97204 Effective Date: 11/01/2015 Description: ELECTRONIC RECORD KEEPER FOR ARCHIVING EMAILS, INSTANT MESSAGES, SOCIAL MEDIA AND TRADE BLOTTERS. Name: BIZNEWS24.COM, INC. Business Address: 9 TRAFALGAR SQUARE SUITE 150 NASHUA, NH 03063 Effective Date: 02/01/2014 Description: ELECTRONIC RECORD KEEPER FOR ARCHIVED RECORDS OF OBAS, DISCLOSURE FORMS, ANNUAL CERTIFICATION STATEMENTS, ANNUAL INDIVIDUAL COMPLIANCE REVIEWS, DETACHED OFFICE COMPLIANCE REVIEWS, COMPLIANCE TRAINING RECORDS (FIRM ELEMENT, AML, NEW REP, NAIC) AND NON REGISTERED FINGERPRINTED AND ASSOCIATED PERSONS TRAINING RECORDS AND APQS.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 20 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) Name: DATALOK Business Address: 727 KINGSHILL PLACE CARSON, CA 90746 Effective Date: 03/01/1993 Description: HARD COPY OFFSITE STORAGE OF GENERAL BD RECORDS.

Name: ALBRIDGE SOLUTIONS, INC. Business Address: ONE PERSHING PLAZA JERSEY CITY, NJ 07399 Effective Date: 01/01/2010 Description: ELECTRONIC RECORD KEEPER FOR CERTAIN ORDER TICKETS

Name: IRON MOUNTAIN INFORMATION MANAGEMENT, LLC Business Address: 700 DISTRIBUTION DRIVE ATLANTA, GA 30336 Effective Date: 08/01/2011 Description: HARD COPY OFFSITE STORAGE OF GENERAL BD RECORDS

Name: VERITAS TECHNOLOGIES, INC. Business Address: 900 CORPORATE POINTE CULVER CITY, CA 90230 Effective Date: 01/31/2008 Description: ELECTRONIC RECORD KEEPER FOR ARCHIVING EMAILS, INSTANT MESSAGES AND TRADE BLOTTERS Name: DOCUPACE TECHNOLOGIES, INC. Business Address: 201 S BARRINGTON AVE #215 LOS ANGELES, CA 90025 Effective Date: 12/19/2007 Description: ELECTRONIC RECORD-KEEPER FOR GENERAL ACCOUNT DOCUMENTATION AND PROCESSING This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

Control Persons/Financing

This©2021 firm FINRA. does All rightsnot havereserved. individuals Report about who CETERA control ADVISOR its management NETWORKS LLC or policies through agreement. 21 www.finra.org/brokercheck User Guidance Firm Operations Industry Arrangements (continued) This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 22 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates This section provides information on control relationships the firm has with other firms in the securities, investment advisory, or banking business.

This firm is, directly or indirectly: · in control of · controlled by · or under common control with the following partnerships, corporations, or other organizations engaged in the securities or investment advisory business. CETERA ADVISORY SERVICES LLC is under common control with the firm. CRD #: 285648 Business Address: 200 N SEPULVEDA BLVD SUITE 1200 EL SEGUNDO, CA 90245 Effective Date: 11/18/2016 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: APPLICANT AND AFFILIATE ARE UNDER COMMON CONTROL OF ARETEC GROUP, INC.

FIRST ALLIED SECURITIES, INC. is under common control with the firm. CRD #: 32444 Business Address: 655 WEST BROADWAY 12TH FLOOR SAN DIEGO, CA 92101 Effective Date: 04/29/2014 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF ©2021 FINRA. All rights reserved. Report aboutARETEC CETERA GROUP, ADVISOR INC. NETWORKS LLC 23 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF ARETEC GROUP, INC.

CETERA INVESTMENT MANAGEMENT LLC is under common control with the firm. CRD #: 165436 Business Address: 200 N. SEPULVEDA BLVD. SUITE 1200 EL SEGUNDO, CA 90245 Effective Date: 01/03/2013 Foreign Entity: No Country: Securities Activities: No Investment Advisory Yes Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF CETERA FINANCIAL GROUP, INC.

CETERA INVESTMENT ADVISERS LLC is under common control with the firm. CRD #: 105644 Business Address: 1450 AMERICAN LANE 6TH FLOOR, SUITE #650 SCHAUMBURG, IL 60173 Effective Date: 04/02/2012 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF CETERA FINANCIAL GROUP, INC.

CETERA FINANCIAL SPECIALISTS LLC is under common control with the firm. CRD #: 10358 Business Address: 1450 AMERICAN LANE 6TH FLOOR, SUITE #650 ©2021 FINRA. All rights reserved. Report aboutSCHAUMBURG, CETERA ADVISOR IL 60173 NETWORKS LLC 24 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued) Business Address: 1450 AMERICAN LANE 6TH FLOOR, SUITE #650 SCHAUMBURG, IL 60173 Effective Date: 04/02/2012 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory Yes Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF CETERA FINANCIAL GROUP, INC.

CETERA INVESTMENT SERVICES LLC is under common control with the firm. CRD #: 15340 Business Address: 400 FIRST STREET SOUTH, SUITE 300 SUITE 300 ST. CLOUD, MN Effective Date: 12/13/2000 Foreign Entity: No Country: Securities Activities: Yes Investment Advisory No Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF CETERA FINANCIAL GROUP, INC.

CETERA ADVISORS LLC is under common control with the firm. CRD #: 10299 Business Address: 4600 SOUTH SYRACUSE SUITE 600 DENVER, CO 80237 Effective Date: 09/11/2002 Foreign Entity: No Country: Securities Activities: Yes ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 25 www.finra.org/brokercheck User Guidance Firm Operations

Organization Affiliates (continued)

Securities Activities: Yes Investment Advisory Yes Activities: Description: APPLICANT AND CONTROL AFFILIATE ARE UNDER COMMON CONTROL OF CETERA FINANCIAL GROUP, INC.

This firm is not directly or indirectly, controlled by the following: · bank holding company · national bank · state member bank of the Federal Reserve System · state non-member bank · savings bank or association · credit union · or foreign bank

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 26 www.finra.org/brokercheck User Guidance Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal or civil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved. For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm or one of its control affiliates. Further information regarding these events can be found in the subsequent pages of this report. Pending Final On Appeal Regulatory Event 0 17 0 Civil Event 1 1 0 Arbitration N/A 15 N/A

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 27 www.finra.org/brokercheck User Guidance

Disclosure Event Details What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includes summary information regarding FINRA arbitration awards in cases where the brokerage firm was named as a respondent. 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 brokerage firm is required to disclose a particular criminal event. 3. Disclosure events in BrokerCheck reports come from different sources: o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firm and a regulator report information for the same event, both versions of the event will appear in the BrokerCheck report. The different versions will be separated by a solid line with the reporting source labeled. 4. 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 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. 5. You may wish to contact the brokerage firm to obtain further information regarding any of the disclosure events contained in this BrokerCheck report. Regulatory - Final This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a state securities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission, foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation or suspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federal contractor. Disclosure 1 of 17 Reporting Source: Regulator Current Status: Final Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") ©2021 FINRA. All rights reserved. Report aboutDEEMS CETERA IT APPROPRIATE ADVISOR NETWORKS AND LLC IN THE PUBLIC INTEREST THAT PUBLIC 28 ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST CETERA ADVISOR NETWORKS LLC, CETERA ADVISORS LLC, CETERA INVESTMENT SERVICES LLC, CETERA FINANCIAL SPECIALISTS LLC, AND CETERA INVESTMENT ADVISERS LLC (TOGETHER, "CETERA ENTITIES" OR "RESPONDENTS").

THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF CETERA ENTITIES' FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION S-P ("SAFEGUARDS RULE") AND, WITH RESPECT TO CETERA ADVISORS LLC AND CETERA INVESTMENT ADVISERS LLC, FAILURE TO ADOPT AND IMPLEMENT REASONABLY DESIGNED PROCEDURES FOR REVIEW OF COMMUNICATIONS SENT TO IMPACTED CLIENTS IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

THE SAFEGUARDS RULE REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO: (1) INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION; (2) PROTECT AGAINST ANY ANTICIPATED THREATS OR HAZARDS TO THE SECURITY OR INTEGRITY OF CUSTOMER RECORDS AND INFORMATION; AND (3) PROTECT AGAINST UNAUTHORIZED ACCESS TO OR USE OF CUSTOMER RECORDS OR INFORMATION THAT COULD RESULT IN SUBSTANTIAL HARM OR INCONVENIENCE TO ANY CUSTOMER.

CETERA ENTITIES ARE REGISTERED WITH THE COMMISSION AS BROKER- DEALERS, INVESTMENT ADVISERS, OR BOTH. BETWEEN NOVEMBER 2017 AND JUNE 2020, EMAIL ACCOUNTS OF OVER 60 CETERA ENTITIES' PERSONNEL WERE TAKEN OVER BY UNAUTHORIZED THIRD PARTIES RESULTING IN THE EXPOSURE OF OVER 4,388 OF CETERA ENTITIES' CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION ("PII") STORED IN THE COMPROMISED EMAIL ACCOUNTS. AT THE TIME, NONE OF THESE ACCOUNTS HAD MULTI-FACTOR AUTHENTICATION ("MFA") TURNED ON, EVEN THOUGH CETERA ENTITIES' OWN POLICIES REQUIRED MFA "WHEREVER POSSIBLE," BEGINNING IN 2018. ALTHOUGH THESE EMAIL ACCOUNT TAKEOVERS DO NOT APPEAR TO HAVE RESULTED IN ANY UNAUTHORIZED TRADES OR TRANSFERS IN BROKERAGE CUSTOMERS' OR ADVISORY CLIENTS' ("CUSTOMERS") ACCOUNTS, CETERA ENTITIES VIOLATED THE SAFEGUARDS RULE BECAUSE THEIR POLICIES AND PROCEDURES TO PROTECT CUSTOMER INFORMATION AND TO PREVENT AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES, SPECIFICALLY AS APPLIED TO INDEPENDENT CONTRACTOR REPRESENTATIVES AND OFFSHORE CONTRACTORS. CETERA ENTITIES HAD A SIGNIFICANT NUMBER OF SECURITY TOOLS AT THEIR DISPOSAL THAT ALLOWED THEM TO IMPLEMENT CONTROLS THAT WOULD MITIGATE THESE HIGHER RISKS. HOWEVER, CETERA ENTITIES FAILED TO USE THESE TOOLS IN THE MANNER TAILORED TO THEIR BUSINESS, EXPOSING THEIR CUSTOMERS' PII TO UNREASONABLE RISKS.

SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER REQUIRE A REGISTERED INVESTMENT ADVISER, OR AN INVESTMENT ADVISER REQUIRED TO REGISTER, TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS, BY THE ADVISER OR ITS SUPERVISED PERSONS, OF THE ADVISERS ACT AND THE RULES ADOPTED BY THE COMMISSION THEREUNDER. CETERA ADVISORS LLC ("CETERA ADVISORS") AND CETERA INVESTMENT ADVISERS LLC ("CETERA INVESTMENT ADVISERS") VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT REASONABLY DESIGNED POLICIES AND PROCEDURES REGARDING REVIEW OF COMMUNICATIONS TO ADVISORY CLIENTS. THIS FAILURE RESULTED IN SENDING BREACH NOTIFICATIONS TO THE FIRMS' CLIENTS THAT INCLUDED MISLEADING TEMPLATE LANGUAGE SUGGESTING THAT THE NOTIFICATIONS WERE ISSUED MUCH SOONER THAN THEY ACTUALLY WERE AFTER THE DISCOVERY OF THE INCIDENTS. www.finra.org/brokercheck User Guidance

Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST CETERA ADVISOR NETWORKS LLC, CETERA ADVISORS LLC, CETERA INVESTMENT SERVICES LLC, CETERA FINANCIAL SPECIALISTS LLC, AND CETERA INVESTMENT ADVISERS LLC (TOGETHER, "CETERA ENTITIES" OR "RESPONDENTS").

THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF CETERA ENTITIES' FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION S-P ("SAFEGUARDS RULE") AND, WITH RESPECT TO CETERA ADVISORS LLC AND CETERA INVESTMENT ADVISERS LLC, FAILURE TO ADOPT AND IMPLEMENT REASONABLY DESIGNED PROCEDURES FOR REVIEW OF COMMUNICATIONS SENT TO IMPACTED CLIENTS IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

THE SAFEGUARDS RULE REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO: (1) INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION; (2) PROTECT AGAINST ANY ANTICIPATED THREATS OR HAZARDS TO THE SECURITY OR INTEGRITY OF CUSTOMER RECORDS AND INFORMATION; AND (3) PROTECT AGAINST UNAUTHORIZED ACCESS TO OR USE OF CUSTOMER RECORDS OR INFORMATION THAT COULD RESULT IN SUBSTANTIAL HARM OR INCONVENIENCE TO ANY CUSTOMER.

CETERA ENTITIES ARE REGISTERED WITH THE COMMISSION AS BROKER- DEALERS, INVESTMENT ADVISERS, OR BOTH. BETWEEN NOVEMBER 2017 AND JUNE 2020, EMAIL ACCOUNTS OF OVER 60 CETERA ENTITIES' PERSONNEL WERE TAKEN OVER BY UNAUTHORIZED THIRD PARTIES RESULTING IN THE EXPOSURE OF OVER 4,388 OF CETERA ENTITIES' CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION ("PII") STORED IN THE COMPROMISED EMAIL ACCOUNTS. AT THE TIME, NONE OF THESE ACCOUNTS HAD MULTI-FACTOR AUTHENTICATION ("MFA") TURNED ON, EVEN THOUGH CETERA ENTITIES' OWN POLICIES REQUIRED MFA "WHEREVER POSSIBLE," BEGINNING IN 2018. ALTHOUGH THESE EMAIL ACCOUNT TAKEOVERS DO NOT APPEAR TO HAVE RESULTED IN ANY UNAUTHORIZED TRADES OR TRANSFERS IN BROKERAGE CUSTOMERS' OR ADVISORY CLIENTS' ("CUSTOMERS") ACCOUNTS, CETERA ENTITIES VIOLATED THE SAFEGUARDS RULE BECAUSE THEIR POLICIES AND ©2021 FINRA. All rights reserved. Report aboutPROCEDURES CETERA ADVISOR TO PROTECTNETWORKS CUSTOMERLLC INFORMATION AND TO PREVENT 29 AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES, SPECIFICALLY AS APPLIED TO INDEPENDENT CONTRACTOR REPRESENTATIVES AND OFFSHORE CONTRACTORS. CETERA ENTITIES HAD A SIGNIFICANT NUMBER OF SECURITY TOOLS AT THEIR DISPOSAL THAT ALLOWED THEM TO IMPLEMENT CONTROLS THAT WOULD MITIGATE THESE HIGHER RISKS. HOWEVER, CETERA ENTITIES FAILED TO USE THESE TOOLS IN THE MANNER TAILORED TO THEIR BUSINESS, EXPOSING THEIR CUSTOMERS' PII TO UNREASONABLE RISKS.

SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER REQUIRE A REGISTERED INVESTMENT ADVISER, OR AN INVESTMENT ADVISER REQUIRED TO REGISTER, TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS, BY THE ADVISER OR ITS SUPERVISED PERSONS, OF THE ADVISERS ACT AND THE RULES ADOPTED BY THE COMMISSION THEREUNDER. CETERA ADVISORS LLC ("CETERA ADVISORS") AND CETERA INVESTMENT ADVISERS LLC ("CETERA INVESTMENT ADVISERS") VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT REASONABLY DESIGNED POLICIES AND PROCEDURES REGARDING REVIEW OF COMMUNICATIONS TO ADVISORY CLIENTS. THIS FAILURE RESULTED IN SENDING BREACH NOTIFICATIONS TO THE FIRMS' CLIENTS THAT INCLUDED MISLEADING TEMPLATE LANGUAGE SUGGESTING THAT THE NOTIFICATIONS WERE ISSUED MUCH SOONER THAN THEY ACTUALLY WERE AFTER THE DISCOVERY OF THE INCIDENTS. THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST CETERA ADVISOR NETWORKS LLC, CETERA ADVISORS LLC, CETERA INVESTMENT SERVICES LLC, CETERA FINANCIAL SPECIALISTS LLC, AND CETERA INVESTMENT ADVISERS LLC (TOGETHER, "CETERA ENTITIES" OR "RESPONDENTS").

THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF CETERA ENTITIES' FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION S-P ("SAFEGUARDS RULE") AND, WITH RESPECT TO CETERA ADVISORS LLC AND CETERA INVESTMENT ADVISERS LLC, FAILURE TO ADOPT AND IMPLEMENT REASONABLY DESIGNED PROCEDURES FOR REVIEW OF COMMUNICATIONS SENT TO IMPACTED CLIENTS IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

THE SAFEGUARDS RULE REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO: (1) INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION; (2) PROTECT AGAINST ANY ANTICIPATED THREATS OR HAZARDS TO THE SECURITY OR INTEGRITY OF CUSTOMER RECORDS AND INFORMATION; AND (3) PROTECT AGAINST UNAUTHORIZED ACCESS TO OR USE OF CUSTOMER RECORDS OR INFORMATION THAT COULD RESULT IN SUBSTANTIAL HARM OR INCONVENIENCE TO ANY CUSTOMER.

CETERA ENTITIES ARE REGISTERED WITH THE COMMISSION AS BROKER- DEALERS, INVESTMENT ADVISERS, OR BOTH. BETWEEN NOVEMBER 2017 AND JUNE 2020, EMAIL ACCOUNTS OF OVER 60 CETERA ENTITIES' PERSONNEL WERE TAKEN OVER BY UNAUTHORIZED THIRD PARTIES RESULTING IN THE EXPOSURE OF OVER 4,388 OF CETERA ENTITIES' CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION ("PII") STORED IN THE COMPROMISED EMAIL ACCOUNTS. AT THE TIME, NONE OF THESE ACCOUNTS HAD MULTI-FACTOR AUTHENTICATION ("MFA") TURNED ON, EVEN THOUGH CETERA ENTITIES' OWN POLICIES REQUIRED MFA www.finra.org/brokercheck "WHEREVER POSSIBLE," BEGINNING IN 2018. ALTHOUGH THESE EMAIL User Guidance ACCOUNT TAKEOVERS DO NOT APPEAR TO HAVE RESULTED IN ANY UNAUTHORIZED TRADES OR TRANSFERS IN BROKERAGE CUSTOMERS' OR ADVISORY CLIENTS' ("CUSTOMERS") ACCOUNTS, CETERA ENTITIES VIOLATED THE SAFEGUARDS RULE BECAUSE THEIR POLICIES AND PROCEDURES TO PROTECT CUSTOMER INFORMATION AND TO PREVENT AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES, SPECIFICALLY AS APPLIED TO INDEPENDENT CONTRACTOR REPRESENTATIVES AND OFFSHORE CONTRACTORS. CETERA ENTITIES HAD A SIGNIFICANT NUMBER OF SECURITY TOOLS AT THEIR DISPOSAL THAT ALLOWED THEM TO IMPLEMENT CONTROLS THAT WOULD MITIGATE THESE HIGHER RISKS. HOWEVER, CETERA ENTITIES FAILED TO USE THESE TOOLS IN THE MANNER TAILORED TO THEIR BUSINESS, EXPOSING THEIR CUSTOMERS' PII TO UNREASONABLE RISKS.

SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER REQUIRE A REGISTERED INVESTMENT ADVISER, OR AN INVESTMENT ADVISER REQUIRED TO REGISTER, TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS, BY THE ADVISER OR ITS SUPERVISED PERSONS, OF THE ADVISERS ACT AND THE RULES ADOPTED BY THE COMMISSION THEREUNDER. CETERA ADVISORS LLC ("CETERA ADVISORS") AND CETERA INVESTMENT ADVISERS LLC ("CETERA INVESTMENT ADVISERS") VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER BY FAILING TO ADOPT AND IMPLEMENT REASONABLY DESIGNED POLICIES AND PROCEDURES REGARDING REVIEW OF COMMUNICATIONS TO ADVISORY CLIENTS. THIS FAILURE RESULTED IN SENDING BREACH NOTIFICATIONS TO THE FIRMS' CLIENTS THAT INCLUDED MISLEADING TEMPLATE LANGUAGE SUGGESTING THAT THE NOTIFICATIONS WERE ISSUED MUCH SOONER THAN THEY ACTUALLY WERE AFTER THE DISCOVERY OF THE INCIDENTS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/30/2021 Docket/Case Number: 3-20490

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/30/2021 Does the order constitute a Yes ©2021final orderFINRA. basedAll rights on reserved. Report about CETERA ADVISOR NETWORKS LLC 30 violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a Yes final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $300,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CETERA ADVISOR NETWORKS LLC IS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION S-P; AND SHALL PAY A CIVIL MONEY PENALTY JOINTLY AND SEVERALLY IN THE AMOUNT OF $300,000 TO THE COMMISSION. Regulator Statement RESPONDENT CETERA ADVISOR NETWORKS LLC HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. CETERA ADVISOR NETWORKS LLC WILLFULLY VIOLATED THE SAFEGUARDS RULE, WHICH REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO SAFEGUARD CUSTOMER RECORDS AND INFORMATION. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE CETERA ADVISOR NETWORKS LLC CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION S-P; IS CENSURED; AND SHALL PAY A CIVIL MONEY PENALTY JOINTLY AND SEVERALLY IN THE AMOUNT OF $300,000 TO THE COMMISSION. i Reporting Source: Firm Current Status: Final Allegations: THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST CETERA ADVISOR NETWORKS LLC, CETERA ADVISORS LLC, CETERA INVESTMENT SERVICES LLC, CETERA FINANCIAL SPECIALISTS LLC, AND CETERA INVESTMENT ADVISERS LLC (TOGETHER, "CETERA ENTITIES" OR "RESPONDENTS"). THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF CETERA ENTITIES' FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED ©2021 FINRA. All rights reserved. Report aboutTO PROTECT CETERA ADVISOR CUSTOMER NETWORKS RECORDS LLC AND INFORMATION, IN VIOLATION OF 31 RULE 30(A) OF REGULATION S-P ("SAFEGUARDS RULE") AND, WITH RESPECT TO CETERA ADVISORS LLC AND CETERA INVESTMENT ADVISERS LLC, FAILURE TO ADOPT AND IMPLEMENT REASONABLY DESIGNED PROCEDURES FOR REVIEW OF COMMUNICATIONS SENT TO IMPACTED CLIENTS IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THE SAFEGUARDS RULE REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO: (1) INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION; (2) PROTECT AGAINST ANY ANTICIPATED THREATS OR HAZARDS TO THE SECURITY OR INTEGRITY OF CUSTOMER RECORDS AND INFORMATION; AND (3) PROTECT AGAINST UNAUTHORIZED ACCESS TO OR USE OF CUSTOMER RECORDS OR INFORMATION THAT COULD RESULT IN SUBSTANTIAL HARM OR INCONVENIENCE TO ANY CUSTOMER. CETERA ENTITIES ARE REGISTERED WITH THE COMMISSION AS BROKER- DEALERS, INVESTMENT ADVISERS, OR BOTH. BETWEEN NOVEMBER 2017 AND JUNE 2020, EMAIL ACCOUNTS OF OVER 60 CETERA ENTITIES' PERSONNEL WERE TAKEN OVER BY UNAUTHORIZED THIRD PARTIES RESULTING IN THE EXPOSURE OF OVER 4,388 OF CETERA ENTITIES' CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION ("PII") STORED IN THE COMPROMISED EMAIL ACCOUNTS. AT THE TIME, NONE OF THESE ACCOUNTS HAD MULTI-FACTOR AUTHENTICATION ("MFA") TURNED ON, EVEN THOUGH CETERA ENTITIES' OWN POLICIES REQUIRED MFA "WHEREVER POSSIBLE," BEGINNING IN 2018. ALTHOUGH THESE EMAIL ACCOUNT TAKEOVERS DO NOT APPEAR TO HAVE RESULTED IN ANY UNAUTHORIZED TRADES OR TRANSFERS IN BROKERAGE CUSTOMERS' OR ADVISORY CLIENTS' ("CUSTOMERS") ACCOUNTS, CETERA ENTITIES VIOLATED THE SAFEGUARDS RULE BECAUSE THEIR POLICIES AND PROCEDURES TO PROTECT CUSTOMER INFORMATION AND TO PREVENT AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES, SPECIFICALLY AS APPLIED TO INDEPENDENT CONTRACTOR REPRESENTATIVES AND OFFSHORE CONTRACTORS. CETERA ENTITIES HAD A SIGNIFICANT NUMBER OF SECURITY TOOLS AT THEIR DISPOSAL THAT ALLOWED THEM TO IMPLEMENT CONTROLS THAT WOULD MITIGATE THESE HIGHER RISKS. HOWEVER, CETERA ENTITIES FAILED TO USE THESE TOOLS IN THE MANNER TAILORED TO THEIR BUSINESS, EXPOSING THEIR CUSTOMERS' PII TO UNREASONABLE RISKS. THE SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT"), AGAINST CETERA ADVISOR NETWORKS LLC, CETERA www.finra.org/brokercheck ADVISORS LLC, CETERA INVESTMENT SERVICES LLC, CETERA FINANCIAL User Guidance SPECIALISTS LLC, AND CETERA INVESTMENT ADVISERS LLC (TOGETHER, "CETERA ENTITIES" OR "RESPONDENTS"). THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF CETERA ENTITIES' FAILURE TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION S-P ("SAFEGUARDS RULE") AND, WITH RESPECT TO CETERA ADVISORS LLC AND CETERA INVESTMENT ADVISERS LLC, FAILURE TO ADOPT AND IMPLEMENT REASONABLY DESIGNED PROCEDURES FOR REVIEW OF COMMUNICATIONS SENT TO IMPACTED CLIENTS IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THE SAFEGUARDS RULE REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO: (1) INSURE THE SECURITY AND CONFIDENTIALITY OF CUSTOMER RECORDS AND INFORMATION; (2) PROTECT AGAINST ANY ANTICIPATED THREATS OR HAZARDS TO THE SECURITY OR INTEGRITY OF CUSTOMER RECORDS AND INFORMATION; AND (3) PROTECT AGAINST UNAUTHORIZED ACCESS TO OR USE OF CUSTOMER RECORDS OR INFORMATION THAT COULD RESULT IN SUBSTANTIAL HARM OR INCONVENIENCE TO ANY CUSTOMER. CETERA ENTITIES ARE REGISTERED WITH THE COMMISSION AS BROKER- DEALERS, INVESTMENT ADVISERS, OR BOTH. BETWEEN NOVEMBER 2017 AND JUNE 2020, EMAIL ACCOUNTS OF OVER 60 CETERA ENTITIES' PERSONNEL WERE TAKEN OVER BY UNAUTHORIZED THIRD PARTIES RESULTING IN THE EXPOSURE OF OVER 4,388 OF CETERA ENTITIES' CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION ("PII") STORED IN THE COMPROMISED EMAIL ACCOUNTS. AT THE TIME, NONE OF THESE ACCOUNTS HAD MULTI-FACTOR AUTHENTICATION ("MFA") TURNED ON, EVEN THOUGH CETERA ENTITIES' OWN POLICIES REQUIRED MFA "WHEREVER POSSIBLE," BEGINNING IN 2018. ALTHOUGH THESE EMAIL ACCOUNT TAKEOVERS DO NOT APPEAR TO HAVE RESULTED IN ANY UNAUTHORIZED TRADES OR TRANSFERS IN BROKERAGE CUSTOMERS' OR ADVISORY CLIENTS' ("CUSTOMERS") ACCOUNTS, CETERA ENTITIES VIOLATED THE SAFEGUARDS RULE BECAUSE THEIR POLICIES AND PROCEDURES TO PROTECT CUSTOMER INFORMATION AND TO PREVENT AND RESPOND TO CYBERSECURITY INCIDENTS WERE NOT REASONABLY DESIGNED TO MEET THESE OBJECTIVES, SPECIFICALLY AS APPLIED TO INDEPENDENT CONTRACTOR REPRESENTATIVES AND OFFSHORE CONTRACTORS. CETERA ENTITIES HAD A SIGNIFICANT NUMBER OF SECURITY TOOLS AT THEIR DISPOSAL THAT ALLOWED THEM TO IMPLEMENT CONTROLS THAT WOULD MITIGATE THESE HIGHER RISKS. HOWEVER, CETERA ENTITIES FAILED TO USE THESE TOOLS IN THE MANNER TAILORED TO THEIR BUSINESS, EXPOSING THEIR CUSTOMERS' PII TO UNREASONABLE RISKS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Date Initiated: 08/30/2021 Docket/Case Number: 3-20490 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 32 www.finra.org/brokercheck User Guidance

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 08/30/2021 Sanctions Ordered: Censure Monetary/Fine $300,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: CETERA ADVISOR NETWORKS LLC IS CENSURED; ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION S-P; AND SHALL PAY A CIVIL MONEY PENALTY JOINTLY AND SEVERALLY IN THE AMOUNT OF $300,000 TO THE COMMISSION. Firm Statement RESPONDENT CETERA ADVISOR NETWORKS LLC HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. CETERA ADVISOR NETWORKS LLC WILLFULLY VIOLATED THE SAFEGUARDS RULE, WHICH REQUIRES EVERY BROKER-DEALER AND EVERY INVESTMENT ADVISER REGISTERED WITH THE COMMISSION TO ADOPT WRITTEN POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO SAFEGUARD CUSTOMER RECORDS AND INFORMATION. "WILLFULLY," FOR PURPOSES OF IMPOSING RELIEF UNDER SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND SECTION 203(E) OF THE INVESTMENT ADVISERS ACT OF 1940, MEANS NO MORE THAN THAT THE PERSON CHARGED WITH THE DUTY KNOWS WHAT HE IS DOING. THERE IS NO REQUIREMENT THAT THE ACTOR ALSO BE AWARE THAT HE IS VIOLATING ONE OF THE RULES OR ACTS. ACCORDINGLY, IT IS HEREBY ORDERED THAT THE CETERA ADVISOR NETWORKS LLC CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION S-P; IS CENSURED; AND SHALL PAY A CIVIL MONEY PENALTY JOINTLY AND SEVERALLY IN THE AMOUNT OF $300,000 TO THE COMMISSION. i Disclosure 2 of 17 Reporting Source: Regulator

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 33 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED REGISTERED REPRESENTATIVES, WHOM THE FIRM WAS RECRUITING, TO TAKE NONPUBLIC PERSONAL CUSTOMER INFORMATION FROM THE FIRMS WHERE THE REPRESENTATIVES WERE THEN REGISTERED AND TO DISCLOSE IT TO A THIRD-PARTY VENDOR WITHOUT THE OTHER BROKER- DEALERS' OR THE CUSTOMERS' KNOWLEDGE OR CONSENT, CAUSING THOSE BROKER-DEALERS TO VIOLATE THE SEC'S REGULATION S-P: PRIVACY OF CONSUMER FINANCIAL INFORMATION AND SAFEGUARDING INFORMATION. THE FINDINGS STATED THAT THE FIRM UNDERSTOOD THAT THE VENDOR WOULD COLLECT INFORMATION ABOUT THE RECRUITED REPRESENTATIVES' CUSTOMERS, INCLUDING NONPUBLIC PERSONAL INFORMATION SUCH AS CUSTOMERS' SOCIAL SECURITY NUMBERS, DRIVER'S LICENSE NUMBERS, AND BIRTH DATES, AS WELL AS INFORMATION PERTAINING TO THEIR FINANCIAL POSITION (ACCOUNT NUMBERS, ANNUAL INCOMES, AND NET WORTH, ETC.). ONCE A RECRUITED REPRESENTATIVE BECAME REGISTERED THROUGH THE FIRM, THE VENDOR USED THE CUSTOMERS' INFORMATION TO AUTOMATICALLY PRE-POPULATE NEW ACCOUNT FORMS. THE FIRM DIRECTLY REIMBURSED THE NEWLY AFFILIATED REGISTERED REPRESENTATIVES FOR THEIR USE OF THE VENDOR. THE FIRM FAILED TO TAKE ANY STEPS TO VERIFY WHETHER THE RECRUITED REPRESENTATIVES OR THEIR BROKER-DEALERS AT THE TIME HAD NOTIFIED CUSTOMERS ABOUT THE DISCLOSURE OF THEIR NONPUBLIC PERSONAL INFORMATION. NOR DID THE FIRM TAKE ANY STEPS TO VERIFY WHETHER CUSTOMERS HAD BEEN GIVEN AN OPPORTUNITY TO OPT-OUT OF HAVING THEIR INFORMATION DISCLOSED. Initiated By: FINRA Date Initiated: 06/25/2021 Docket/Case Number: 2020066875501

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/25/2021

©2021Does FINRA.the order All rights constitute reserved. a Report aboutNo CETERA ADVISOR NETWORKS LLC 34 final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $125,000. PAID IN FULL ON JULY 13, 2021. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT CAUSED REGISTERED REPRESENTATIVES, WHOM THE FIRM WAS RECRUITING, TO TAKE NONPUBLIC PERSONAL CUSTOMER INFORMATION FROM THE FIRMS WHERE THE REPRESENTATIVES WERE THEN REGISTERED AND TO DISCLOSE IT TO A THIRD-PARTY VENDOR WITHOUT THE OTHER BROKER- DEALERS' OR THE CUSTOMERS' KNOWLEDGE OR CONSENT, CAUSING THOSE BROKER-DEALERS TO VIOLATE THE SEC'S REGULATION S-P: PRIVACY OF CONSUMER FINANCIAL INFORMATION AND SAFEGUARDING INFORMATION. THE FINDINGS STATED THAT THE FIRM UNDERSTOOD THAT THE VENDOR WOULD COLLECT INFORMATION ABOUT THE RECRUITED REPRESENTATIVES' CUSTOMERS, INCLUDING NONPUBLIC PERSONAL INFORMATION SUCH AS CUSTOMERS' SOCIAL SECURITY NUMBERS, DRIVER'S LICENSE NUMBERS, AND BIRTH DATES, AS WELL AS INFORMATION PERTAINING TO THEIR FINANCIAL POSITION (ACCOUNT NUMBERS, ANNUAL INCOMES, AND NET WORTH, ETC.). ONCE A RECRUITED REPRESENTATIVE BECAME REGISTERED THROUGH THE FIRM, THE VENDOR USED THE CUSTOMERS' INFORMATION TO AUTOMATICALLY PRE-POPULATE NEW ACCOUNT FORMS. THE FIRM DIRECTLY REIMBURSED THE NEWLY AFFILIATED REGISTERED REPRESENTATIVES FOR THEIR USE OF THE VENDOR. THE FIRM FAILED TO TAKE ANY STEPS TO VERIFY WHETHER THE RECRUITED REPRESENTATIVES OR THEIR BROKER-DEALERS AT THE TIME HAD NOTIFIED CUSTOMERS ABOUT THE DISCLOSURE OF THEIR NONPUBLIC PERSONAL INFORMATION. NOR DID THE FIRM TAKE ANY STEPS TO VERIFY WHETHER CUSTOMERS HAD BEEN GIVEN AN OPPORTUNITY TO OPT-OUT OF HAVING THEIR INFORMATION DISCLOSED. Initiated By: FINRA ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 35 www.finra.org/brokercheck User Guidance

Initiated By: FINRA Date Initiated: 06/25/2021 Docket/Case Number: 2020066875501

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 06/25/2021 Sanctions Ordered: Censure Monetary/Fine $125,000.00 Other Sanctions Ordered: Sanction Details: THE FIRM WAS CENSURED AND FINED $125,000 i Disclosure 3 of 17 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUPERVISE CERTAIN PRIVATE SECURITIES TRANSACTIONS OF DUALLY- REGISTERED REPRESENTATIVES (DRRS) WHO WERE ASSOCIATED WITH OUTSIDE REGISTERED INVESTMENTS ADVISORS (RIAS) AND HAD UNREASONABLE SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES (WSPS) TO SUPERVISE PRIVATE SECURITIES TRANSACTIONS THAT THE DRRS RECOMMENDED THROUGH THE OUTSIDE RIAS. THE FINDINGS STATED THAT THE FIRM WAS AWARE OF THE SUPERVISORY DEFICIENCIES AS THEY WERE IDENTIFIED IN SECURITIES AND EXCHANGE COMMISSION (SEC) EXAMINATIONS, YET, DESPITE SEVERAL EFFORTS TO ADDRESS SUCH DEFICIENCIES, IT FAILED TO IMPLEMENT SYSTEMS AND PROCEDURES TO REASONABLY SUPERVISE THE TRANSACTIONS. THE FIRM ALSO INITIATED A PROJECT TO OBTAIN THE INFORMATION NECESSARY TO SUPERVISE OUTSIDE RIA TRANSACTIONS FOR DRRS. THIS PROJECT, HOWEVER, WAS NOT COMPLETED AND THE AUTOMATED SYSTEM FOR OUTSIDE RIA TRANSACTION REVIEW WAS NOT IMPLEMENTED. IN RESPONSE TO THE ©2021 FINRA. All rights reserved. Report aboutSEC'S CETERA EXAMINATION ADVISOR NETWORKS FINDINGS, LLC THE FIRM STATED THAT IT EXPECTED TO 36 ESTABLISH AN ELECTRONIC CONNECTION TO OBTAIN ELECTRONIC REPORTING INFORMATION (I.E., A DATA FEED) BY THE END OF SEPTEMBER 2015 TO CAPTURE, MONITOR, AND SUPERVISE OUTSIDE RIA TRANSACTIONS. THE FIRM ESTABLISHED SUPERVISORY PROCEDURES TO ENSURE THAT OUTSIDE RIA TRANSACTIONS WERE CONSISTENT WITH CLIENTS' INVESTMENT OBJECTIVES AND OTHER SUITABILITY CONSIDERATIONS AND PROCESSES FOR OBTAINING INFORMATION ABOUT ITS DRRS' OUTSIDE RIA TRANSACTIONS. HOWEVER, THE DATA FEED WAS PROVIDED BY THIRD-PARTY CUSTODIANS THAT SOMETIMES RESTRICTED ACCESS TO THE INFORMATION AND, ON OCCASION, CUT OFF THE FIRM'S ACCESS TO THE INFORMATION. THE FIRM DID NOT RECEIVE AUTOMATED DATA FEEDS FROM ALL CUSTODIANS UNTIL JUNE 2018, AND, THUS, DID NOT HAVE ACCESS TO INFORMATION ABOUT CERTAIN OUTSIDE RIA ACCOUNTS THAT WERE NOT CUSTODIED AT ITS CLEARING FIRM. EVEN AFTER THE FIRM BEGAN RECEIVING THE TRANSACTION DATA, IT DID NOT RECEIVE COMPLETE CUSTOMER-SPECIFIC ACCOUNT INFORMATION FOR ALL ACCOUNTS AND, THUS, COULD NOT SATISFY ITS SUPERVISORY OBLIGATIONS INCLUDING, BUT NOT LIMITED TO, A SUITABILITY REVIEW OF ALL ACCOUNT TRANSACTIONS. THE FINDINGS ALSO STATED THAT DUE TO THE FIRM'S SUPERVISORY FAILURES, IT FAILED TO RECORD DRR PRIVATE SECURITIES TRANSACTIONS CONDUCTED THROUGH ITS OUTSIDE RIAS ON ITS BOOKS AND RECORDS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUPERVISE CERTAIN PRIVATE SECURITIES TRANSACTIONS OF DUALLY- REGISTERED REPRESENTATIVES (DRRS) WHO WERE ASSOCIATED WITH OUTSIDE REGISTERED INVESTMENTS ADVISORS (RIAS) AND HAD UNREASONABLE SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES (WSPS) TO SUPERVISE PRIVATE SECURITIES TRANSACTIONS THAT THE DRRS RECOMMENDED THROUGH THE OUTSIDE RIAS. THE FINDINGS STATED THAT THE FIRM WAS AWARE OF THE SUPERVISORY DEFICIENCIES AS THEY WERE IDENTIFIED IN SECURITIES AND EXCHANGE COMMISSION (SEC) EXAMINATIONS, YET, DESPITE SEVERAL EFFORTS TO ADDRESS SUCH DEFICIENCIES, IT FAILED TO IMPLEMENT SYSTEMS AND PROCEDURES TO REASONABLY SUPERVISE www.finra.org/brokercheck THE TRANSACTIONS. THE FIRM ALSO INITIATED A PROJECT TO OBTAIN User Guidance THE INFORMATION NECESSARY TO SUPERVISE OUTSIDE RIA TRANSACTIONS FOR DRRS. THIS PROJECT, HOWEVER, WAS NOT COMPLETED AND THE AUTOMATED SYSTEM FOR OUTSIDE RIA TRANSACTION REVIEW WAS NOT IMPLEMENTED. IN RESPONSE TO THE SEC'S EXAMINATION FINDINGS, THE FIRM STATED THAT IT EXPECTED TO ESTABLISH AN ELECTRONIC CONNECTION TO OBTAIN ELECTRONIC REPORTING INFORMATION (I.E., A DATA FEED) BY THE END OF SEPTEMBER 2015 TO CAPTURE, MONITOR, AND SUPERVISE OUTSIDE RIA TRANSACTIONS. THE FIRM ESTABLISHED SUPERVISORY PROCEDURES TO ENSURE THAT OUTSIDE RIA TRANSACTIONS WERE CONSISTENT WITH CLIENTS' INVESTMENT OBJECTIVES AND OTHER SUITABILITY CONSIDERATIONS AND PROCESSES FOR OBTAINING INFORMATION ABOUT ITS DRRS' OUTSIDE RIA TRANSACTIONS. HOWEVER, THE DATA FEED WAS PROVIDED BY THIRD-PARTY CUSTODIANS THAT SOMETIMES RESTRICTED ACCESS TO THE INFORMATION AND, ON OCCASION, CUT OFF THE FIRM'S ACCESS TO THE INFORMATION. THE FIRM DID NOT RECEIVE AUTOMATED DATA FEEDS FROM ALL CUSTODIANS UNTIL JUNE 2018, AND, THUS, DID NOT HAVE ACCESS TO INFORMATION ABOUT CERTAIN OUTSIDE RIA ACCOUNTS THAT WERE NOT CUSTODIED AT ITS CLEARING FIRM. EVEN AFTER THE FIRM BEGAN RECEIVING THE TRANSACTION DATA, IT DID NOT RECEIVE COMPLETE CUSTOMER-SPECIFIC ACCOUNT INFORMATION FOR ALL ACCOUNTS AND, THUS, COULD NOT SATISFY ITS SUPERVISORY OBLIGATIONS INCLUDING, BUT NOT LIMITED TO, A SUITABILITY REVIEW OF ALL ACCOUNT TRANSACTIONS. THE FINDINGS ALSO STATED THAT DUE TO THE FIRM'S SUPERVISORY FAILURES, IT FAILED TO RECORD DRR PRIVATE SECURITIES TRANSACTIONS CONDUCTED THROUGH ITS OUTSIDE RIAS ON ITS BOOKS AND RECORDS. Initiated By: FINRA Date Initiated: 12/15/2020 Docket/Case Number: 2015046716901

