harbour investments, inc

BrokerCheck Report

HARBOUR INVESTMENTS, INC.

Section Title

Report Summary

Firm History

CRD# 19258

1

7

Firm Profile 2 - 6

Page(s)

Firm Operations 8 - 13

Disclosure Events 14

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CRD# 19258

SEC# 8-37373

Main Office Location

575 D'ONOFRIO DRIVESUITE 300MADISON, WI 53719Regulated by FINRA Chicago Office

Mailing Address

575 D'ONOFRIO DRIVESUITE 300MADISON, WI 53719

This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:

Business Telephone Number

(608) 662-6100

https://www.adviserinfo.sec.gov

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 3

Bond 6

Firm Profile

This firm is classified as a corporation.

This firm was formed in Wisconsin on 01/22/1987.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 12 types of businesses.

This firm is not affiliated with any financial orinvestment institutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 52 U.S. states and territories

www.finra.org/brokercheck User Guidance

1©2022 FINRA. All rights reserved. Report about HARBOUR INVESTMENTS, INC.

https://adviserinfo.sec.gov/firm/summary/19258


http://www.finra.org/brokercheck

http://www.finra.org/brokercheck_reports


This firm is classified as a corporation.

This firm was formed in Wisconsin on 01/22/1987.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.


SEC#

19258

8-37373

Main Office Location

Mailing Address

Business Telephone Number

Doing business as HARBOUR INVESTMENTS, INC.

(608) 662-6100

Regulated by FINRA Chicago Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

SONDEL, NICK WILLIAM

CHIEF EXECUTIVE OFFICER

75% or more

No

Individual

01/1987

Yes

1261064

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BATOR, TRAVIS LEIGH

VP & CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

08/2021

No

5241485



Position

Position Start Date

DUSHEK, JAMES WALTER

VICE PRESIDENT OF OPERATIONS

Individual

01/2020

4323103








Direct Owners and Executive Officers (continued)

Firm Profile



Position Start Date


Less than 5%

No

01/2020

No

Position



Position Start Date


HAGER, AARON MICHAEL

PRESIDENT

Less than 5%

No

Individual

01/2020

No

5017811



Position



Position Start Date


MEYER, RHONDA LEE

SENIOR VICE PRESIDENT & CHIEF OPERATING OFFICER, FINOP

Less than 5%

No

Individual

01/2020

No

2285226








Direct Owners and Executive Officers (continued)

Firm Profile

Position



Position Start Date


NELLES, JULIE MARIE

VP OF ADVISORY OPERATIONS & SERVICES

Less than 5%

No

Individual

08/2021

No

4771824



Position



Position Start Date


WIPPERFURTH, DANIEL THOMAS

VICE PRESIDENT OF ADVISOR DEVELOPMENT

Less than 5%

No

Individual

01/2020

No

4029404








This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

No information reported.






Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, 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 52 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 03/23/1987

Self-Regulatory Organization Status Date Effective

FINRA Approved 04/14/1987






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 08/15/1990

Alaska Approved 01/06/2008

Arizona Approved 07/29/1992

Arkansas Approved 02/19/2004

California Approved 03/20/1989

Colorado Approved 04/12/1993

Connecticut Approved 04/30/1997

Delaware Approved 02/09/2006

District of Columbia Approved 10/13/2006

Florida Approved 08/02/1989

Georgia Approved 03/10/1997

Hawaii Approved 08/30/2007

Idaho Approved 01/30/1995

Illinois Approved 02/17/1988

Indiana Approved 04/26/1988

Iowa Approved 02/16/1988

Kansas Approved 06/11/1992

Kentucky Approved 04/17/2001

Louisiana Approved 04/24/1996

Maine Approved 03/14/2007

Maryland Approved 02/11/1998

Massachusetts Approved 01/27/1994

Michigan Approved 05/02/1988

Minnesota Approved 05/18/1988

Mississippi Approved 07/22/1997

Missouri Approved 03/09/1994

Montana Approved 12/03/1992

Nebraska Approved 04/26/2000

Nevada Approved 07/25/2000

New Hampshire Approved 06/28/1996

New Jersey Approved 11/04/1991

New Mexico Approved 03/03/1999

New York Approved 03/05/1991

U.S. States &Territories

Status Date Effective

North Carolina Approved 06/23/1992

North Dakota Approved 01/19/1995

Ohio Approved 03/26/1990

Oklahoma Approved 07/13/1998

Oregon Approved 02/10/2000

Pennsylvania Approved 03/24/1997

Rhode Island Approved 04/23/2007

South Carolina Approved 03/17/1998

South Dakota Approved 05/02/1996

Tennessee Approved 03/04/1993

Texas Approved 10/14/1994

Utah Approved 04/15/1996

Vermont Approved 06/24/1998

Virgin Islands TerminationRequested

12/31/2012

Virginia Approved 01/03/1995

Washington Approved 06/01/2000

West Virginia Approved 09/07/2012

Wisconsin Approved 04/17/1987

Wyoming Approved 09/12/2000






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

This firm currently conducts 12 types of businesses.

