On July 16, 2020, First Western Capital Management Company (“FWCM”) settled an administrative proceeding where it agreed it purchased for advisory clients securities that were sold in reliance on Rule 144A under the Securities Act of 1933 (“Securities Act”) without having adequate compliance policies and procedures and without providing investment adviser representatives (“IARs”) training and supervision of Rule 144A securities. As a result, over a seven-year period, certain IARs purchased for 81 FWCM advisory clients a gross total of over $666 million worth of securities sold in reliance on Rule 144A when the clients were not qualified institutional buyers in a Rule 144A transaction.