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/15/2020 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or ©2021deceptive FINRA. conduct? All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 37 www.finra.org/brokercheck User Guidance

Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: CERTIFICATION Sanction Details: THE FIRM WAS CENSURED, FINED $750,000 AND ORDERED TO REVIEW AND REVISE, AS NECESSARY, THEIR SYSTEMS, POLICIES AND PROCEDURES WITH RESPECT TO THE SUPERVISION OF THEIR DUALLY- REGISTERED REPRESENTATIVES' (DRRS) SECURITIES TRANSACTIONS AND WITHIN 90 DAYS CERTIFY THAT IT HAS ENGAGED IN THE REVIEW AND THAT THEY HAVE ESTABLISHED AND IMPLEMENTED SYSTEMS, POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FINRA RULES. FINE PAID IN FULL ON JANUARY 27, 2021. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUPERVISE CERTAIN PRIVATE SECURITIES TRANSACTIONS OF DUALLY- REGISTERED REPRESENTATIVES (DRRS) WHO WERE ASSOCIATED WITH OUTSIDE REGISTERED INVESTMENTS ADVISORS (RIAS) AND HAD UNREASONABLE SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES (WSPS) TO SUPERVISE PRIVATE SECURITIES TRANSACTIONS THAT THE DRRS RECOMMENDED THROUGH THE OUTSIDE RIAS. THE FINDINGS STATED THAT THE FIRM WAS AWARE OF THE SUPERVISORY DEFICIENCIES AS THEY WERE IDENTIFIED IN SECURITIES AND EXCHANGE COMMISSION (SEC) EXAMINATIONS, YET, DESPITE SEVERAL EFFORTS TO ADDRESS SUCH DEFICIENCIES, IT FAILED TO IMPLEMENT SYSTEMS AND PROCEDURES TO REASONABLY SUPERVISE THE TRANSACTIONS. THE FIRM ALSO INITIATED A PROJECT TO OBTAIN THE INFORMATION NECESSARY TO SUPERVISE OUTSIDE RIA TRANSACTIONS FOR DRRS. THIS PROJECT, HOWEVER, WAS NOT COMPLETED AND THE AUTOMATED SYSTEM FOR OUTSIDE RIA TRANSACTION REVIEW WAS NOT IMPLEMENTED. IN RESPONSE TO THE SEC'S EXAMINATION FINDINGS, THE FIRM STATED THAT IT EXPECTED TO ESTABLISH AN ELECTRONIC CONNECTION TO OBTAIN ELECTRONIC REPORTING INFORMATION (I.E., A DATA FEED) BY THE END OF ©2021 FINRA. All rights reserved. Report aboutSEPTEMBER CETERA ADVISOR 2015 TO NETWORKS CAPTURE, LLC MONITOR, AND SUPERVISE OUTSIDE RIA 38 TRANSACTIONS. THE FIRM ESTABLISHED SUPERVISORY PROCEDURES TO ENSURE THAT OUTSIDE RIA TRANSACTIONS WERE CONSISTENT WITH CLIENTS' INVESTMENT OBJECTIVES AND OTHER SUITABILITY CONSIDERATIONS AND PROCESSES FOR OBTAINING INFORMATION ABOUT ITS DRRS' OUTSIDE RIA TRANSACTIONS. HOWEVER, THE DATA FEED WAS PROVIDED BY THIRD-PARTY CUSTODIANS THAT SOMETIMES RESTRICTED ACCESS TO THE INFORMATION AND, ON OCCASION, CUT OFF THE FIRM'S ACCESS TO THE INFORMATION. THE FIRM DID NOT RECEIVE AUTOMATED DATA FEEDS FROM ALL CUSTODIANS UNTIL JUNE 2018, AND, THUS, DID NOT HAVE ACCESS TO INFORMATION ABOUT CERTAIN OUTSIDE RIA ACCOUNTS THAT WERE NOT CUSTODIED AT ITS CLEARING FIRM. EVEN AFTER THE FIRM BEGAN RECEIVING THE TRANSACTION DATA, IT DID NOT RECEIVE COMPLETE CUSTOMER-SPECIFIC ACCOUNT INFORMATION FOR ALL ACCOUNTS AND, THUS, COULD NOT SATISFY ITS SUPERVISORY OBLIGATIONS INCLUDING, BUT NOT LIMITED TO, A SUITABILITY REVIEW OF ALL ACCOUNT TRANSACTIONS. THE FINDINGS ALSO STATED THAT DUE TO THE FIRM'S SUPERVISORY FAILURES, IT FAILED TO RECORD DRR PRIVATE SECURITIES TRANSACTIONS CONDUCTED THROUGH ITS OUTSIDE RIAS ON ITS BOOKS AND RECORDS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUPERVISE CERTAIN PRIVATE SECURITIES TRANSACTIONS OF DUALLY- REGISTERED REPRESENTATIVES (DRRS) WHO WERE ASSOCIATED WITH OUTSIDE REGISTERED INVESTMENTS ADVISORS (RIAS) AND HAD UNREASONABLE SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES (WSPS) TO SUPERVISE PRIVATE SECURITIES TRANSACTIONS THAT THE DRRS RECOMMENDED THROUGH THE OUTSIDE RIAS. THE FINDINGS STATED THAT THE FIRM WAS AWARE OF THE SUPERVISORY DEFICIENCIES AS THEY WERE IDENTIFIED IN SECURITIES AND EXCHANGE COMMISSION (SEC) EXAMINATIONS, YET, DESPITE SEVERAL EFFORTS TO ADDRESS SUCH DEFICIENCIES, IT FAILED TO IMPLEMENT SYSTEMS AND PROCEDURES TO REASONABLY SUPERVISE THE TRANSACTIONS. THE FIRM ALSO INITIATED A PROJECT TO OBTAIN THE INFORMATION NECESSARY TO SUPERVISE OUTSIDE RIA TRANSACTIONS FOR DRRS. THIS PROJECT, HOWEVER, WAS NOT COMPLETED AND THE AUTOMATED SYSTEM FOR OUTSIDE RIA www.finra.org/brokercheck TRANSACTION REVIEW WAS NOT IMPLEMENTED. IN RESPONSE TO THE User Guidance SEC'S EXAMINATION FINDINGS, THE FIRM STATED THAT IT EXPECTED TO ESTABLISH AN ELECTRONIC CONNECTION TO OBTAIN ELECTRONIC REPORTING INFORMATION (I.E., A DATA FEED) BY THE END OF SEPTEMBER 2015 TO CAPTURE, MONITOR, AND SUPERVISE OUTSIDE RIA TRANSACTIONS. THE FIRM ESTABLISHED SUPERVISORY PROCEDURES TO ENSURE THAT OUTSIDE RIA TRANSACTIONS WERE CONSISTENT WITH CLIENTS' INVESTMENT OBJECTIVES AND OTHER SUITABILITY CONSIDERATIONS AND PROCESSES FOR OBTAINING INFORMATION ABOUT ITS DRRS' OUTSIDE RIA TRANSACTIONS. HOWEVER, THE DATA FEED WAS PROVIDED BY THIRD-PARTY CUSTODIANS THAT SOMETIMES RESTRICTED ACCESS TO THE INFORMATION AND, ON OCCASION, CUT OFF THE FIRM'S ACCESS TO THE INFORMATION. THE FIRM DID NOT RECEIVE AUTOMATED DATA FEEDS FROM ALL CUSTODIANS UNTIL JUNE 2018, AND, THUS, DID NOT HAVE ACCESS TO INFORMATION ABOUT CERTAIN OUTSIDE RIA ACCOUNTS THAT WERE NOT CUSTODIED AT ITS CLEARING FIRM. EVEN AFTER THE FIRM BEGAN RECEIVING THE TRANSACTION DATA, IT DID NOT RECEIVE COMPLETE CUSTOMER-SPECIFIC ACCOUNT INFORMATION FOR ALL ACCOUNTS AND, THUS, COULD NOT SATISFY ITS SUPERVISORY OBLIGATIONS INCLUDING, BUT NOT LIMITED TO, A SUITABILITY REVIEW OF ALL ACCOUNT TRANSACTIONS. THE FINDINGS ALSO STATED THAT DUE TO THE FIRM'S SUPERVISORY FAILURES, IT FAILED TO RECORD DRR PRIVATE SECURITIES TRANSACTIONS CONDUCTED THROUGH ITS OUTSIDE RIAS ON ITS BOOKS AND RECORDS. Initiated By: FINRA Date Initiated: 12/15/2020 Docket/Case Number: 2015046716901

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/15/2020 Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: CERTIFICATION Sanction Details: THE FIRM WAS CENSURED, FINED $750,000 AND ORDERED TO REVIEW AND REVISE, AS NECESSARY, THEIR SYSTEMS, POLICIES AND PROCEDURES WITH RESPECT TO THE SUPERVISION OF THEIR DUALLY- REGISTERED REPRESENTATIVES' (DRRS) SECURITIES TRANSACTIONS AND WITHIN 90 DAYS CERTIFY THAT IT HAS ENGAGED IN THE REVIEW AND ©2021 FINRA. All rights reserved. Report aboutTHAT CETERA THEY ADVISOR HAVE ESTABLISHED NETWORKS LLC AND IMPLEMENTED SYSTEMS, POLICIES 39 AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FINRA RULES. www.finra.org/brokercheck THE FIRM WAS CENSURED, FINED $750,000 AND ORDERED TO REVIEW User Guidance AND REVISE, AS NECESSARY, THEIR SYSTEMS, POLICIES AND PROCEDURES WITH RESPECT TO THE SUPERVISION OF THEIR DUALLY- REGISTERED REPRESENTATIVES' (DRRS) SECURITIES TRANSACTIONS AND WITHIN 90 DAYS CERTIFY THAT IT HAS ENGAGED IN THE REVIEW AND THAT THEY HAVE ESTABLISHED AND IMPLEMENTED SYSTEMS, POLICIES AND PROCEDURES THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FINRA RULES. i Disclosure 4 of 17 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO RESPOND REASONABLY TO RED FLAGS OF UNSUITABLE MUTUAL FUND SWITCHING AND UNSUITABLE STOCK TRADING INTENDED TO CONCEAL THE SWITCHING BY ONE OF ITS REGISTERED REPRESENTATIVES. THE FINDINGS STATED THAT THE REPRESENTATIVE'S DESIGNATED SUPERVISORS DETECTED EVIDENCE OF HIS UNSUITABLE TRADING THROUGH ANNUAL AUDITS AND ELECTRONIC TRADE REPORTS AND SUBMITTED THEIR FINDINGS TO THE FIRM'S HOME OFFICE. THE FIRM'S ELECTRONIC TRADE REVIEW SYSTEM REPEATEDLY FLAGGED TRADES IN THE REPRESENTATIVE'S CUSTOMER ACCOUNTS, GENERATING HUNDREDS OF EXCEPTIONS THAT WERE INCORPORATED INTO THE ANNUAL AUDIT REPORTS WHICH ALSO DOCUMENTED HIS UNEXPLAINED AND UNJUSTIFIED SHORT-TERM CLASS A MUTUAL FUND SWITCHING AND RAISED QUESTIONS RELATING TO HIS RECORD KEEPING. NEITHER THE FIRM, NOR THE DESIGNATED SUPERVISORS, WHO WERE REGISTERED WITH FINRA THROUGH THE FIRM, BUT EMPLOYED BY AN OUTSIDE COMPANY THAT PROVIDED BACK OFFICE AND COMPLIANCE SUPPORT, TOOK ANY DISCIPLINARY ACTION AGAINST THE REPRESENTATIVE WHOSE UNSUITABLE TRADING CAUSED NEARLY $700,000 IN CUSTOMER LOSSES. THE DESIGNATED SUPERVISORS DID NOT HAVE AUTHORITY TO TERMINATE OR TAKE OTHER SIGNIFICANT DISCIPLINARY ACTION AGAINST THE REPRESENTATIVE ON THEIR OWN. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO HAVE A REASONABLE SYSTEM OVERSEEING THE REPRESENTATIVE'S DESIGNATED SUPERVISORS. THE FIRM PERMITTED AN INDIVIDUAL OUTSIDE OF THE LICENSED SUPERVISORY CHAIN TO DIRECT THE DESIGNATED SUPERVISORS ON MATTERS RELATING TO THE REPRESENTATIVE'S SUPERVISION. FURTHERMORE, AS THE SALES MANAGER'S COMPENSATION WAS BASED IN PART ON THE PROFITABILITY OF THE BRANCH, AND THUS ON THE REPRESENTATIVES COMMISSIONS, THE SALES MANAGER HAD A FINANCIAL INCENTIVE TO NOT RESTRICT HIS PRODUCTION. Initiated By: FINRA Date Initiated: 12/19/2018

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 40 www.finra.org/brokercheck User Guidance

Docket/Case Number: 2014040951702

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/19/2018 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $700,000.00 Disgorgement/Restitution Other Sanctions Ordered: CERTIFICATION AND UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $700,000, ORDERED TO PAY $691,755.27, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS, UNDERTAKES TO SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS, TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC AND SHALL CERTIFY THAT IT HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES, AND INTERNAL CONTROLS REASONABLY DESIGNED TO ADDRESS AND REMEDIATE THE ISSUES IDENTIFIED IN THE AWC. FINES PAID IN FULL ON JANUARY 9, 2019. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY RESPOND TO RED FLAGS OF A REGISTERED REPRESENTATIVE'S MISCONDUCT AND FAILED TO ESTABLISH A REASONABLE SUPERVISORY SYSTEM IN CONNECTION WITH MUTUAL FUND SWITCHING AND STOCK TRADING. THE FINDINGS STATED THAT EVEN THOUGH DESIGNATED SUPERVISORS DETECTED AND PASSED ON ©2021 FINRA. All rights reserved. Report aboutTHEIR CETERA FINDINGS ADVISOR OF NETWORKS POTENTIALLY LLC UNSUITABLE TRADING VIA ANNUAL 41 AUDIT REPORTS TO THE FIRM'S HOME OFFICE, THE FIRM DID NOT REVIEW THE RED FLAGS AND FAILED TO TAKE DISCIPLINARY ACTION AGAINST A REGISTERED REPRESENTATIVE. ALTHOUGH THE FIRM TASKED THE REGISTERED REPRESENTATIVE'S DESIGNATED SUPERVISORS WITH CONDUCTING AUDITS THAT DETECTED THE UNSUITABLE TRADING THEY WERE NOT EMPOWERED TO FIRE OR TAKE OTHER SIGNIFICANT DISCIPLINARY ACTION ON THEIR OWN. AS A RESULT, GIVEN THE DESIGN OF THE SYSTEM, NO ONE AT THE FIRM ADDRESSED THE MISCONDUCT RAISED IN THOSE REPORTS. THE FIRM ALSO FAILED TO HAVE A REASONABLE SYSTEM OVERSEEING THE REGISTERED REPRESENTATIVE'S DESIGNATED SUPERVISORS THAT PROVIDED BACK OFFICE AND COMPLIANCE SUPPORT TO THE FIRM'S REGISTERED REPRESENTATIVES. IN PARTICULAR, THE FIRM PERMITTED A NON- SUPERVISOR EMPLOYED BY AN OUTSIDE COMPANY TO EXERCISE CONTROL OVER THE DESIGNATED SUPERVISORS WITH RESPECT TO SUPERVISORY MATTERS. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO www.finra.org/brokercheck REASONABLY RESPOND TO RED FLAGS OF A REGISTERED User Guidance REPRESENTATIVE'S MISCONDUCT AND FAILED TO ESTABLISH A REASONABLE SUPERVISORY SYSTEM IN CONNECTION WITH MUTUAL FUND SWITCHING AND STOCK TRADING. THE FINDINGS STATED THAT EVEN THOUGH DESIGNATED SUPERVISORS DETECTED AND PASSED ON THEIR FINDINGS OF POTENTIALLY UNSUITABLE TRADING VIA ANNUAL AUDIT REPORTS TO THE FIRM'S HOME OFFICE, THE FIRM DID NOT REVIEW THE RED FLAGS AND FAILED TO TAKE DISCIPLINARY ACTION AGAINST A REGISTERED REPRESENTATIVE. ALTHOUGH THE FIRM TASKED THE REGISTERED REPRESENTATIVE'S DESIGNATED SUPERVISORS WITH CONDUCTING AUDITS THAT DETECTED THE UNSUITABLE TRADING THEY WERE NOT EMPOWERED TO FIRE OR TAKE OTHER SIGNIFICANT DISCIPLINARY ACTION ON THEIR OWN. AS A RESULT, GIVEN THE DESIGN OF THE SYSTEM, NO ONE AT THE FIRM ADDRESSED THE MISCONDUCT RAISED IN THOSE REPORTS. THE FIRM ALSO FAILED TO HAVE A REASONABLE SYSTEM OVERSEEING THE REGISTERED REPRESENTATIVE'S DESIGNATED SUPERVISORS THAT PROVIDED BACK OFFICE AND COMPLIANCE SUPPORT TO THE FIRM'S REGISTERED REPRESENTATIVES. IN PARTICULAR, THE FIRM PERMITTED A NON- SUPERVISOR EMPLOYED BY AN OUTSIDE COMPANY TO EXERCISE CONTROL OVER THE DESIGNATED SUPERVISORS WITH RESPECT TO SUPERVISORY MATTERS. Initiated By: FINRA Date Initiated: 12/19/2018 Docket/Case Number: 2014040951702