Types of Business

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Mutual fund retailer

U S. government securities broker

Municipal securities broker

Broker or dealer selling variable life insurance or annuities

Put and call broker or dealer or option writer

Investment advisory services

Broker or dealer selling tax shelters or limited partnerships in primary distributions

Broker or dealer selling tax shelters or limited partnerships in the secondary market

Private placements of securities

Broker or dealer selling interests in mortgages or other receivables






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

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07399

CRD #: 7560

Effective Date: 08/19/1997

Description: HARBOUR INVESTMENTS, INC. HAS A CLEARING AGREEMENT WITHPERSHING LLC. HARBOUR INVESTMENTS, INC. REFERS ANDINTRODUCES CUSTOMERS TO PERSHING.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does have accounts, funds, or securities maintained by a third party.

This firm does have customer accounts, funds, or securities maintained by a third party.

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.

Control Persons/Financing

Name: PERSHING LLC


CRD #: 7560


Description: PERSHING LLC WILL MAINTAIN ACCOUNTS AND RECORDS FOR ANYAND ALL TRADES FOR ACCOUNTS HELD.

Name: PERSHING LLC


CRD #: 7560


Description: PERSHING LLC WILL HOLD AND MAINTAIN FUNDS AND SECURITIESRELATED TO THE TRADING IN ACCOUNTS HELD ON A FULLYDISCLOSED BASIS.

Name: PERSHING LLC


CRD #: 7560


Description: CUSTOMERS WILL BE INTRODUCES TO PERSHING LLC FOR THEPURPOSE OF TRADING INDIVIDUAL ISSUES OF EQUITIES, FIXEDINCOME PRODUCTS, VARIABLE PRODUCTS, MUTUAL FUNDS AND CDS.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is not, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

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






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil 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 orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 3 0

Bond N/A 6 N/A






Disclosure Event Details

What you should know about reported disclosure events:

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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 firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

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.

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or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

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§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure 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 statesecurities 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 orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 3

Reporting Source: Regulator

Allegations: SEC ADMIN RELEASE 34-84115, IA RELEASE 40-5006 / SEPTEMBER 13, 2018:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940("ADVISERS ACT") AGAINST HARBOUR INVESTMENTS, INC. ("HARBOUR" OR "RESPONDENT").THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE FROMCERTAIN FAILURES BY REGISTERED INVESTMENT ADVISER HARBOUR.FROM AT LEAST 2012 THROUGH 2016 (THE "PERTINENT PERIOD"),HARBOUR FAILED TO FULLY AND FAIRLY DISCLOSE TO ITS ADVISORYCLIENTS COMPENSATION IT RECEIVED UNDER A MARKETING SERVICESAGREEMENT WITH A THIRD-PARTY BROKER-DEALER ("CUSTODIAN A")THAT PROVIDED CUSTODY AND CLEARING SERVICES TO HARBOUR ANDTHE CONFLICTS OF INTEREST ARISING FROM THAT COMPENSATION. THISARRANGEMENT CREATED INCENTIVES FOR HARBOUR TO FAVORCUSTODIAN A OVER OTHER CUSTODIANS WHEN GIVING INVESTMENTADVICE TO ITS ADVISORY CLIENTS ABOUT WHERE TO CUSTODY ASSETS.DURING THE SAME PERIOD, HARBOUR INVESTED SOME OF ITS ADVISORYCLIENTS IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES WHENLOWER COST SHARE CLASSES OF THE SAME FUND WERE AVAILABLE. INITS CAPACITY AS A BROKER-DEALER, HARBOUR RECEIVED 12B-1 FEESFROM SOME INVESTMENTS IN THESE SHARE CLASSES, WHICH CREATEDA CONFLICT OF INTEREST THAT HARBOUR DID NOT FULLY AND FAIRLYDISCLOSE TO ITS ADVISORY CLIENTS. INVESTING IN A MORE EXPENSIVESHARE CLASS OVER A LESS EXPENSIVE ONE IN THE SAME FUND WASALSO INCONSISTENT WITH HARBOUR'S DUTY TO SEEK BEST EXECUTIONFOR ITS ADVISORY CLIENTS.FINALLY, HARBOUR DID NOT IMPLEMENT CERTAIN OF ITS POLICIES ANDPROCEDURES DESIGNED TO MANAGE THE ABOVE CONFLICTS. BASED ONTHE CONDUCT ALLEGED, HARBOUR VIOLATED SECTIONS 206(2), 206(4)AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