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/19/2018 Sanctions Ordered: Censure Monetary/Fine $700,000.00 Disgorgement/Restitution Other Sanctions Ordered: CERTIFICATION AND UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, FINED $700,000, ORDERED TO PAY $691,755.27, PLUS INTEREST, IN RESTITUTION TO CUSTOMERS, UNDERTAKES TO SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS, TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC AND SHALL CERTIFY THAT IT HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES, AND ©2021 FINRA. All rights reserved. Report aboutINTERNAL CETERA CONTROLSADVISOR NETWORKS REASONABLY LLC DESIGNED TO ADDRESS AND 42 REMEDIATE THE ISSUES IDENTIFIED IN THE AWC. THE FIRM WAS CENSURED, FINED $700,000, ORDERED TO PAY $691,755.27, www.finra.org/brokercheck PLUS INTEREST, IN RESTITUTION TO CUSTOMERS, UNDERTAKES TO User Guidance SUBMIT SATISFACTORY PROOF OF PAYMENT OF RESTITUTION, OR OF REASONABLE AND DOCUMENTED EFFORTS, TO FINRA NO LATER THAN 120 DAYS AFTER ACCEPTANCE OF THE AWC AND SHALL CERTIFY THAT IT HAS ESTABLISHED AND IMPLEMENTED POLICIES, PROCEDURES, AND INTERNAL CONTROLS REASONABLY DESIGNED TO ADDRESS AND REMEDIATE THE ISSUES IDENTIFIED IN THE AWC. i Disclosure 5 of 17 Reporting Source: Regulator Current Status: Final Allegations: THE DIVISION ALLEGED RESPONDENT ENGAGED IN DISHONEST OR UNETHICAL PRACTICES UNDER SECTION 61-1-6(2)(A)(II)(G) OF THE UTAH UNIFORM SECURITIES ACT (ACT) AND FAILED TO REASONABLY SUPERVISE UNDER SECTION 61-1-6(2)(A)(II)(J) OF THE ACT. Initiated By: UTAH Date Initiated: 04/05/2018 Docket/Case Number: SD-18-0014 URL for Regulatory Action: HTTPS://SECURITIES.UTAH.GOV/DOCKETS/18001401.PDF Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/09/2019 Sanctions Ordered: Censure Monetary/Fine $199,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE FINE WAS PAID IN FULL ON 4/16/2019. Regulator Statement A PDF OF THE CONSENT ORDER MAY BE VIEWED ONLINE AT: HTTPS://SECURITIES.UTAH.GOV/DOCKETS/18001437.PDF i Reporting Source: Firm Current Status: Final Allegations: THE DIVISION ALLEGED RESPONDENT ENGAGED IN DISHONEST OR ©2021 FINRA. All rights reserved. Report aboutUNETHICAL CETERA ADVISOR PRACTICES NETWORKS UNDER LLC SECTION 61-1-6(2)(A)(II)(G) OF THE UTAH 43 UNIFORM SECURITIES ACT (ACT) AND FAILED TO REASONABLY SUPERVISE UNDER SECTION 61-1-6(2)(A)(II)(J) OF THE ACT. www.finra.org/brokercheck User Guidance

Allegations: THE DIVISION ALLEGED RESPONDENT ENGAGED IN DISHONEST OR UNETHICAL PRACTICES UNDER SECTION 61-1-6(2)(A)(II)(G) OF THE UTAH UNIFORM SECURITIES ACT (ACT) AND FAILED TO REASONABLY SUPERVISE UNDER SECTION 61-1-6(2)(A)(II)(J) OF THE ACT. Initiated By: UTAH Date Initiated: 04/05/2018 Docket/Case Number: SD-18-0014

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Stipulation and Consent Resolution Date: 04/09/2019 Sanctions Ordered: Censure Monetary/Fine $199,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: THE FINE WAS PAID IN FULL ON 4/16/2019. Firm Statement A PDF OF THE CONSENT ORDER MAY BE VIEWED ONLINE AT: HTTPS://SECURITIES.UTAH.GOV/DOCKETS/18001437.PDF i Disclosure 6 of 17 Reporting Source: Firm Current Status: Final Allegations: CETERA ADVISOR NETWORKS APPLIED FOR RENEWAL OF ITS NONRESIDENTIAL BUSINESS ENTITY INSURANCE PRODUCER LICENSE ON OR ABOUT MARCH 20, 2017, WITH THE OKLAHOMA INSURANCE DEPARTMENT (OID). ON THE APPLICATION FORM, THE SECOND QUESTION ASKS THE FOLLOWING: "HAS THE BUSINESS ENTITY OR ANY OWNER, PARTNER, OFFICER OR DIRECTOR OF THE BUSINESS ENTITY, OR MANAGER OR MEMBER OF A LIMITED LIABILITY COMPANY, EVER BEEN NAMED OR INVOLVED AS A PARTY IN AN ADMINISTRATIVE PROCEEDING, INCLUDING A FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) SANCTION OR ARBITRATION PROCEEDING REGARDING ANY ©2021 FINRA. All rights reserved. Report aboutPROFESSIONAL CETERA ADVISOR OR NETWORKS OCCUPATIONAL LLC LICENSE, OR REGISTRATION?" 44 CETERA ADVISOR NETWORKS ANSWERED "NO" TO THIS QUESTION. A BACKGROUND CHECK CONDUCTED BY THE OID LICENSING DIVISION SHOWED THAT CETERA ADVISOR NETWORKS (CAN) HAD THE FOLLOWING ADMINISTRATIVE ACTION LISTED ON ITS RECORD: AN ADMINISTRATIVE ACTION BY THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION. CAN ENTERED INTO A CONSENT ORDER ON JANUARY 27, 2017 REGARDING FAILURE TO REGISTER ADVISOR REPRESENTATIVES WITH THE COMMONWEALTH. CAN WAS ORDERED TO CEASE AND DESIST, AND FINED ONE HUNDRED FIFTY THOUSAND DOLLARS ($150,000.00). ACCORDINGLY, CAN DID NOT PROPERLY DISCLOSE THE AFOREMENTIONED ADMINISTRATIVE ACTION IN THE LICENSE APPLICATION. CETERA ADVISOR NETWORKS APPLIED FOR RENEWAL OF ITS NONRESIDENTIAL BUSINESS ENTITY INSURANCE PRODUCER LICENSE ON OR ABOUT MARCH 20, 2017, WITH THE OKLAHOMA INSURANCE DEPARTMENT (OID). ON THE APPLICATION FORM, THE SECOND QUESTION ASKS THE FOLLOWING: "HAS THE BUSINESS ENTITY OR ANY OWNER, www.finra.org/brokercheck PARTNER, OFFICER OR DIRECTOR OF THE BUSINESS ENTITY, OR User Guidance MANAGER OR MEMBER OF A LIMITED LIABILITY COMPANY, EVER BEEN NAMED OR INVOLVED AS A PARTY IN AN ADMINISTRATIVE PROCEEDING, INCLUDING A FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) SANCTION OR ARBITRATION PROCEEDING REGARDING ANY PROFESSIONAL OR OCCUPATIONAL LICENSE, OR REGISTRATION?" CETERA ADVISOR NETWORKS ANSWERED "NO" TO THIS QUESTION. A BACKGROUND CHECK CONDUCTED BY THE OID LICENSING DIVISION SHOWED THAT CETERA ADVISOR NETWORKS (CAN) HAD THE FOLLOWING ADMINISTRATIVE ACTION LISTED ON ITS RECORD: AN ADMINISTRATIVE ACTION BY THE COMMONWEALTH OF MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION. CAN ENTERED INTO A CONSENT ORDER ON JANUARY 27, 2017 REGARDING FAILURE TO REGISTER ADVISOR REPRESENTATIVES WITH THE COMMONWEALTH. CAN WAS ORDERED TO CEASE AND DESIST, AND FINED ONE HUNDRED FIFTY THOUSAND DOLLARS ($150,000.00). ACCORDINGLY, CAN DID NOT PROPERLY DISCLOSE THE AFOREMENTIONED ADMINISTRATIVE ACTION IN THE LICENSE APPLICATION. Initiated By: OKLAHOMA INSURANCE DEPARTMENT Date Initiated: 05/13/2017 Docket/Case Number: 17-0254-DEN

Principal Product Type: Insurance Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Order Resolution Date: 05/13/2017 Sanctions Ordered: Monetary/Fine $300.00 Other Sanctions Ordered: Sanction Details: THE $300.00 FINE IS TO BE PAID WITHIN THIRTY (30) DAYS MADE PAYABLE TO THE OKLAHOMA INSURANCE DEPARTMENT. CAN'S RENEWAL APPLICATION FOR ITS NONRESIDENT BUSINESS ENTITY INSURANCE PRODUCER LICENSE MAY BE GRANTED UPON RECEIPT OF PAYMENT OF THE FINE. IT IS FURTHER ORDERED, ADJUDGED AND DECREED BY THE INSURANCE COMMISSIONER THAT THIS ORDER IS A CONDITIONAL ORDER. UNLESS CAN REQUESTS A HEARING WITH RESPECT TO THE ALLEGATIONS OF FACT SET FORTH ABOVE WITHIN THIRTY (30) DAYS OF DATE OF MAILING OF THIS ORDER (04/13/2017, THIS ORDER AND THE PENALTIES SET FORTH ABOVE SHALL BECOME A FINAL ORDER ON THE THIRTY-FIRST DAY FOLLOWING THE DATE OF MAILING THIS ORDER.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 45 www.finra.org/brokercheck User Guidance

i Disclosure 7 of 17 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THE FINDINGS STATED THAT MANY MUTUAL FUNDS WAIVE THE UP-FRONT SALES CHARGES ASSOCIATED WITH CLASS A SHARES FOR CERTAIN RETIREMENT PLANS AND/OR CHARITABLE ORGANIZATIONS. SOME OF THE MUTUAL FUNDS AVAILABLE ON THE FIRM'S RETAIL PLATFORM OFFERED SUCH WAIVERS AND DISCLOSED THOSE WAIVERS IN THEIR PROSPECTUSES. NOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILED TO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BY ELIGIBLE CUSTOMERS AND INSTEAD SOLD THE CUSTOMERS CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THESE SALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY. THE DIFFERENT SALES CHARGES, BREAKPOINTS, WAIVERS AND FEES ASSOCIATED WITH DIFFERENT SHARE CLASSES AFFECT MUTUAL FUND INVESTORS' RETURNS. IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER AND PURCHASED CLASS A SHARES, THE INVESTOR WILL NOT PAY A FRONT-END SALES LOAD. IN CONTRAST, A PURCHASE OF CLASS B OR C SHARES OF THE SAME FUND WILL BE SUBJECT TO HIGHER ONGOING FEES, AS WELL AS A POTENTIAL APPLICATION OF A CONTINGENT DEFERRED SALES CHARGE. THEREFORE, IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER, THERE WOULD BE NO REASON FOR THE INVESTOR TO PURCHASE ANY OTHER CLASS OF SHARES THAT HAS A SALES LOAD AND/OR HIGHER ANNUAL EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE MUTUAL FUND SALES TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. FOR INSTANCE, THE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFY APPLICABLE SALES CHARGE WAIVERS IN FUND'S PROSPECTUSES FOR ELIGIBLE CUSTOMERS. IN ADDITION, THE FIRM ©2021 FINRA. All rights reserved. Report aboutFAILED CETERA TO ADVISORADEQUATELY NETWORKS NOTIFY LLC AND TRAIN ITS FINANCIAL ADVISORS 46 REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. FINALLY, THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES.

THE FINDINGS ALSO INCLUDED THAT THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER IT PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS. BASED ON THIS REVIEW, THE FIRM SELF- REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS MAY NOT HAVE RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATED THAT APPROXIMATELY 722 CUSTOMER ACCOUNTS PURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALES CHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, IT ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY AT LEAST $1,666,404 FOR MUTUAL FUND PURCHASES MADE. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THE FINDINGS STATED THAT MANY MUTUAL FUNDS WAIVE THE UP-FRONT SALES CHARGES ASSOCIATED WITH CLASS A SHARES FOR CERTAIN RETIREMENT PLANS AND/OR CHARITABLE ORGANIZATIONS. SOME OF THE MUTUAL FUNDS AVAILABLE ON THE FIRM'S RETAIL PLATFORM OFFERED SUCH WAIVERS AND DISCLOSED THOSE WAIVERS IN THEIR PROSPECTUSES. NOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILED TO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BY ELIGIBLE CUSTOMERS AND INSTEAD SOLD THE CUSTOMERS CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THESE SALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY. THE DIFFERENT SALES CHARGES, BREAKPOINTS, WAIVERS AND FEES ASSOCIATED WITH DIFFERENT SHARE CLASSES AFFECT MUTUAL FUND INVESTORS' RETURNS. IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER AND PURCHASED CLASS A SHARES, THE INVESTOR WILL NOT PAY A FRONT-END SALES LOAD. IN CONTRAST, A PURCHASE OF CLASS B OR C SHARES OF THE SAME FUND WILL BE SUBJECT TO HIGHER ONGOING FEES, AS WELL AS A POTENTIAL APPLICATION OF A CONTINGENT DEFERRED SALES CHARGE. THEREFORE, IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER, THERE WOULD BE NO REASON FOR THE INVESTOR TO PURCHASE ANY OTHER CLASS OF SHARES THAT HAS A SALES LOAD AND/OR HIGHER ANNUAL EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE MUTUAL FUND SALES TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN www.finra.org/brokercheck ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL User Guidance ADVISORS IN MAKING THIS DETERMINATION. FOR INSTANCE, THE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFY APPLICABLE SALES CHARGE WAIVERS IN FUND'S PROSPECTUSES FOR ELIGIBLE CUSTOMERS. IN ADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. FINALLY, THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES.

THE FINDINGS ALSO INCLUDED THAT THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER IT PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS. BASED ON THIS REVIEW, THE FIRM SELF- REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS MAY NOT HAVE RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATED THAT APPROXIMATELY 722 CUSTOMER ACCOUNTS PURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALES CHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, IT ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY AT LEAST $1,666,404 FOR MUTUAL FUND PURCHASES MADE. Initiated By: FINRA Date Initiated: 05/03/2017 Docket/Case Number: 2016050258801

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/03/2017 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 47 www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED, REQUIRED TO PAY A TOTAL OF $1,911,080, INCLUSIVE OF INTEREST, IN RESTITUTION TO ELIGIBLE CUSTOMERS, AND WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS, AND REQUIRED TO PROVIDE REMEDIATION TO ELIGIBLE CUSTOMERS WHO, FROM JULY 1, 2009, QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS WHEN THE FIRM FAILED TO IDENTIFY AND APPLY AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE RETIREMENT ACCOUNTS AND CHARITABLE ORGANIZATIONS. THE FIRM WILL PROVIDE TO FINRA A DETAILED PLAN TO REMEDIATE ELIGIBLE CUSTOMERS BASED ON SPECIFIC CRITERIA THAT ARE NOT UNACCEPTABLE TO FINRA. THE FIRM WILL ALSO ADDRESS RESTITUTION FOR EACH RETIREMENT PLAN CUSTOMER THAT, WHILE NOT ELIGIBLE TO PURCHASE CLASS A SHARES WITHOUT A FRONT-END SALES CHARGE, WAS ELIGIBLE TO PURCHASE AN ALTERNATIVE SHARE CLASS (INCLUDING, BUT NOT LIMITED TO, R SHARES) WITHOUT A FRONT-END SALES CHARGE AND WITH ONGOING FEES SUBSTANTIALLY SIMILAR TO THOSE OF THE CLASS A SHARE. THE FIRM WILL SUBMIT TO FINRA A SCHEDULE OF ELIGIBLE CUSTOMERS IDENTIFIED FOR REMEDIATION AND INCLUDE THE DETAILS OF THE QUALIFYING PURCHASES AND TOTAL DOLLAR AMOUNTS OF RESTITUTION THAT WILL BE PROVIDED TO EACH CUSTOMER. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THE FINDINGS STATED THAT MANY MUTUAL FUNDS WAIVE THE UP-FRONT SALES CHARGES ASSOCIATED WITH CLASS A SHARES FOR CERTAIN RETIREMENT PLANS AND/OR CHARITABLE ORGANIZATIONS. SOME OF THE MUTUAL FUNDS AVAILABLE ON THE FIRM'S RETAIL PLATFORM OFFERED SUCH WAIVERS AND DISCLOSED THOSE WAIVERS IN THEIR PROSPECTUSES. NOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILED TO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BY ELIGIBLE CUSTOMERS AND INSTEAD SOLD THE CUSTOMERS CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THESE SALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY. THE DIFFERENT SALES CHARGES, ©2021 FINRA. All rights reserved. Report aboutBREAKPOINTS, CETERA ADVISOR WAIVERS NETWORKS AND LLC FEES ASSOCIATED WITH DIFFERENT SHARE 48 CLASSES AFFECT MUTUAL FUND INVESTORS' RETURNS. IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER AND PURCHASED CLASS A SHARES, THE INVESTOR WILL NOT PAY A FRONT-END SALES LOAD. IN CONTRAST, A PURCHASE OF CLASS B OR C SHARES OF THE SAME FUND WILL BE SUBJECT TO HIGHER ONGOING FEES, AS WELL AS A POTENTIAL APPLICATION OF A CONTINGENT DEFERRED SALES CHARGE. THEREFORE, IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER, THERE WOULD BE NO REASON FOR THE INVESTOR TO PURCHASE ANY OTHER CLASS OF SHARES THAT HAS A SALES LOAD AND/OR HIGHER ANNUAL EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE MUTUAL FUND SALES TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. FOR INSTANCE, THE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFY APPLICABLE SALES CHARGE WAIVERS IN FUND'S PROSPECTUSES FOR ELIGIBLE CUSTOMERS. IN ADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. FINALLY, THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. THE FINDINGS ALSO INCLUDED THAT THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER IT PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS. BASED ON THIS REVIEW, THE FIRM SELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS MAY NOT HAVE RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATED THAT APPROXIMATELY 722 CUSTOMER ACCOUNTS PURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALES CHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, IT ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY AT LEAST $1,666,404 FOR MUTUAL FUND PURCHASES MADE. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN AND CHARITABLE ORGANIZATION CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONT-END SALES CHARGE (ELIGIBLE CUSTOMERS). THE FINDINGS STATED THAT MANY MUTUAL FUNDS WAIVE THE UP-FRONT SALES CHARGES ASSOCIATED WITH CLASS A SHARES FOR CERTAIN RETIREMENT PLANS AND/OR CHARITABLE ORGANIZATIONS. SOME OF THE MUTUAL FUNDS AVAILABLE ON THE FIRM'S RETAIL PLATFORM OFFERED SUCH WAIVERS AND DISCLOSED THOSE WAIVERS IN THEIR PROSPECTUSES. NOTWITHSTANDING THE AVAILABILITY OF THE WAIVERS, THE FIRM FAILED TO APPLY THE WAIVERS TO MUTUAL FUND PURCHASES MADE BY ELIGIBLE CUSTOMERS AND INSTEAD SOLD THE CUSTOMERS CLASS A SHARES WITH A FRONT-END SALES CHARGE OR CLASS B OR C SHARES www.finra.org/brokercheck WITH BACK-END SALES CHARGES AND HIGHER ONGOING FEES AND User Guidance EXPENSES. THESE SALES DISADVANTAGED ELIGIBLE CUSTOMERS BY CAUSING SUCH CUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY. THE DIFFERENT SALES CHARGES, BREAKPOINTS, WAIVERS AND FEES ASSOCIATED WITH DIFFERENT SHARE CLASSES AFFECT MUTUAL FUND INVESTORS' RETURNS. IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER AND PURCHASED CLASS A SHARES, THE INVESTOR WILL NOT PAY A FRONT-END SALES LOAD. IN CONTRAST, A PURCHASE OF CLASS B OR C SHARES OF THE SAME FUND WILL BE SUBJECT TO HIGHER ONGOING FEES, AS WELL AS A POTENTIAL APPLICATION OF A CONTINGENT DEFERRED SALES CHARGE. THEREFORE, IF AN INVESTOR QUALIFIES FOR A CLASS A SALES CHARGE WAIVER, THERE WOULD BE NO REASON FOR THE INVESTOR TO PURCHASE ANY OTHER CLASS OF SHARES THAT HAS A SALES LOAD AND/OR HIGHER ANNUAL EXPENSES. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE MUTUAL FUND SALES TO ENSURE THAT ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. FOR INSTANCE, THE FIRM FAILED TO ESTABLISH AND MAINTAIN WRITTEN PROCEDURES TO IDENTIFY APPLICABLE SALES CHARGE WAIVERS IN FUND'S PROSPECTUSES FOR ELIGIBLE CUSTOMERS. IN ADDITION, THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS FOR ELIGIBLE CUSTOMERS. FINALLY, THE FIRM FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY DID NOT PROVIDE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS IN CONNECTION WITH THEIR MUTUAL FUND PURCHASES. THE FINDINGS ALSO INCLUDED THAT THE FIRM BEGAN A REVIEW TO DETERMINE WHETHER IT PROVIDED AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS. BASED ON THIS REVIEW, THE FIRM SELF-REPORTED TO FINRA THAT ELIGIBLE CUSTOMERS MAY NOT HAVE RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FIRM ESTIMATED THAT APPROXIMATELY 722 CUSTOMER ACCOUNTS PURCHASED MUTUAL FUND SHARES FOR WHICH AN AVAILABLE SALES CHARGE WAIVER WAS NOT APPLIED. AS A RESULT OF THE FAILURE OF THE FIRM TO APPLY AVAILABLE SALES CHARGE WAIVERS, IT ESTIMATED THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY AT LEAST $1,666,404 FOR MUTUAL FUND PURCHASES MADE. Initiated By: FINRA Date Initiated: 05/03/2017 Docket/Case Number: 2016050258801

Principal Product Type: Mutual Fund(s) Other Product Type(s): ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 49 www.finra.org/brokercheck User Guidance

Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 05/03/2017 Sanctions Ordered: Censure Disgorgement/Restitution Other Sanctions Ordered: UNDERTAKING Sanction Details: THE FIRM WAS CENSURED, REQUIRED TO PAY A TOTAL OF $1,911,080, INCLUSIVE OF INTEREST, IN RESTITUTION TO ELIGIBLE CUSTOMERS, AND WILL ALSO ENSURE THAT RETIREMENT AND CHARITABLE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS, AND REQUIRED TO PROVIDE REMEDIATION TO ELIGIBLE CUSTOMERS WHO, FROM JULY 1, 2009, QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS WHEN THE FIRM FAILED TO IDENTIFY AND APPLY AVAILABLE SALES CHARGE WAIVERS TO ELIGIBLE RETIREMENT ACCOUNTS AND CHARITABLE ORGANIZATIONS. THE FIRM WILL PROVIDE TO FINRA A DETAILED PLAN TO REMEDIATE ELIGIBLE CUSTOMERS BASED ON SPECIFIC CRITERIA THAT ARE NOT UNACCEPTABLE TO FINRA. THE FIRM WILL ALSO ADDRESS RESTITUTION FOR EACH RETIREMENT PLAN CUSTOMER THAT, WHILE NOT ELIGIBLE TO PURCHASE CLASS A SHARES WITHOUT A FRONT-END SALES CHARGE, WAS ELIGIBLE TO PURCHASE AN ALTERNATIVE SHARE CLASS (INCLUDING, BUT NOT LIMITED TO, R SHARES) WITHOUT A FRONT-END SALES CHARGE AND WITH ONGOING FEES SUBSTANTIALLY SIMILAR TO THOSE OF THE CLASS A SHARE. THE FIRM WILL SUBMIT TO FINRA A SCHEDULE OF ELIGIBLE CUSTOMERS IDENTIFIED FOR REMEDIATION AND INCLUDE THE DETAILS OF THE QUALIFYING PURCHASES AND TOTAL DOLLAR AMOUNTS OF RESTITUTION THAT WILL BE PROVIDED TO EACH CUSTOMER. i Disclosure 8 of 17 Reporting Source: Regulator Current Status: Final Allegations: COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER INVESTMENT ADVISER REPRESENTATIVES WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND ENSURE INVESTMENT ADVISER REPRESENTATIVES WERE PROPERLY REGISTERED WITH THE COMMONWEALTH. ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 50 www.finra.org/brokercheck COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER User Guidance INVESTMENT ADVISER REPRESENTATIVES WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND ENSURE INVESTMENT ADVISER REPRESENTATIVES WERE PROPERLY REGISTERED WITH THE COMMONWEALTH. Initiated By: MASSACHUSETTS Date Initiated: 01/27/2017 Docket/Case Number: 2016-0123 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ORDER Sought:

Resolution: Order Resolution Date: 01/27/2017 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Monetary/Fine $150,000.00 Other Sanctions Ordered: COMMONWEALTH OF MASSACHUSETTS REQUIRED INVESTMENT ADVISER REPRESENTATIVES WHO HAVE A PLACE OF BUSINESS IN MASSACHUSETTS TO REGISTER AS INVESTMENT ADVISER REPRESENTATIVES IF THEY INTEND TO PROVIDE ADVISORY SERVICES. IN ADDITION, RESPONDENT REVIEWED ITS POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS. Sanction Details: MONETARY FINE OF $150,000 PAID ON 02/02/2017 Regulator Statement MONETARY FINE OF $150,000 PAID AND MASSACHUSETTS INVESTMENT ADVISER REPRESENTATIVE REGISTRATION PROCEDURES REVIEWED TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS. i Reporting Source: Firm Current Status: Final Allegations: COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER INVESTMENT ADVISER REPRESENTATIVES WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND ENSURE INVESTMENT ADVISER ©2021 FINRA. All rights reserved. Report aboutREPRESENTATIVES CETERA ADVISOR NETWORKS WERE PROPERLY LLC REGISTERED WITH THE 51 COMMONWEALTH. www.finra.org/brokercheck User Guidance

COMMONWEALTH OF MASSACHUSETTS ALLEGED FAILURE TO REGISTER INVESTMENT ADVISER REPRESENTATIVES WHO HAD A PLACE OF BUSINESS IN MASSACHUSETTS AND ENSURE INVESTMENT ADVISER REPRESENTATIVES WERE PROPERLY REGISTERED WITH THE COMMONWEALTH. Initiated By: MASSACHUSETTS Date Initiated: 01/27/2017 Docket/Case Number: 2016-0123

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief ORDER Sought:

Resolution: Order Resolution Date: 01/27/2017 Sanctions Ordered: Monetary/Fine $150,000.00 Other Sanctions Ordered: COMMONWEALTH OF MASSACHUSETTS REQUIRED INVESTMENT ADVISER REPRESENTATIVES WHO HAVE A PLACE OF BUSINESS IN MASSACHUSETTS TO REGISTER AS INVESTMENT ADVISER REPRESENTATIVES IF THEY INTEND TO PROVIDE ADVISORY SERVICES. IN ADDITION, RESPONDENT REVIEWED ITS POLICIES AND PROCEDURES TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS. Sanction Details: MONETARY FINE OF $150,000 PAID ON 02/02/2017 Firm Statement MONETARY FINE OF $150,000 PAID AND MASSACHUSETTS INVESTMENT ADVISER REPRESENTATIVE REGISTRATION PROCEDURES REVIEWED TO ENSURE COMPLIANCE WITH REGISTRATION REQUIREMENTS. i Disclosure 9 of 17 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM ©2021 FINRA. All rights reserved. Report aboutFAILED CETERA TO ADVISORIMPLEMENT NETWORKS A SUPERVISORY LLC SYSTEM AND PROCEDURES 52 DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS.

THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L- SHARE CONTRACTS ARE ACCOMPANIED BY LONG-TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO IDENTIFY THE PATTERN OF RED FLAGS IN SUITABILITY REVIEWS AND CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON.

THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI-SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED REPRESENTATIVES DID NOT HAVE THE TOOLS TO PRESENT POTENTIAL PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS.

FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR CERTAIN VA EXCHANGES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS www.finra.org/brokercheck REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE User Guidance CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM FAILED TO IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS.

THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L- SHARE CONTRACTS ARE ACCOMPANIED BY LONG-TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO IDENTIFY THE PATTERN OF RED FLAGS IN SUITABILITY REVIEWS AND CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON.

THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI-SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED ©2021 FINRA. All rights reserved. Report aboutREPRESENTATIVES CETERA ADVISOR NETWORKS DID NOT LLCHAVE THE TOOLS TO PRESENT POTENTIAL 53 PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS.

FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR CERTAIN VA EXCHANGES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM FAILED TO IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS.

THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L- SHARE CONTRACTS ARE ACCOMPANIED BY LONG-TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO IDENTIFY THE PATTERN OF RED FLAGS IN SUITABILITY REVIEWS AND CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON.

THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI-SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA www.finra.org/brokercheck TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES User Guidance RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED REPRESENTATIVES DID NOT HAVE THE TOOLS TO PRESENT POTENTIAL PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS.

FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR CERTAIN VA EXCHANGES. Initiated By: FINRA Date Initiated: 11/02/2016 Docket/Case Number: 2015045234401

Principal Product Type: Other Other Product Type(s): MULTI-SHARE CLASS VARIABLE ANNUITIES(VA): L-SHARE VA'S (L-SHARE CONTRACTS) Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/02/2016 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: THE FIRM WAS CENSURED, FINED $750,000, AND REQUIRED TO CONDUCT UNDERTAKINGS. ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 54 THE FIRM WAS REQUIRED TO REVIEW AND REVISE, AS NECESSARY, THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE) AND TRAINING WITH RESPECT TO THE AREAS DESCRIBED WITHIN SECTION I.A OF THIS AWC. WITHIN 90 BUSINESS DAYS OF THE DATE THIS AWC IS ACCEPTED, THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT WITH RESPECT TO THE AREAS DESCRIBED IN SECTION I.A. OF THIS AWC: (I) THE FIRM HAS ENGAGED IN THE REVIEW; AND (II) AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED SYSTEMS AND POLICIES AND PROCEDURES (WRITTEN OR OTHERWISE) THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FINRA AND NASD RULES CITED IN THE AWC.

THE FIRM, WITHIN 120 DAYS OF THE DATE THIS AWC IS ACCEPTED BY FINRA, THE FIRM IS ORDERED TO PROVIDE PAYMENT TO ITS CUSTOMERS WHO PURCHASED FROM THE FIRM'S REGISTERED REPRESENTATIVE L- SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS AND NO PERSISTENCY CREDITS FROM NOVEMBER 1, 2011 THROUGH OCTOBER 30, 2016 AND WHO CURRENTLY HOLD THOSE CONTRACTS AT ANY AFFILIATE OF THE FIRM (THE "RESTITUTION VA CONTRACTS"), ACCORDING TO A PLAN NOT UNACCEPTABLE TO FINRA IN AN AMOUNT THAT WILL TOTAL NOT LESS THAN $4.5 MILLION. FINES PAID IN FULL ON NOVEMBER 21, 2016. www.finra.org/brokercheck User Guidance

Sanction Details: THE FIRM WAS CENSURED, FINED $750,000, AND REQUIRED TO CONDUCT UNDERTAKINGS.

THE FIRM WAS REQUIRED TO REVIEW AND REVISE, AS NECESSARY, THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE) AND TRAINING WITH RESPECT TO THE AREAS DESCRIBED WITHIN SECTION I.A OF THIS AWC. WITHIN 90 BUSINESS DAYS OF THE DATE THIS AWC IS ACCEPTED, THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT WITH RESPECT TO THE AREAS DESCRIBED IN SECTION I.A. OF THIS AWC: (I) THE FIRM HAS ENGAGED IN THE REVIEW; AND (II) AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED SYSTEMS AND POLICIES AND PROCEDURES (WRITTEN OR OTHERWISE) THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FINRA AND NASD RULES CITED IN THE AWC.

THE FIRM, WITHIN 120 DAYS OF THE DATE THIS AWC IS ACCEPTED BY FINRA, THE FIRM IS ORDERED TO PROVIDE PAYMENT TO ITS CUSTOMERS WHO PURCHASED FROM THE FIRM'S REGISTERED REPRESENTATIVE L- SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS AND NO PERSISTENCY CREDITS FROM NOVEMBER 1, 2011 THROUGH OCTOBER 30, 2016 AND WHO CURRENTLY HOLD THOSE CONTRACTS AT ANY AFFILIATE OF THE FIRM (THE "RESTITUTION VA CONTRACTS"), ACCORDING TO A PLAN NOT UNACCEPTABLE TO FINRA IN AN AMOUNT THAT WILL TOTAL NOT LESS THAN $4.5 MILLION. FINES PAID IN FULL ON NOVEMBER 21, 2016. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM FAILED TO IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L-SHARE CONTRACTS ARE ACCOMPANIED BY LONG- TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO ©2021 FINRA. All rights reserved. Report aboutIDENTIFY CETERA THE ADVISOR PATTERN NETWORKS OF RED LLC FLAGS IN SUITABILITY REVIEWS AND 55 CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON. THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI- SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED REPRESENTATIVES DID NOT HAVE THE TOOLS TO PRESENT POTENTIAL PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS. FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR CERTAIN VA EXCHANGES. WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM FAILED TO IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF www.finra.org/brokercheck SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A User Guidance LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L-SHARE CONTRACTS ARE ACCOMPANIED BY LONG- TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO IDENTIFY THE PATTERN OF RED FLAGS IN SUITABILITY REVIEWS AND CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON. THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI- SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED REPRESENTATIVES DID NOT HAVE THE TOOLS TO PRESENT POTENTIAL PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS. FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR ©2021 FINRA. All rights reserved. Report aboutCERTAIN CETERA VA ADVISOR EXCHANGES. NETWORKS LLC 56 WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A PROCESS REASONABLY DESIGNED TO SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATION OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO ITS CUSTOMERS. THE FINDINGS STATED THAT DESPITE THE SIGNIFICANT ROLE THAT VA SALES PLAYED IN THE RESPONDENT'S OVERALL BUSINESS, THE FIRM FAILED TO IMPLEMENT A SUPERVISORY SYSTEM AND PROCEDURES DESIGNED TO REASONABLY ENSURE SUITABILITY IN ITS MULTI-SHARE CLASS VA SALES, INCLUDING L-SHARE CONTRACTS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE SALE OF MULTI-SHARE CLASS VAS BY FAILING TO IDENTIFY AND ADDRESS RED FLAGS. SALES OF SHORT SURRENDER PERIOD L-SHARE CONTRACTS COMBINED WITH A LONG-TERM INCOME RIDER HAVE CONFLICTING TIME HORIZONS AND ARE RED FLAGS. WHEN L-SHARE CONTRACTS ARE ACCOMPANIED BY LONG- TERM INCOME RIDERS, AND WHERE THAT COMBINATION APPEARS IN A SIGNIFICANT NUMBER OF TRANSACTIONS, FIRMS SHOULD BE ABLE TO IDENTIFY THE PATTERN OF RED FLAGS IN SUITABILITY REVIEWS AND CONDUCT A MEANINGFUL HEIGHTENED REVIEW OF THOSE TRANSACTIONS. THE FIRM DID NOT IDENTIFY SALES OF L-SHARE CONTRACTS COMBINED WITH LONG-TERM INCOME RIDERS AS RED FLAGS DESPITE RECURRING PATTERNS OVER THE RELEVANT PERIOD. THE FIRM APPROVED L-SHARE CONTRACTS SOLD WITH A LONG-TERM INCOME RIDER WITHOUT IDENTIFYING OR SUFFICIENTLY INVESTIGATING THE SUITABILITY OF THE POTENTIALLY INCOMPATIBLE RECOMMENDATION. INDEED, IN MANY OF THESE TRANSACTIONS, THE CUSTOMER PURCHASING THE L-SHARE CONTRACT WITH A LONG-TERM INCOME RIDER HAD A LONG-TERM INVESTMENT HORIZON OF OVER SEVEN YEARS ACCORDING TO INFORMATION CONTAINED ON THE CUSTOMER'S VA APPLICATION. THE TRANSACTION COMBINED WITH THE INVESTMENT HORIZON WAS A RED FLAG THAT A DIFFERENT SHARE CLASS WITH LOWER FEES MAY HAVE BEEN MORE APPROPRIATE FOR THE CUSTOMER'S TIME HORIZON. THE FINDINGS ALSO INCLUDED THAT DESPITE THE FACT THAT A SIGNIFICANT PORTION OF THE FIRM'S ANNUAL REVENUES FROM VAS WERE GENERATED FROM L-SHARE CONTRACTS, IT FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND WSPS RELATED TO THE SALE OF MULTI- SHARE CLASS VAS. THE FIRMS FAILED TO PROVIDE SUFFICIENT TRAINING TO ITS REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS. THE FIRM'S WSPS AND TRAINING MATERIALS FAILED TO PROVIDE REGISTERED REPRESENTATIVES AND PRINCIPALS WITH SUFFICIENT GUIDANCE OR SUITABILITY CONSIDERATIONS FOR SALES OF DIFFERENT VA SHARE CLASSES. AS A RESULT, THE REGISTERED REPRESENTATIVES AND PRINCIPALS WHO WERE RESPONSIBLE FOR REVIEWING VA TRANSACTIONS, FAILED TO ADEQUATELY CONSIDER SUITABILITY ISSUES RELATED TO SHARE CLASS SELECTION. THEY ALSO FAILED TO IDENTIFY RED FLAGS IN VA RECOMMENDATIONS, INCLUDING SALES OF L-SHARE CONTRACTS TO CUSTOMERS WITH A LONG-TERM INVESTMENT HORIZON. BECAUSE OF THE LACK OF TRAINING AND GUIDANCE, REGISTERED REPRESENTATIVES DID NOT HAVE THE TOOLS TO PRESENT POTENTIAL PURCHASERS WITH A SIDE-BY-SIDE COMPARISON OF THE FEES AND SURRENDER CHARGES OR OTHER INFORMATION DETAILING THE POTENTIAL IMPACT OF THE INCREASED FEE IF THE L-SHARE CONTRACT WAS HELD BY THE CUSTOMER FOR A LONG TERM. IN ADDITION, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WSPS OR PROVIDE SUFFICIENT GUIDANCE OR TRAINING TO ITS REGISTERED www.finra.org/brokercheck REPRESENTATIVES AND ITS PRINCIPALS ON THE SALE OF LONG-TERM User Guidance INCOME RIDERS WITH MULTI-SHARE CLASS VAS, PARTICULARLY THE COMBINATION OF L-SHARE CONTRACTS WITH LONG-TERM INCOME RIDERS. FINRA FOUND THAT THE FIRM FAILED TO IMPLEMENT A REASONABLE SUPERVISORY SYSTEMS AND PROCEDURES TO MONITOR CERTAIN VA EXCHANGES. Initiated By: FINRA Date Initiated: 11/02/2016 Docket/Case Number: 2015045234401

Principal Product Type: Other Other Product Type(s): MULTI-SHARE CLASS VARIABLE ANNUITIES(VA): L-SHARE VA'S (L-SHARE CONTRACTS Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/02/2016 Sanctions Ordered: Censure Monetary/Fine $750,000.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: THE FIRM WAS CENSURED, FINED $750,000, AND REQUIRED TO CONDUCT UNDERTAKINGS. THE FIRM WAS REQUIRED TO REVIEW AND REVISE, AS NECESSARY, THE FIRM'S SYSTEMS, POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE) AND TRAINING WITH RESPECT TO THE AREAS DESCRIBED WITHIN SECTION I.A OF THIS AWC. WITHIN 90 BUSINESS DAYS OF THE DATE THIS AWC IS ACCEPTED, THE FIRM SHALL CERTIFY IN WRITING TO FINRA THAT WITH RESPECT TO THE AREAS DESCRIBED IN SECTION I.A. OF THIS AWC: (I) THE FIRM HAS ENGAGED IN THE REVIEW; AND (II) AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS ESTABLISHED AND IMPLEMENTED SYSTEMS AND POLICIES AND PROCEDURES (WRITTEN OR OTHERWISE) THAT ARE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE FINRA AND NASD RULES CITED IN THE AWC. THE FIRM, WITHIN 120 DAYS OF THE DATE THIS AWC IS ACCEPTED BY FINRA, THE FIRM IS ORDERED TO PROVIDE PAYMENT TO ITS CUSTOMERS WHO PURCHASED FROM THE FIRM'S REGISTERED REPRESENTATIVE L-SHARE CONTRACTS WITH LONG- TERM INCOME RIDERS AND NO PERSISTENCY CREDITS FROM NOVEMBER 1, 2011 THROUGH OCTOBER 30, 2016 AND WHO CURRENTLY HOLD THOSE CONTRACTS AT ANY AFFILIATE OF THE FIRM (THE "RESTITUTION VA CONTRACTS"), ACCORDING TO A PLAN NOT UNACCEPTABLE TO FINRA IN AN AMOUNT THAT WILL TOTAL NOT LESS THAN $4.5 MILLION.