Current Status: Final






Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Principal Sanction(s)/ReliefSought:

Cease and Desist

Other Sanction(s)/ReliefSought:

Date Initiated: 09/13/2018

Docket/Case Number: 3-18760

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations: SEC ADMIN RELEASE 34-84115, IA RELEASE 40-5006 / SEPTEMBER 13, 2018:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940("ADVISERS ACT") AGAINST HARBOUR INVESTMENTS, INC. ("HARBOUR" OR "RESPONDENT").THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE FROMCERTAIN FAILURES BY REGISTERED INVESTMENT ADVISER HARBOUR.FROM AT LEAST 2012 THROUGH 2016 (THE "PERTINENT PERIOD"),HARBOUR FAILED TO FULLY AND FAIRLY DISCLOSE TO ITS ADVISORYCLIENTS COMPENSATION IT RECEIVED UNDER A MARKETING SERVICESAGREEMENT WITH A THIRD-PARTY BROKER-DEALER ("CUSTODIAN A")THAT PROVIDED CUSTODY AND CLEARING SERVICES TO HARBOUR ANDTHE CONFLICTS OF INTEREST ARISING FROM THAT COMPENSATION. THISARRANGEMENT CREATED INCENTIVES FOR HARBOUR TO FAVORCUSTODIAN A OVER OTHER CUSTODIANS WHEN GIVING INVESTMENTADVICE TO ITS ADVISORY CLIENTS ABOUT WHERE TO CUSTODY ASSETS.DURING THE SAME PERIOD, HARBOUR INVESTED SOME OF ITS ADVISORYCLIENTS IN MUTUAL FUND SHARE CLASSES WITH 12B-1 FEES WHENLOWER COST SHARE CLASSES OF THE SAME FUND WERE AVAILABLE. INITS CAPACITY AS A BROKER-DEALER, HARBOUR RECEIVED 12B-1 FEESFROM SOME INVESTMENTS IN THESE SHARE CLASSES, WHICH CREATEDA CONFLICT OF INTEREST THAT HARBOUR DID NOT FULLY AND FAIRLYDISCLOSE TO ITS ADVISORY CLIENTS. INVESTING IN A MORE EXPENSIVESHARE CLASS OVER A LESS EXPENSIVE ONE IN THE SAME FUND WASALSO INCONSISTENT WITH HARBOUR'S DUTY TO SEEK BEST EXECUTIONFOR ITS ADVISORY CLIENTS.FINALLY, HARBOUR DID NOT IMPLEMENT CERTAIN OF ITS POLICIES ANDPROCEDURES DESIGNED TO MANAGE THE ABOVE CONFLICTS. BASED ONTHE CONDUCT ALLEGED, HARBOUR VIOLATED SECTIONS 206(2), 206(4)AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.







Resolution Date: 09/13/2018

Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: HARBOUR IS CENSURED AND ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTIONS 206(2), 206(4), AND 207 OF THE ADVISERS ACT AND RULE206(4)-7 THEREUNDER.HARBOUR SHALL PAY DISGORGEMENT OF $157,327, PREJUDGMENTINTEREST OF $9,152, AND A CIVIL PENALTY IN THE AMOUNT OF $75,000,FOR A TOTAL OF $241,479.HARBOUR IS ALSO ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.

Regulator Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT.HARBOUR WILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER.IT IS ORDERED THAT HARBOUR IS CENSURED AND SHALL CEASE ANDDESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2), 206(4), AND 207 OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER.HARBOUR SHALL PAY DISGORGEMENT OF $157,327, PREJUDGMENTINTEREST OF $9,152, AND A CIVIL PENALTY IN THE AMOUNT OF $75,000,FOR A TOTAL OF $241,479.HARBOUR IS ALSO ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.

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

Yes

Sanctions Ordered: CensureMonetary/Fine $75,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order