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 57 www.finra.org/brokercheck User Guidance

i Disclosure 10 of 17 Reporting Source: Regulator Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $151,108.33. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS, DESPITE THE FACT THAT THE FIRM DID NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS. Initiated By: FINRA Date Initiated: 10/19/2015 Docket/Case Number: 2014041838501

Principal Product Type: Unit Investment Trust(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/19/2015 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure ©2021 FINRA. All rights reserved. Report aboutMonetary/Fine CETERA ADVISOR $150,000.00 NETWORKS LLC 58 Disgorgement/Restitution www.finra.org/brokercheck User Guidance

Sanctions Ordered: Censure Monetary/Fine $150,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM IS CENSURED, FINED $150,000, AND PAID RESTITUTION OF 151,108.33 TO CUSTOMERS. FINE PAID IN FULL ON NOVEMBER 10, 2015. i Reporting Source: Firm Current Status: Final Allegations: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHAREGS OF APPROXIMATELY $151,108.33. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS, DESPITE THE FACT THAT THE FIRM DID NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS. Initiated By: FINRA Date Initiated: 10/19/2015 Docket/Case Number: 2014041838501

Principal Product Type: Unit Investment Trust(s) Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 10/19/2015 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 59 www.finra.org/brokercheck User Guidance

Resolution Date: 10/19/2015 Sanctions Ordered: Censure Monetary/Fine $150,000.00 Disgorgement/Restitution Other Sanctions Ordered: Sanction Details: THE FIRM IS CENSURED, FINED $150,000, AND PAID RESTITUTION OF $151,108.33 TO CUSTOMERS i Disclosure 11 of 17 Reporting Source: Regulator Current Status: Final Allegations: FINRA BY-LAWS ARTICLE IV, SECTION 8, FINRA RULE 2010, NASD RULES 3010(A), 3010(B): FOR OVER TWO AND A HALF YEAR PERIOD, THE FIRM FAILED TO PROMPTLY FILE FORM BR AMENDMENTS, TO CORRECT MATERIAL DEFICIENCIES IN FORM BR FILINGS, WITHIN 30 DAYS AFTER THE FIRM LEARNED OF THE FACTS AND CIRCUMSTANCES NECESSITATING THE AMENDMENTS, THUS FAILING TO PROMPTLY ADVISE FINRA OF CHANGES TO THE INFORMATION REGARDING ITS BRANCH OFFICES. DURING AN EXAMINATION OF THE FIRM, FINRA FOUND CERTAIN FORM BR DEFICIENCIES FOR EACH OF THE FORM BR FILINGS REVIEWED, AND ASKED THE FIRM TO CONDUCT AN INTERNAL REVIEW OF ITS FORM BR FILINGS. ACCORDINGLY, THE FIRM DETERMINED IT FAILED TO FILE TIMELY AMENDMENTS TO CORRECT MATERIAL DEFICIENCIES IN FORM BR FILINGS FOR APPROXIMATELY 50.8 PERCENT OF ITS OFFICES. ALL OF THE AMENDMENTS TO FORMS BR FOLLOWING THE FIRM'S INTERNAL REVIEW WERE MADE MORE THAN 30 DAYS AFTER THE INFORMATION CHANGED. DURING THE PERIOD, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSP), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS. THE FIRM DID NOT HAVE A SYSTEM IN PLACE TO PERIODICALLY REVIEW FORM BR FILINGS FOR EACH BRANCH OFFICE, TO ENSURE THAT THE FIRM PROMPTLY AND TIMELY ADVISED FINRA REGARDING CHANGES TO THE INFORMATION FOR EACH REGISTERED BRANCH OFFICE. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REQUIRED ITS REGISTERED REPRESENTATIVES TO MAINTAIN A CURRENT AND ACCURATE FORM BR FOR EACH OFFICE WHERE A SECURITIES BUSINESS WAS CONDUCTED AND TO MAKE ANY AND TIMELY CHANGES TO SUCH INFORMATION. HOWEVER, THE PROCEDURES DID NOT INCLUDE PROVISIONS FOR MONITORING OR VERIFYING REPRESENTATIVES' COMPLIANCE WITH THE REQUIREMENT. Initiated By: FINRA

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Date Initiated: 12/03/2012 Docket/Case Number: 2011025788201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 12/03/2012 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED, FINED $40,000, AND AN UNDERTAKING TO, WITHIN 60 DAYS FROM THE EFFECTIVE DATE OF THIS LETTER OF ACCEPTANCE WAIVER AND CONSENT, CONDUCT A REVIEW OF ITS WRITTEN SUPERVISORY PROCEDURES AND SYSTEMS WITH RESPECT TO FORM BR, DETERMINE WHETHER ANY CHANGES ARE NECESSARY TO FULLY COMPLY WITH NASD RULES, INCLUDING, 3010(A) AND 3010(B), AND IF SO MAKE THOSE CHANGES, AND PROVIDE A WRITTEN REPORT TO FINRA DESCRIBING THE REVIEW, AND ANY CHANGES MADE TO WRITTEN SUPERVISORY PROCEDURES AND SYSTEMS. WITHIN 12 MONTHS OF THE DATE OF THE WRITTEN REPORT, THE FIRM SHALL REVIEW NOT LESS THAN 25 PERCENT OF FORMS BR ON FILE WITH FINRA, RANDOMLY SELECTED, TO DETERMINE THE ACCURACY OF SUCH FORMS BR AND PROVIDE A WRITTEN REPORT TO FINRA OF THE RESULTS OF ITS REVIEW. FINE PAID IN FULL ON 12/31/12. i Reporting Source: Firm

©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 61 www.finra.org/brokercheck User Guidance

Current Status: Final Allegations: FOR OVER A TWO AND HALF YEAR PERIOD, THE FIRM FAILED TO PROMPTLY FILE FORM BR AMENDMENTS, TO CORRECT MATERIAL DEFICIENCIES IN FORM BR FILINGS, WITHIN 30 DAYS AFTER THE FIRM LEARNED OF THE FACTS AND CIRCUMSTANCES NECESSITATING THE AMENDMENTS, THUS FAILING TO PROMPTLY ADVISE FINRA OF CHANGES TO THE INFORMATION REGARDING ITS BRANCH OFFICES. DURING AN EXAMINATION OF THE FIRM, FINRA FOUND CERTAIN FORM BR DEFICIENCIES FOR EACH OF THE FORM BR FILINGS REVIEWED, AND ASKED THE FIRM TO CONDUCT AN INTERNAL REVIEW OF ITS FORM BR FILINGS. ACCORDINGLY, THE FIRM DETERMINED IT FAILED TO FILE TIMELY AMENDMENTS TO CORRECT MATERIAL DEFICIENCIES IN FORM BR FILINGS FOR APPROXIMATELY 50.8 PERCENT OF ITS OFFICES. ALL OF THE AMENDMENTS TO FORMS BR FOLLOWING THE FIRM'S INTERNAL REVIEW WERE MADE MORE THAN 30 DAYS AFTER THE INFORMATION CHANGED. DURING THE PERIOD, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE RULES AND REGULATIONS. THE FIRM DID NOT HAVE A SYSTEM IN PLACE TO PERIODICALLY REVIEW FORM BR FILINGS FOR EACH BRANCH OFFICE, TO ENSURE THAT THE FIRM PROMPTLY AND TIMELY ADVISED FINRA REGARDING CHANGES TO THE INFORMATION FOR EACH REGISTERED BRANCH OFFICE. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES REQUIRED ITS REGISTERED REPRESENTATIVES TO MAINTAIN A CURRENT AND ACCURATE FORM BR FOR EACH OFFICE WHERE A SECURITIES BUSINESS WAS CONDUCTED AND TO MAKE ANY AND TIMELY CHANGES TO SUCH INFORMATION. HOWEVER, THE PROCEDURES DID NOT INCLUDE PROVISIONS FOR MONITORING OR VERIFYING REPRESENTATIVES' COMPLIANCE WITH THE REQUIREMENT. Initiated By: FINRA Date Initiated: 12/03/2012 Docket/Case Number: 2011025788201

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief N/A Sought:

Resolution: Acceptance, Waiver & Consent(AWC) ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 62 www.finra.org/brokercheck User Guidance

Resolution Date: 12/03/2012 Sanctions Ordered: Censure Monetary/Fine $40,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE FIRM WAS CENSURED, FINED $40,000 AND AGREED TO AN UNDERTAKING TO, WITHIN 60 DAYS FROM THE EFFECTIVE DATE OF THE AWC, CONDUCT A REVIEW OF THE FIRM'S WRITTEN SUPERVISORY PROCEDURES AND SYSTEMS WITH RESPECT TO FORM BR, DETERMINE WHETHER ANY CHANGES ARE NECESSARY TO FULLY COMPLY WITH NASD RULES, INCLUDING 3010(A) AND 3010(B), AND IF SO MAKE THOSE CHANGES, AND PROVIDE A WRITTEN REPORT TO FINRA DESCRIBING THE REVIEW AND ANY CHANGES MADE TO WRITTEN SUPERVISORY PROCEDURES AND SYSTEMS. WITHIN 12 MONTHS OF THE DATE OF THE WRITTEN REPORT, THE FIRM SHALL REVIEW NOT LESS THAN 25 PERCENT OF FORMS BR ON FILE WITH FINRA, RANDOMLY SELECTED, TO DETERMINE THE ACCURACY OF SUCH FORMS BR AND PROVIDE A WRITTEN REPORT TO FINRA OF THE RESULTS OF ITS REVIEW. FINE PAID IN FULL BY APPLICANT IN DECEMBER, 2012. i Disclosure 12 of 17 Reporting Source: Regulator Current Status: Final Allegations: THE ENFORCEMENT SECTION OF THE MISSOURI SECURITIES DIVISION HAS ALLEGED THAT FINANCIAL NETWORK INVESTMENT CORPORATION EMPLOYED AN UNREGISTERED AGENT IN VIOLATION OF SECTION 409.4- 402(D). Initiated By: MISSOURI SECURITIES DIVISION Date Initiated: 11/23/2010 Docket/Case Number: AP-10-38 URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Other Sought: Other Sanction(s)/Relief CONSENT Sought: ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 63 www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief CONSENT Sought:

Resolution: Consent Resolution Date: 02/22/2011 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $82,260.00 Other Sanctions Ordered: Sanction Details: RESPONDENT FNIC'S REGISTRATION IS HEREBY CENSURED. RESPONDENT FNIC SHALL PAY A FINE OF $40,000, $20,000 OF THIS PAYMENT WILL BE SUSPENDED IN LIGHT OF FNIC'S COOPERATION IN THE INVESTIGATION AND PROVIDED FNIC DOES NOT VIOLATE SECTIONS 409.4- 412(D)(2) AND 409.4-412(D)(9) OF THE MISSOURI SECURITIES ACT FOR A PERIOD OF 2 YEARS FROM THE EFFECTIVE DATE OF THIS ORDER. RESPONDENT FNIC SHALL PAY TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND THE SUM OF $40,000, $20,000 OF THIS PAYMENT WILL BE SUSPENDED IN LIGHT OF FNIC'S COOPERATION IN THE INVESTIGATION AND PROVIDED FNIC DOES NOT VIOLATE SECTIONS 409.4-412(D)(2) AND 409.4-412(D)(9) OF THE MISSOURI SECURITIES ACT FOR A PERIOD OF 2 YEARS FROM THE EFFECTIVE DATE OF THIS ORDER. RESPONDENT IS ORDERED TO PAY $2,260 AS THE COST OF THIS INVESTIGATION. RESPONDENT FNIC SHALL PAY ITS OWN COSTS AND ATTORNEYS' FEES WITH RESPECT TO THIS MATTER. i Reporting Source: Firm Current Status: Final Allegations: FIRM EMPLOYED UNREGISTERED AGENTS WHO TRANSACTED BUSINESS IN THE STATE OF MISSOURI IN VIOLATION OF SECTION 409.4-402(D). Initiated By: STATE OF MISSOURI, OFFICE OF SECRETARY OF STATE Date Initiated: 11/23/2010 Docket/Case Number: AP-10-38

Principal Product Type: Other

©2021Other FINRA. Product All rights Type(s): reserved. Report aboutCLOSED CETERA END ADVISOR FUND NETWORKS LLC 64 www.finra.org/brokercheck User Guidance

Other Product Type(s): CLOSED END FUND Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 02/22/2011 Sanctions Ordered: Censure Monetary/Fine $82,260.00 Other Sanctions Ordered: Sanction Details: FNIC'S REGISTRATION IS CENSURED AND FNIC SHALL PAY A FINE OF $40,000, $20,000 OF WHICH WILL BE SUSPENDED IN LIGHT OF FNIC'S COOPERATION IN THE INVESTIGATION, PROVIDED THAT FNIC DOES NOT VIOLATE SECTIONS 409.4-412(D)(2) AND 409.4-412(D)(9)OF THE MISSOURI SECURITIES ACT FOR A PERIOD OF 2 YEARS FROM THE EFFECTIVE DATE OF THIS ORDER. FNIC SHALL ALSO PAY TO THE MISSOURI SECRETARY OF STATE'S INVESTOR EDUCATION AND PROTECTION FUND THE SUM OF $40,000, $20,000 OF WHICH WILL BE SUSPENDED IN LIGHT OF FNIC'S COOPERATION IN THE INVESTIGATION, PROVIDED THAT FNIC DOES NOT VIOLATE SECTIONS 409.4-412(D)(2) AND 409.4-412(D)(9) OF THE MISSOURI SECURITIES ACT FOR A PERIOD OF 2 YEARS FROM THE EFFECTIVE DATE OF THIS ORDER. FNIC ALSO AGREES TO PAY $2,260 AS THE COST OF THIS INVESTIGATION TO THE STATE OF MISSOURI. Firm Statement THE MISSOURI SECURITIES DIVISION ALLEGES THAT IN AUGUST AND NOVEMBER OF 2010, REPRESENTATIVES STETSURA AND ROBERTSON CONTACTED PERSONS WITHIN THE SECURITIES DIVISION AND OFFERED TO SELL THEM SECURITIES. THE SECRITIES DIVISION ALSO ALLEGES THAT NEITHER STETSURA NOR ROBERTSON WERE REGISTERED OR GRANTED AN EXEMPTION FROM REGISTRATION TO TRANSACT BUSINESS AS AGENTS IN MISSOURI. AS A RESULT OF THESE SOLICITATIONS, THE SECURITIES DIVISION ALLEGES THAT FINANCIAL NETWORK EMPLOYED UNREGISTERED AGENTS WHO TRANSACTD BUSINESS IN MISSOURI. i Disclosure 13 of 17 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110, 3010, 6230(A) - FINANCIAL NETWORK INVESTMENT CORP. FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM ©2021 FINRA. All rights reserved. Report aboutHOURS CETERA WITHIN ADVISOR 45 MINUTESNETWORKS OFLLC THE TIME OF EXECUTION; AND THE FIRM'S 65 SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING REPORTING OF TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. www.finra.org/brokercheck User Guidance

NASD RULES 2110, 3010, 6230(A) - FINANCIAL NETWORK INVESTMENT CORP. FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 45 MINUTES OF THE TIME OF EXECUTION; AND THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND NASD RULES CONCERNING REPORTING OF TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES. Initiated By: FINRA Date Initiated: 09/21/2007 Docket/Case Number: 2005000178302

Principal Product Type: Other Other Product Type(s): TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/21/2007 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO REPORTING OF TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Reporting Source: Firm Current Status: Final Allegations: FINRA RULES 2110,3010,6230(A) - FINANCIAL NETWORK INVESTMENT ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 66 CORPORATION FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 45 MINUTES FOLLOWING THE TIME OF EXECUTION; AND THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING REPORTING OF TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES. www.finra.org/brokercheck User Guidance

Allegations: FINRA RULES 2110,3010,6230(A) - FINANCIAL NETWORK INVESTMENT CORPORATION FAILED TO REPORT TO TRACE TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES EXECUTED ON A BUSINESS DAY DURING TRACE SYSTEM HOURS WITHIN 45 MINUTES FOLLOWING THE TIME OF EXECUTION; AND THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO APPLICABLE SECURITIES LAWS, REGULATIONS AND FINRA RULES CONCERNING REPORTING OF TRANSACTIONS IN TRACE- ELIGIBLE SECURITIES. Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY Date Initiated: 09/21/2007 Docket/Case Number: 20050001783-02

Principal Product Type: Other Other Product Type(s): TRACE-ELIGIBLE SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE UNDERTAKING Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 09/21/2007 Sanctions Ordered: Censure Monetary/Fine $10,000.00 Other Sanctions Ordered: UNDERTAKING Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO REPORTING OF TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC. i Disclosure 14 of 17 Reporting Source: Regulator Current Status: Final Allegations: NASD RULES 2110 AND 2830(K)(1) - RESPONDENT MAINTAINED A SHELF SPACE (REVENUE SHARING) PROGRAM KNOWN AS THE STRATEGIC PARTNERS PLATFORM IN CONNECTION WITH RETAIL SALES OF MUTUAL FUNDS. IN RETURN FOR PAYMENTS, MUTUAL FUND COMPLEXES THAT ©2021 FINRA. All rights reserved. Report aboutPARTICIPATED CETERA ADVISOR IN THE NETWORKS PROGRAM LLC RECEIVED PREFERENTIAL TREATMENT 67 FROM THE FIRM IN THE SALES AND MARKETING OF THEIR FUNDS. THE PROGRAM PROVIDED INCREASED ACCESS TO THE FIRM'S RETAIL BROKERAGE SALES FORCE, PLACEMENT OF MATERIALS ON THE FIRM'S WEBSITES, IDENTIFICATION AS A STRATEGIC PARTNER ON THE ITS INTRANET WEBSITES INCLUDING LINKS TO THE STRATEGIC PARTNERS' WEBSITES AND PAYMENT OF TICKET CHARGES FOR RETAIL BROKERAGE SALES OF STRATEGIC PARTNERS' FUNDS. SOME MUTUAL FUND COMPLEXES MADE PAYMENTS FOR PARTICIPATING IN THE PROGRAM BY DIRECTING APPROXIMATELY $12.5 MILLION IN MUTUAL FUND PORTFOLIO BROKERAGE COMMISSIONS TO THE FIRM THOUGH CLEARING BROKERS. www.finra.org/brokercheck User Guidance NASD RULES 2110 AND 2830(K)(1) - RESPONDENT MAINTAINED A SHELF SPACE (REVENUE SHARING) PROGRAM KNOWN AS THE STRATEGIC PARTNERS PLATFORM IN CONNECTION WITH RETAIL SALES OF MUTUAL FUNDS. IN RETURN FOR PAYMENTS, MUTUAL FUND COMPLEXES THAT PARTICIPATED IN THE PROGRAM RECEIVED PREFERENTIAL TREATMENT FROM THE FIRM IN THE SALES AND MARKETING OF THEIR FUNDS. THE PROGRAM PROVIDED INCREASED ACCESS TO THE FIRM'S RETAIL BROKERAGE SALES FORCE, PLACEMENT OF MATERIALS ON THE FIRM'S WEBSITES, IDENTIFICATION AS A STRATEGIC PARTNER ON THE ITS INTRANET WEBSITES INCLUDING LINKS TO THE STRATEGIC PARTNERS' WEBSITES AND PAYMENT OF TICKET CHARGES FOR RETAIL BROKERAGE SALES OF STRATEGIC PARTNERS' FUNDS. SOME MUTUAL FUND COMPLEXES MADE PAYMENTS FOR PARTICIPATING IN THE PROGRAM BY DIRECTING APPROXIMATELY $12.5 MILLION IN MUTUAL FUND PORTFOLIO BROKERAGE COMMISSIONS TO THE FIRM THOUGH CLEARING BROKERS. Initiated By: NASD Date Initiated: 07/27/2006 Docket/Case Number: EAF0400760002

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/27/2006 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $3,415,000.00 Other Sanctions Ordered: Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, FINANCIAL NETWORK INVESTMENT CORP. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED AND FINED $3,415,000. i Reporting Source: ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 68 www.finra.org/brokercheck User Guidance

Reporting Source: Firm Current Status: Final Allegations: FINANCIAL NETWORK INVESTMENT CORPORATION AND ITS CONTROL AFFILIATES, ING FINANCIAL PARTNERS, INC., MULTI-FINANCIAL SECURITIES CORPORATION AND PRIMEVEST FINANCIAL SERVICES, INC. (THE "FIRMS") SIGNED AN AWC IN WHICH THE NASD FOUND THAT THE FIRMS MAINTAINED A STRATEGIC PARTNERS PROGRAM WHEREBY THE FIRMS RECEIVED DIRECTED BROKERAGE COMMISSIONS FROM MUTUAL FUNDS TO PAY FOR PARTICIPATION IN THE PROGRAM, WHICH VIOLATED NASD RULES 2830 (K)(I) AND 2110. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS (NASD) Date Initiated: 07/27/2006 Docket/Case Number: EAF0400760002

Principal Product Type: Mutual Fund(s) Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 07/27/2006 Sanctions Ordered: Censure Monetary/Fine $3,415,000.00 Other Sanctions Ordered: Sanction Details: TOTAL FINE $7,000,000 FINANCIAL NETWORK INVESTMENT CORPORATION - $3,415,000 ING FINANCIAL PARTNERS, INC. - $1,291,000 MULTI-FINANCIAL SECURITIES CORPORATION - $1,228,000 PRIMEVEST FINANCIAL SERVICES, INC. - $1,066,000 Firm Statement FINANCIAL NETWORK INVESTMENT CORPORATION AND ITS CONTROL AFFILIATES, ING FINANCIAL PARTNERS, MULTI-FINANCIAL SECURITIES CORPORATION AND PRIMEVEST FINANCIAL SERVICES, INC. (THE "FIRMS"), SIGNED AN AWC ON 7/27/06. THE FIRMS WERE FINED A TOTAL OF $7,000,000 AND CENSURED. FINANCIAL NETWORK INVESTMENT CORPORATION IS RESPONSIBLE FOR A FINE AMOUNT OF $3,415,000. i Disclosure 15 of 17 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 69 www.finra.org/brokercheck User Guidance

Disclosure 15 of 17 Reporting Source: Regulator Current Status: Final Allegations: ARTICLE V, SECTIONS 2(C) AND 3(B) OF NASD'S BY-LAWS, NASD RULES 2110, 3010, 3070 - FINANCIAL NETWORK INVESTMENT CORP. FILED 130 LATE AMENDMENTS TO FORMS U4 AND U5, REPRESENTING APPROXIMATELY 74% OF THE REQUIRED AMENDMENTS RELATING TO REPORTABLE CUSTOMER COMPLAINTS, TERMINATIONS, REGULATORY ACTIONS, AND CRIMINAL DISCLOSURES. THE FIRM'S SUPERVISORY SYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS ARTICLE V REPORTING OBLIGATIONS. NASD ALSO FOUND LATE FILINGS OF, AND FAILURES TO FILE, DISCLOSURES OF CUSTOMER COMPLAINTS IN ACCORDANCE WITH NASD RULE 3070 AND FAILURES TO FILE FORM U4 AMENDMENTS RELATING TO A CUSTOMER COMPLAINT. Initiated By: NASD Date Initiated: 11/30/2004 Docket/Case Number: CAF040112

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Sought: Other Sanction(s)/Relief Sought:

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/30/2004 Does the order constitute a No final order based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct? Sanctions Ordered: Censure Monetary/Fine $185,000.00 Other Sanctions Ordered: UNDERTAKINGS Sanction Details: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FINANCIAL NETWORK INVESTMENT CORP. CONSENTED TO THE DESCRIBED ©2021 FINRA. All rights reserved. Report aboutSANCTIONS CETERA ADVISOR AND TO NETWORKS THE ENTRY LLC OF FINDINGS, THEREFORE, IT IS 70 CENSURED, FINED $185,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. NO LATER THAN 60 DAYS AFTER THE DATE OF THE REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET FORTH THEREIN. www.finra.org/brokercheck User Guidance

WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, FINANCIAL NETWORK INVESTMENT CORP. CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE, IT IS CENSURED, FINED $185,000 WHICH SHALL BE PAID WITHIN 10 DAYS OF NOTICE OF ACCEPTANCE OF THIS AWC. PROMPTLY FOLLOWING NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM'S INTERNAL AUDIT DEPT. OR PERSONNEL NOT DIRECTLY RESPONSIBLE FOR THE FIRM'S ARTICLE V REPORTING OBLIGATIONS AND THEIR IMMEDIATE SUPERVISORS SHALL CONDUCT AN AUDIT FOR THE PERIOD JANUARY 1, 2004 THROUGH SEPTEMBER 30, 2004 TO ASSESS THE EFFECTIVENESS OF ITS SYSTEM AND PROCEDURES FOR ENSURING TIMELY FILING OF FORM U4 AND U5 AMENDMENTS SUMMARIZING FINDINGS AND RECOMMENDATIONS AND SHALL FOR THE NEXT FOUR CALENDAR QUARTERS BEGINNING FOURTH QUARTER 2004, CONDUCT A SIMILAR AUDIT AND PREPARE A SIMILAR WRITTEN AUDIT REPORT. NO LATER THAN 90 DAYS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER OF THE FIRM SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED AND THE OFFICER HAS REVIEWED THE CURRENT AUDIT REPORT. NO LATER THAN 60 DAYS AFTER THE DATE OF THE REPORT, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS IMPLEMENTED, OR HAS BEGUN TO IMPLEMENT, ANY RECOMMENDATIONS WITHIN A SPECIFIED TIME PERIOD. NO LATER THAN 60 DAYS AFTER THE LAST DAY OF THE NEXT FOUR QUARTERS, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT AN AUDIT WAS CONDUCTED, THE CURRENT AUDIT REPORT WAS REVIEWED, AND RECOMMENDATIONS IMPLEMENTED, OR BEGUN TO BE IMPLEMENTED. NO LATER THAN SIX MONTHS AFTER NOTICE OF ACCEPTANCE OF THIS AWC, AN OFFICER SHALL CERTIFY IN WRITING TO NASD THAT THE FIRM HAS REVIEWED ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS ARTICLE V REPORTING OBLIGATIONS AND HAS ESTABLISHED A SYSTEM AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REPORTING REQUIREMENTS SET FORTH THEREIN. i Reporting Source: Firm Current Status: Final Allegations: THE NASD ALLEGED THAT FROM JANUARY 2002 THROUGH MARCH 2004, FINANCIAL NETWORK INVESTMENT CORPORATION ("FN"), IN VIOLATION OF NASD CONDUCT RULES 2110, 3070, AND 3010,(I) FAILED TO TIMELY FILE, AS REQUIRED BY THE NASD'S BY-LAWS, CERTAIN AMENDMENTS TO FORMS U4 AND U5 AS WELL AS CERTAIN RULE 3070 REPORTS (HEREINAFTER REFERRED TO AS THE "REPORTING OBLIGATIONS") AND (II) THAT ITS SUPERVISORY SYSTEM AND PROCEDURES WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS REPORTING OBLIGATIONS. Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS Date Initiated: 11/30/2004 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 71 www.finra.org/brokercheck User Guidance

Date Initiated: 11/30/2004 Docket/Case Number: NASD CASE NO. CAF040112

Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief CENSURE Sought: UNDERTAKING

Resolution: Acceptance, Waiver & Consent(AWC) Resolution Date: 11/30/2004 Sanctions Ordered: Censure Monetary/Fine $185,000.00 Other Sanctions Ordered: FN, WITHOUT ADMITTING OR DENYING THE NASD'S ALLEGATIONS OR FINDINGS, WITHIN CERTAIN SPECIFIED TIME PERIODS, CONSENTED TO UNDERTAKE AUDITS AND COMPLETE OFFICER CERTIFICATIONS WITH RESPECT TO ITS REPORTING OBLIGATIONS AS WELL AS OFFICER CERTIFICATIONS WITH RESPECT TO ITS SYSTEM AND PROCEDURES FOR COMPLYING WITH ITS REPORTING OBLIGATIONS. Sanction Details: MONETARY FINE OF $185,000 PAID ON DECEMBER 3, 2004. Firm Statement FINAL RESOLUTION THROUGH ACCEPTANCE, WAIVER AND CONSENT. i Disclosure 16 of 17 Reporting Source: Regulator Current Status: Final Allegations: NOT PROVIDED Initiated By: FLORIDA DIVISION OF SECURITIES Date Initiated: 11/09/1992 Docket/Case Number: 1795-S-11/92 URL for Regulatory Action: Principal Product Type: Other Other Product Type(s): UNKNOWN CRD DATA CONVERSION Principal Sanction(s)/Relief Sought:

©2021Other FINRA. Sanction(s)/Relief All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 72 Sought: www.finra.org/brokercheck User Guidance

Other Sanction(s)/Relief Sought:

Resolution: Consent Resolution Date: 03/23/1993 Sanctions Ordered: Monetary/Fine $10,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: ON MARCH 23, 1993, THE FLORIDA DEPARTMENT OF BANKING AND FINANCE ENTERED INTO A FINAL ORDER AND STIPULATION AND CONSENT AGREEMENT WITH RESPONDENTS FINANCIAL NETWORK INVESTMENT CORPORATION, MILES Z. GORDON, STEVEN K. KLEIN AND KENT R. BIEHLER. RESPONDENT FINANCIAL NETWORK INVESTMENTT CORPORATION AGREES TO CEASE AND DESIST FROM ALL FUTURE VIOLATIONS OF CHAPTER 517, FLORIDA STATUTES, AND TO PAY A $10,000 ADMINISTRATIVE FINE. THE DEPARTMENT AGREED TO DISMISS THE ORIGINAL ADMINISTRATIVE COMPLAINT WITH RESPECT TO RESPONDENTS GORDON, KLEIN, AND BIEHLER. i Reporting Source: Firm Current Status: Final Allegations: STATE OF FLORIDA ALLEGED THAT FINANCIAL NETWORK FAILED TO COMPLETE REGISTRATION OF ONE BRANCH OFFICE WITH THE STATE Initiated By: STATE OF FLORIDA, OFFICE OF COMPTROLLER, DEPARTMENT OF BANKING AND FINANCE, DIVISON OF SECURITIES Date Initiated: 10/09/1992 Docket/Case Number: 1795-S-11/92

Principal Product Type: Mutual Fund(s) Other Product Type(s): GENERAL SECURITIES Principal Sanction(s)/Relief Civil and Administrative Penalt(ies) /Fine(s) Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent Resolution Date: 03/23/1993 Sanctions Ordered: Monetary/Fine $10,000.00 ©2021 FINRA. All rights reserved. Report aboutCease CETERA and Desist/Injunction ADVISOR NETWORKS LLC 73 www.finra.org/brokercheck User Guidance

Sanctions Ordered: Monetary/Fine $10,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: PURSUANT TO ORDER ISSUED BY STATE OF FLORIDA, DTD 3/19/93, FINANCIAL NETWORK'S BUSINESS WAS RESTRICTED FOR PERIOD OF ONE YEAR BEGINNING 11/24/92. FINANCIAL NETWORK WAS LIMITED TO OPENING 2 BRANCHES IN THE STATE OF FLORIDA. THE RESTRICTION WAS LIFTED AFTER A ONE YEAR TIME PERIOD. Firm Statement FINANCIAL NETWORK REGISTERED AN OSJ BRANCH IN THE STATE OF FLORIDA THROUGH THE CRD SYSTEM AND RECEIVED APPROVAL FROM THE NASD. ALSO FILED DOCUMENTS FOR REGISTRATION OF BRANCH WITH THE STATE OF FLORIDA AND OPERATED THE BRANCH BELIEVING THAT FILING WAS SUFFICIENT FOR PROPER REGISTRATION. FLORIDA DISMISSED COMPLAINT AGAINST MILES GORDON. i Disclosure 17 of 17 Reporting Source: Regulator Current Status: Final Allegations: ON 11-10-92, THE STATE OF FLORIDA, ENTERED A NOTICE OF INTENT TO DENY THE THREE BRANCH OFFICE APPLICATIONS FILED BY FINANCIAL NETWORK INVESTMENT CORPORATION FOR LOCATIONS IN DEERFIELD BEACH, BOCA RATON AND ALTAMONTE SPRINGS. THE DENIAL WAS BASED UPON THE DETERMINATION THAT THE DEALER IS THE SUBJECT OF A PENDING ENFORCEMENT ACTION. THE DENIAL IS NOT FINAL AND IS SUBJECT TO APPEAL. Initiated By: FL DOS Date Initiated: 11/10/1992 Docket/Case Number: 92.352.DOS URL for Regulatory Action: Principal Product Type: No Product Other Product Type(s): Principal Sanction(s)/Relief Cease and Desist Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 74 www.finra.org/brokercheck User Guidance

Resolution: Stipulation and Consent Resolution Date: 03/23/1993 Sanctions Ordered: Monetary/Fine $10,000.00 Cease and Desist/Injunction Other Sanctions Ordered: Sanction Details: NOT PROVIDED Regulator Statement NOT PROVIDED i Reporting Source: Firm Current Status: Final Allegations: DENIED THREE APPLICATIONS FOR REGISTRATION OF BRANCH OFFICES DUE TO PENDANCY OF ORDER & STIPULATION #1795-S-11/92 Initiated By: STATE OF FLORIDA, OFFICE OF COMPTROLLER DIV. OF SECURITIES Date Initiated: 11/10/1992 Docket/Case Number: 92-352.DOS

Principal Product Type: Mutual Fund(s) Other Product Type(s): GENERAL SECURITIES Principal Sanction(s)/Relief Denial Sought: Other Sanction(s)/Relief Sought:

Resolution: Stipulation and Consent Resolution Date: 03/23/1993 Sanctions Ordered: Revocation/Expulsion/Denial Other Sanctions Ordered: Sanction Details: DENIED THREE APPLICATIONS FOR REGISTRATION OF BRANCH OFFICES DUE TO PENDANCY OF ORDER & STIPULATION #1795-S-11/1992 ET SEQ. Firm Statement THE DETERMINATION OF THE STATE OF FLORIDA OFFICE OF COMPTROLLER, DIVISION OF SECURITIES TO RESTRICT REGISTRATION OF BRANCH OFFICES IN FLORIDA. THERE WAS NO FINE OR CEASE AND DESIST ORDER FOR THIS DENIAL ACTION. REFER TO 10/09/1992 FLORIDA CEASE AND DESIST ORDER, DOCKET #1795-S-11/92.

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Civil - Final This type of disclosure event involves (1) an injunction issued by a foreign or domestic court within the last 10 years in connection with investment-related activity, (2) a finding by a court of a violation of any investment-related statute or regulation, or (3) an action dismissed by a court pursuant to a settlement agreement. Disclosure 1 of 1 Reporting Source: Firm Current Status: Final Appellate Court Name and N/A Date Appeal Filed: Allegations: THE COMPLAINT ALLEGED THAT FROM ON OR ABOUT NOVEMBER 1998 THROUGH MAY 1999 AND IN VIOLATION OF REGISTRANT'S PROHIBITION AS SET FORTH IN A LETTER FROM THE REGISTRANT TO CERTAIN OF ITS REGISTERED REPRESENTATIVES, AND WITHOUT THE REGISTRANT'S KNOWLEDGE, CERTAIN REGISTERED REPRESENTATIVES SOLICITED PERSONS TO ENTER INTO CONTRACTS FOR THE PURCHASE OF CUSTOMER OWNED COIN OPERATED TELEPHONES FROM NATIONAL COMMUNICATIONS MARKETING, INC., AND THE LEASING OF THE UNITS TO ETS PAYPHONES, INC., FROM WHICH THE REGISTERED REPRESENTATIVES RECEIVED SALES COMMISSIONS WHICH WERE NEITHER RECEIVED BY, NOR REPORTED TO, THE REGISTRANT. THE COMPLAINT FURTHER ALLEGED THAT THE REGISTRANT'S REGISTERED REPRESENTATIVES CONCEALED THEIR INVOLVEMENT IN THE OFFER AND SALE OF THE CUSTOMER OWNED COIN OPERATED TELEPHONES FROM THE REGISTRANT. Initiated By: ATTORNEY GENERAL OF THE STATE OF NEW YORK Court Details: SUPREME COURT, STATE OF NEW YORK, ERIE COUNTY, INDEX NO. 1-2002-6226 Date Court Action Filed: 06/10/2002 Principal Product Type: Investment Contract(s) Other Product Types: Relief Sought: Restitution Other Relief Sought: CIVIL PENALTY FINE INJUNCTION Resolution: Settled Resolution Date: 12/06/2004 Sanctions Ordered or Relief Disgorgement/Restitution Granted:

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Other Sanctions: NONE Sanction Details: AS REQUIRED, REGISTRANT HAS DEPOSITED $1,650,000.00 AS RESTITUTION INTO AN ESCROW ACCOUNT, THE PROCEEDS OF WHICH ARE TO BE DISTRIBUTED TO THE PERSONS WHO ALLEGEDLY SUFFERED LOSSES FOR CONTRACTS PURCHASED THROUGH THE REGISTERED REPRESENTATIVES DURING THEIR RESPECTIVE REGISTRATIONS WITH REGISTRANT AND WHO SUBMIT VALID DOCUMENTATION OF THEIR CLAIMS ON OR BEFORE MAY 31, 2005. ANY REMAINING BALANCE FOR UNCLAIMED FUNDS AFTER MAY 31, 2005 WILL BE RETURNED TO REGISTRANT. UNKNOWN CLAIMANTS WILL BE PAID UNDER THE SAME TERMS, PRO RATA, AS OTHER SPECIAL UNKNOWN CLAIMANTS, BUT IN NO EVENT WILL REGISTRANT'S LIABILITY EXCEED THE STATED RESITUTION AMOUNT. Firm Statement CONTRARY TO AN EXPLICIT COMMUNICATION PROHIBITING ITS REGISTERED REPRESENTATIVES FROM ENGAGING IN THE SOLICITATION TO PERSONS TO ENTER INTO CONTRACTS FOR THE PURCHASE OF CUSTOMER OWNED COIN OPERATED TELEPHONES AND THE LEASING OF THOSE PHONES TO ETS PAYPHONES, INC. CERTAIN REGISTERED REPRESENTATIVES ENGAGED COVERTLY IN THESE TRANSACTIONS. DURING THE PERIOD OF NOVEMBER 1998 THROUGH MAY 12, 1999, ACCORDING TO THE ATTORNEY GENERAL'S INVESTIGATION, THE REPRESENTATIVES SOLD $3.4 MILLION WORTH OF ETS PAYPHONE CONTRACTS AND RECEIVED SALES COMMISSIONS REGARDING THESE SALES. NO SALES COMMISSIONS WERE RECEIVED BY OR REPORTED TO REGISTRANT. DESPITE CONCEDING THAT THE REGISTRANTS'S REGISTERED REPRESENTATIVES CONCEALED THEIR INVOLVEMENT IN ETS PAYPHONE CONTRACTS FROM THE REGISTRANT, THE STATE OF NEW YORK ALLEGED FAILURE TO SUPERVISE, REPEATED AND PERSISTENT FRAUDULENT OR ILLEGAL ACTIVITY AND CONSUMER FRAUD AGAINST ELDERLY PERSONS CAUSES OF ACTION AGAINST REGISTRANT. REGISTRANT ASSERTS THAT ALL PERTINENT LAWS OF THE STATE OF NEW YORK HAVE BEEN COMPLIED WITH, AS WELL AS COMPIANCE WITH INDUSTRY STANDARDS OF CONDUCT AND BELIEVED THAT IT HAD LEGAL DEFENSES. NONETHELESS, THE PARTIES AGREED TO SETTLE BECAUSE OF CONCERNS OF THE INVESTMENT LOSSES BY PURCHASERS.

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Civil - Pending This type of disclosure event involves a pending civil court action that with seek an injunction to cease certain investment- related activity or alleges a violation of any investment-related statute or regulation. Disclosure 1 of 1 Reporting Source: Regulator Current Status: Pending Allegations: SEC LITIGATION RELEASE 24643, OCTOBER 15, 2019: THE SECURITIES AND EXCHANGE COMMISSION FILED AN AMENDED COMPLAINT ON OCTOBER 11, 2019 ADDING CETERA ADVISOR NETWORKS LLC AS A DEFENDANT IN ITS PREVIOUSLY FILED ACTION AGAINST CETERA ADVISORS, LLC FOR DEFRAUDING RETAIL ADVISORY CLIENTS. THE ADDITION OF CETERA ADVISOR NETWORKS TO THE SEC'S ACTION BRINGS DEFENDANTS' TOTAL ALLEGED UNLAWFUL GAINS THAT THE SEC SEEKS TO RECOVER TO OVER $21 MILLION. ACCORDING TO THE SEC'S AMENDED COMPLAINT, FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO, CETERA ADVISOR NETWORKS BREACHED ITS FIDUCIARY DUTY AND DEFRAUDED RETAIL ADVISORY CLIENTS BY, AMONG OTHER THINGS, FAILING TO DISCLOSE CONFLICTS OF INTEREST RELATED TO THE FIRM'S RECEIPT OF UNDISCLOSED COMPENSATION IN THE FORM OF 12B-1 FEES, REVENUE SHARING, ADMINISTRATIVE FEES, AND MARK-UPS. DEFENDANTS VIOLATED THEIR FIDUCIARY DUTY TO ACT IN THEIR CLIENTS' BEST INTERESTS BY HAVING THEIR CLIENTS INVEST AND HOLD ASSETS IN HIGHER-COST SHARE CLASSES DESPITE KNOWING LOWER-COST SHARE CLASSES WERE AVAILABLE. CETERA ADVISORS AND CETERA ADVISOR NETWORKS RECEIVED AT LEAST $10 MILLION IN 12B-1 FEES AS A RESULT OF THEIR INVESTMENTS OF CLIENT ASSETS IN SHARE CLASSES THAT CHARGED 12B-1 FEES THAT THEY WOULD NOT HAVE COLLECTED HAD THOSE CLIENT ASSETS BEEN INVESTED IN THE AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS. DEFENDANTS MAINTAINED POLICIES AND PROCEDURES REQUIRING DISCLOSURE OF MATERIAL FACTS AND CONFLICTS OF INTEREST, AND THE PURCHASE OF SHARE CLASSES ON THE MUTUAL FUND BUY LISTS, BUT FAILED TO IMPLEMENT THOSE POLICIES. THE SEC'S INITIAL COMPLAINT AGAINST CETERA ADVISORS LLC, FILED IN FEDERAL COURT IN COLORADO IN AUGUST, CHARGED CETERA ADVISORS LLC WITH SIMILARLY FAILING TO ADEQUATELY DISCLOSE TO ITS ADVISORY CLIENTS UNLAWFUL PRACTICES CONCERNING UNDISCLOSED COMPENSATION AND THE CONFLICTS OF INTEREST ASSOCIATED WITH THEM. THE SEC'S AMENDED COMPLAINT CHARGES DEFENDANTS WITH VIOLATING THE ANTIFRAUD, FIDUCIARY, AND CONFLICTS OF INTEREST PROVISIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, AND SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT OF ILL-GOTTEN GAINS AND PREJUDGMENT INTEREST, ©2021 FINRA. All rights reserved. Report aboutAND CETERA CIVIL PENALTIES. ADVISOR NETWORKS LLC 78 SEC LITIGATION RELEASE 24643, OCTOBER 15, 2019: THE SECURITIES AND EXCHANGE COMMISSION FILED AN AMENDED COMPLAINT ON OCTOBER 11, 2019 ADDING CETERA ADVISOR NETWORKS LLC AS A DEFENDANT IN ITS PREVIOUSLY FILED ACTION AGAINST CETERA ADVISORS, LLC FOR DEFRAUDING RETAIL ADVISORY CLIENTS. THE ADDITION OF CETERA ADVISOR NETWORKS TO THE SEC'S ACTION BRINGS DEFENDANTS' TOTAL ALLEGED UNLAWFUL GAINS THAT THE SEC SEEKS TO RECOVER TO OVER $21 MILLION. ACCORDING TO THE SEC'S AMENDED COMPLAINT, FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO, CETERA ADVISOR NETWORKS BREACHED ITS FIDUCIARY DUTY AND DEFRAUDED RETAIL ADVISORY CLIENTS BY, AMONG OTHER THINGS, FAILING TO DISCLOSE CONFLICTS OF INTEREST RELATED TO THE FIRM'S RECEIPT OF UNDISCLOSED COMPENSATION IN THE FORM OF 12B-1 FEES, REVENUE SHARING, ADMINISTRATIVE FEES, AND MARK-UPS. DEFENDANTS VIOLATED THEIR FIDUCIARY DUTY TO ACT IN THEIR CLIENTS' BEST INTERESTS BY HAVING THEIR CLIENTS INVEST AND HOLD ASSETS IN HIGHER-COST SHARE CLASSES DESPITE KNOWING LOWER-COST SHARE CLASSES WERE AVAILABLE. CETERA ADVISORS AND CETERA ADVISOR NETWORKS RECEIVED AT LEAST $10 MILLION IN 12B-1 FEES AS A RESULT OF THEIR INVESTMENTS OF CLIENT ASSETS IN SHARE CLASSES THAT CHARGED 12B-1 FEES THAT THEY WOULD NOT HAVE COLLECTED HAD THOSE CLIENT ASSETS BEEN INVESTED IN THE AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS. DEFENDANTS MAINTAINED POLICIES AND PROCEDURES REQUIRING DISCLOSURE OF MATERIAL FACTS AND CONFLICTS OF INTEREST, AND THE PURCHASE OF SHARE CLASSES ON THE MUTUAL FUND BUY LISTS, BUT FAILED TO IMPLEMENT THOSE POLICIES. THE SEC'S INITIAL COMPLAINT AGAINST CETERA ADVISORS LLC, FILED IN FEDERAL COURT IN COLORADO IN AUGUST, CHARGED CETERA ADVISORS LLC WITH SIMILARLY FAILING TO ADEQUATELY DISCLOSE TO ITS ADVISORY CLIENTS UNLAWFUL PRACTICES CONCERNING UNDISCLOSED COMPENSATION AND THE CONFLICTS OF INTEREST ASSOCIATED WITH THEM. THE SEC'S AMENDED COMPLAINT CHARGES DEFENDANTS WITH VIOLATING THE ANTIFRAUD, www.finra.org/brokercheck FIDUCIARY, AND CONFLICTS OF INTEREST PROVISIONS OF SECTIONS User Guidance 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, AND SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT OF ILL-GOTTEN GAINS AND PREJUDGMENT INTEREST, AND CIVIL PENALTIES. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO - DENVER, CO - CASE NO. 1:19-CV-02461 Date Court Action Filed: 10/11/2019 Principal Product Type: Mutual Fund(s) Other Product Types: Relief Sought: Injunction Other Relief Sought: DISGORGEMENT; PRE-JUDGMENT INTEREST; CIVIL PENALTIES i Reporting Source: Firm Current Status: Pending Allegations: SEC LITIGATION RELEASE 24643, OCTOBER 15, 2019: THE SECURITIES AND EXCHANGE COMMISSION FILED AN AMENDED COMPLAINT ON OCTOBER 11, 2019 ADDING CETERA ADVISOR NETWORKS LLC AS A DEFENDANT IN ITS PREVIOUSLY FILED ACTION AGAINST CETERA ADVISORS, LLC FOR DEFRAUDING RETAIL ADVISORY CLIENTS. THE ADDITION OF CETERA ADVISOR NETWORKS TO THE SEC'S ACTION BRINGS DEFENDANTS' TOTAL ALLEGED UNLAWFUL GAINS THAT THE SEC SEEKS TO RECOVER TO OVER $21 MILLION. ACCORDING TO THE SEC'S AMENDED COMPLAINT, FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO, CETERA ADVISOR NETWORKS BREACHED ITS FIDUCIARY DUTY AND DEFRAUDED RETAIL ADVISORY CLIENTS BY, AMONG OTHER THINGS, FAILING TO DISCLOSE CONFLICTS OF INTEREST RELATED TO THE FIRM'S RECEIPT OF UNDISCLOSED COMPENSATION IN THE FORM OF 12B-1 FEES, REVENUE SHARING, ADMINISTRATIVE FEES, AND MARK-UPS. DEFENDANTS VIOLATED THEIR FIDUCIARY DUTY TO ACT IN THEIR CLIENTS' BEST INTERESTS BY HAVING THEIR CLIENTS INVEST AND HOLD ASSETS IN HIGHER-COST SHARE CLASSES DESPITE KNOWING LOWER-COST SHARE CLASSES WERE AVAILABLE. CETERA ADVISORS AND CETERA ADVISOR NETWORKS RECEIVED AT LEAST $10 MILLION IN 12B-1 FEES AS A RESULT OF THEIR INVESTMENTS OF CLIENT ASSETS IN SHARE CLASSES THAT CHARGED 12B-1 FEES THAT THEY WOULD NOT HAVE COLLECTED HAD THOSE CLIENT ASSETS BEEN INVESTED IN THE AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS. DEFENDANTS MAINTAINED POLICIES AND PROCEDURES REQUIRING DISCLOSURE OF MATERIAL FACTS AND CONFLICTS OF INTEREST, AND THE PURCHASE OF SHARE CLASSES ON THE MUTUAL FUND BUY LISTS, BUT FAILED TO IMPLEMENT THOSE POLICIES. THE SEC'S INITIAL COMPLAINT AGAINST CETERA ADVISORS LLC, FILED IN FEDERAL COURT IN COLORADO IN AUGUST, ©2021 FINRA. All rights reserved. Report aboutCHARGED CETERA CETERAADVISOR NETWORKS ADVISORS LLC LLC WITH SIMILARLY FAILING TO 79 ADEQUATELY DISCLOSE TO ITS ADVISORY CLIENTS UNLAWFUL PRACTICES CONCERNING UNDISCLOSED COMPENSATION AND THE CONFLICTS OF INTEREST ASSOCIATED WITH THEM. THE SEC'S AMENDED COMPLAINT CHARGES DEFENDANTS WITH VIOLATING THE ANTIFRAUD, FIDUCIARY, AND CONFLICTS OF INTEREST PROVISIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, AND SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT OF ILL-GOTTEN GAINS AND PREJUDGMENT INTEREST, AND CIVIL PENALTIES. CETERA ADVISOR NETWORKS IS CONFIDENT THAT ITS DISCLOSURES WERE ADEQUATE AND THAT IT HAS COMPLIED WITH THE SECURITIES LAWS. ACCORDINGLY, THE FIRM BELIEVES THAT IT HAS SIGNIFICANT DEFENSES TO THE SEC'S ALLEGATIONS THAT MAY RESULT IN A FAVORABLE RULING ON THE MERITS. SEC LITIGATION RELEASE 24643, OCTOBER 15, 2019: THE SECURITIES AND EXCHANGE COMMISSION FILED AN AMENDED COMPLAINT ON OCTOBER 11, 2019 ADDING CETERA ADVISOR NETWORKS LLC AS A DEFENDANT IN ITS PREVIOUSLY FILED ACTION AGAINST CETERA ADVISORS, LLC FOR DEFRAUDING RETAIL ADVISORY CLIENTS. THE ADDITION OF CETERA ADVISOR NETWORKS TO THE SEC'S ACTION BRINGS DEFENDANTS' TOTAL ALLEGED UNLAWFUL GAINS THAT THE SEC SEEKS TO RECOVER TO OVER $21 MILLION. ACCORDING TO THE SEC'S AMENDED COMPLAINT, FILED IN THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO, CETERA ADVISOR NETWORKS BREACHED ITS FIDUCIARY DUTY AND DEFRAUDED RETAIL ADVISORY CLIENTS BY, AMONG OTHER THINGS, FAILING TO DISCLOSE CONFLICTS OF INTEREST RELATED TO THE FIRM'S RECEIPT OF UNDISCLOSED COMPENSATION IN THE FORM OF 12B-1 FEES, REVENUE SHARING, ADMINISTRATIVE FEES, AND MARK-UPS. DEFENDANTS VIOLATED THEIR FIDUCIARY DUTY TO ACT IN THEIR CLIENTS' BEST INTERESTS BY HAVING THEIR CLIENTS INVEST AND HOLD ASSETS IN HIGHER-COST SHARE CLASSES DESPITE KNOWING LOWER-COST SHARE CLASSES WERE AVAILABLE. CETERA ADVISORS AND CETERA ADVISOR NETWORKS RECEIVED AT LEAST $10 MILLION IN 12B-1 FEES AS A RESULT OF THEIR INVESTMENTS OF CLIENT ASSETS IN SHARE CLASSES THAT CHARGED 12B-1 FEES THAT THEY WOULD NOT HAVE COLLECTED HAD THOSE CLIENT ASSETS BEEN INVESTED IN THE AVAILABLE LOWER-COST SHARE CLASSES OF THE SAME FUNDS. DEFENDANTS MAINTAINED www.finra.org/brokercheck POLICIES AND PROCEDURES REQUIRING DISCLOSURE OF MATERIAL User Guidance FACTS AND CONFLICTS OF INTEREST, AND THE PURCHASE OF SHARE CLASSES ON THE MUTUAL FUND BUY LISTS, BUT FAILED TO IMPLEMENT THOSE POLICIES. THE SEC'S INITIAL COMPLAINT AGAINST CETERA ADVISORS LLC, FILED IN FEDERAL COURT IN COLORADO IN AUGUST, CHARGED CETERA ADVISORS LLC WITH SIMILARLY FAILING TO ADEQUATELY DISCLOSE TO ITS ADVISORY CLIENTS UNLAWFUL PRACTICES CONCERNING UNDISCLOSED COMPENSATION AND THE CONFLICTS OF INTEREST ASSOCIATED WITH THEM. THE SEC'S AMENDED COMPLAINT CHARGES DEFENDANTS WITH VIOLATING THE ANTIFRAUD, FIDUCIARY, AND CONFLICTS OF INTEREST PROVISIONS OF SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER, AND SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT OF ILL-GOTTEN GAINS AND PREJUDGMENT INTEREST, AND CIVIL PENALTIES. CETERA ADVISOR NETWORKS IS CONFIDENT THAT ITS DISCLOSURES WERE ADEQUATE AND THAT IT HAS COMPLIED WITH THE SECURITIES LAWS. ACCORDINGLY, THE FIRM BELIEVES THAT IT HAS SIGNIFICANT DEFENSES TO THE SEC'S ALLEGATIONS THAT MAY RESULT IN A FAVORABLE RULING ON THE MERITS. Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION Court Details: UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO - DENVER, CO - CASE NO. 1:19-CV-02461 Date Court Action Filed: 10/11/2019 Principal Product Type: Mutual Fund(s) Other Product Types: Relief Sought: Injunction Other Relief Sought: DISGORGEMENT; PRE-JUDGMENT INTEREST; CIVIL PENALTIES

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Arbitration Award - Award / Judgment Brokerage firms are not required to report arbitration claims filed against them by customers; however, BrokerCheck provides summary information regarding FINRA arbitration awards involving securities and commodities disputes between public customers and registered securities firms in this section of the report. The full text of arbitration awards issued by FINRA is available at www.finra.org/awardsonline.

Disclosure 1 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/08/2000 Case Number: 00-03094 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $25,424.99 Disposition: AWARD AGAINST PARTY Disposition Date: 04/30/2001 Sum of All Relief Awarded: $18,545.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 2 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY-OTHER; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/26/2001 Case Number: 01-05481 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 81 www.finra.org/brokercheck User Guidance

Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $471,250.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/09/2003 Sum of All Relief Awarded: $729,064.75 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 3 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 12/13/2002 Case Number: 02-04208 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; UNKNOWN TYPE OF SECURITIES Sum of All Relief Requested: $248,338.00 Disposition: AWARD AGAINST PARTY Disposition Date: 03/07/2005 Sum of All Relief Awarded: $200,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 4 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT RELATED-FAILURE TO SUPERVISE ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 82 www.finra.org/brokercheck User Guidance

Arbitration Forum: NASD Case Initiated: 10/01/2002 Case Number: 02-05708 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $213,441.00 Disposition: AWARD AGAINST PARTY Disposition Date: 11/07/2003 Sum of All Relief Awarded: $200,025.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 5 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT RELATED-FAILURE TO SUPERVISE; ACCOUNT RELATED- NEGLIGENCE; ACCOUNT RELATED-OTHER; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE Arbitration Forum: NASD Case Initiated: 10/07/2004 Case Number: 04-07020 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; MUTUAL FUNDS Sum of All Relief Requested: $31,815.82 Disposition: AWARD AGAINST PARTY Disposition Date: 04/19/2005 Sum of All Relief Awarded: $16,425.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 6 of 15 Reporting Source: Regulator Type of Event: ARBITRATION

©2021Allegations: FINRA. All rights reserved. Report aboutACCOUNT CETERA ACTIVITY-BRCHADVISOR NETWORKS OF LLC FIDUCIARY DT; ACCOUNT RELATED-BREACH 83 OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS www.finra.org/brokercheck User Guidance

Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT RELATED-BREACH OF CONTRACT; ACCOUNT RELATED-ERRORS-CHARGES; ACCOUNT RELATED-MARGIN CALLS Arbitration Forum: NASD Case Initiated: 09/27/2005 Case Number: 05-04993 Disputed Product Type: ANNUITIES; COMMON STOCK; OTHER TYPES OF SECURITIES; PREFERRED STOCK Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 04/27/2007 Sum of All Relief Awarded: $642,187.01 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 7 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 08/02/1990 Case Number: 90-01869 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $76,400.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/16/1991 Sum of All Relief Awarded: $9,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 8 of 15

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Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-FAILURE TO SUPERVISE Arbitration Forum: NASD Case Initiated: 10/25/1991 Case Number: 91-03118 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $53,675.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/27/1992 Sum of All Relief Awarded: $45,224.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 9 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- CHURNING; ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 10/28/1991 Case Number: 91-03204 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; OPTIONS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/07/1992 Sum of All Relief Awarded: $94,768.00

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There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 10 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED-NEGLIGENCE Arbitration Forum: NASD Case Initiated: 02/04/1993 Case Number: 92-04231 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS Sum of All Relief Requested: $200,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 08/09/1993 Sum of All Relief Awarded: $53,500.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 11 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- SUITABILITY; ACCOUNT RELATED-NEGLIGENCE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 01/11/1994 Case Number: 93-05253 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; LIMITED PARTNERSHIPS; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $100,000.00 Disposition: AWARD AGAINST PARTY ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 86 www.finra.org/brokercheck User Guidance

Disposition: AWARD AGAINST PARTY Disposition Date: 03/16/1995 Sum of All Relief Awarded: $35,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 12 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY; ACCOUNT RELATED- NEGLIGENCE Arbitration Forum: NASD Case Initiated: 01/20/1995 Case Number: 95-00239 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; GOVERNMENT SECURITIES; LIMITED PARTNERSHIPS Sum of All Relief Requested: $1,948,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 12/27/2000 Sum of All Relief Awarded: $55,000.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 13 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-BRCH OF FIDUCIARY DT; ACCOUNT ACTIVITY- MISREPRESENTATION; ACCOUNT ACTIVITY-OMISSION OF FACTS; ACCOUNT ACTIVITY-SUITABILITY Arbitration Forum: NASD Case Initiated: 10/02/1996 Case Number: 96-03643 ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 87 www.finra.org/brokercheck User Guidance

Case Number: 96-03643 Disputed Product Type: DO NOT USE-NO OTHER TYPE OF SEC INVOLVE; REAL ESTATE INVESTMENT TRUST Sum of All Relief Requested: $500,000.00 Disposition: AWARD AGAINST PARTY Disposition Date: 10/09/1998 Sum of All Relief Awarded: $51,937.00 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 14 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: ACCOUNT ACTIVITY-MISREPRESENTATION; DO NOT USE-EXECUTIONS- FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD Case Initiated: 09/20/1996 Case Number: 96-03673 Disputed Product Type: COMMON STOCK; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $12,833.80 Disposition: AWARD AGAINST PARTY Disposition Date: 09/10/1997 Sum of All Relief Awarded: $15,179.21 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information. i Disclosure 15 of 15 Reporting Source: Regulator Type of Event: ARBITRATION Allegations: DO NOT USE-EXECUTIONS-FAILURE TO EXECUTE; DO NOT USE-NO OTHER CONTROVERSY INVOLVED Arbitration Forum: NASD ©2021 FINRA. All rights reserved. Report about CETERA ADVISOR NETWORKS LLC 88 www.finra.org/brokercheck User Guidance

Case Initiated: 11/30/1998 Case Number: 98-03603 Disputed Product Type: ANNUITIES; DO NOT USE-NO OTHER TYPE OF SEC INVOLVE Sum of All Relief Requested: $15,196.76 Disposition: AWARD AGAINST PARTY Disposition Date: 07/30/1999 Sum of All Relief Awarded: $7,100.82 There may be a non-monetary award associated with this arbitration. Please select the Case Number above to view more detailed information.

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