iReporting Source: Firm

Allegations: SEC ADMIN RELEASE 34-84115, IA RELEASE 40-5006 / SEPTEMBER 13, 2018:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940("ADVISERS ACT") AGAINST HARBOUR INVESTMENTS, INC. ("HARBOUR" OR "RESPONDENT"). THE COMMISSION FINDS THAT THESE PROCEEDINGSARISE FROM CERTAIN FAILURES BY REGISTERED INVESTMENT ADVISERHARBOUR. FROM AT LEAST 2012 THROUGH 2016 (THE "PERTINENTPERIOD"), HARBOUR FAILED TO FULLY AND FAIRLY DISCLOSE TO ITSADVISORY CLIENTS COMPENSATION IT RECEIVED UNDER A MARKETINGSERVICES AGREEMENT WITH A THIRD-PARTY BROKER-DEALER("CUSTODIAN A") THAT PROVIDED CUSTODY AND CLEARING SERVICES TOHARBOUR AND THE CONFLICTS OF INTEREST ARISING FROM THATCOMPENSATION. THIS ARRANGEMENT CREATED INCENTIVES FORHARBOUR TO FAVOR CUSTODIAN A OVER OTHER CUSTODIANS WHENGIVING INVESTMENT ADVICE TO ITS ADVISORY CLIENTS ABOUT WHERETO CUSTODY ASSETS. DURING THE SAME PERIOD, HARBOUR INVESTEDSOME OF ITS ADVISORY CLIENTS IN MUTUAL FUND SHARE CLASSES WITH12B-1 FEES WHEN LOWER COST SHARE CLASSES OF THE SAME FUNDWERE AVAILABLE. IN ITS CAPACITY AS A BROKER-DEALER, HARBOURRECEIVED 12B-1 FEES FROM SOME INVESTMENTS IN THESE SHARECLASSES, WHICH CREATED A CONFLICT OF INTEREST THAT HARBOUR DIDNOT FULLY AND FAIRLY DISCLOSE TO ITS ADVISORY CLIENTS. INVESTINGIN A MORE EXPENSIVE SHARE CLASS OVER A LESS EXPENSIVE ONE INTHE SAME FUND WAS ALSO INCONSISTENT WITH HARBOUR'S DUTY TOSEEK BEST EXECUTION FOR ITS ADVISORY CLIENTS. FINALLY, HARBOURDID NOT IMPLEMENT CERTAIN OF ITS POLICIES AND PROCEDURESDESIGNED TO MANAGE THE ABOVE CONFLICTS. BASED ON THE CONDUCTALLEGED, HARBOUR VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER.







Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION


Cease and Desist



Docket/Case Number: 3-18760

Principal Product Type: Mutual Fund(s)


Allegations: SEC ADMIN RELEASE 34-84115, IA RELEASE 40-5006 / SEPTEMBER 13, 2018:THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS ITAPPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AND SECTIONS203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940("ADVISERS ACT") AGAINST HARBOUR INVESTMENTS, INC. ("HARBOUR" OR "RESPONDENT"). THE COMMISSION FINDS THAT THESE PROCEEDINGSARISE FROM CERTAIN FAILURES BY REGISTERED INVESTMENT ADVISERHARBOUR. FROM AT LEAST 2012 THROUGH 2016 (THE "PERTINENTPERIOD"), HARBOUR FAILED TO FULLY AND FAIRLY DISCLOSE TO ITSADVISORY CLIENTS COMPENSATION IT RECEIVED UNDER A MARKETINGSERVICES AGREEMENT WITH A THIRD-PARTY BROKER-DEALER("CUSTODIAN A") THAT PROVIDED CUSTODY AND CLEARING SERVICES TOHARBOUR AND THE CONFLICTS OF INTEREST ARISING FROM THATCOMPENSATION. THIS ARRANGEMENT CREATED INCENTIVES FORHARBOUR TO FAVOR CUSTODIAN A OVER OTHER CUSTODIANS WHENGIVING INVESTMENT ADVICE TO ITS ADVISORY CLIENTS ABOUT WHERETO CUSTODY ASSETS. DURING THE SAME PERIOD, HARBOUR INVESTEDSOME OF ITS ADVISORY CLIENTS IN MUTUAL FUND SHARE CLASSES WITH12B-1 FEES WHEN LOWER COST SHARE CLASSES OF THE SAME FUNDWERE AVAILABLE. IN ITS CAPACITY AS A BROKER-DEALER, HARBOURRECEIVED 12B-1 FEES FROM SOME INVESTMENTS IN THESE SHARECLASSES, WHICH CREATED A CONFLICT OF INTEREST THAT HARBOUR DIDNOT FULLY AND FAIRLY DISCLOSE TO ITS ADVISORY CLIENTS. INVESTINGIN A MORE EXPENSIVE SHARE CLASS OVER A LESS EXPENSIVE ONE INTHE SAME FUND WAS ALSO INCONSISTENT WITH HARBOUR'S DUTY TOSEEK BEST EXECUTION FOR ITS ADVISORY CLIENTS. FINALLY, HARBOURDID NOT IMPLEMENT CERTAIN OF ITS POLICIES AND PROCEDURESDESIGNED TO MANAGE THE ABOVE CONFLICTS. BASED ON THE CONDUCTALLEGED, HARBOUR VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THEADVISERS ACT AND RULE 206(4)-7 THEREUNDER.

Resolution: Order 18©2022 FINRA. All rights reserved. Report about HARBOUR INVESTMENTS, INC.






Resolution:

Other Sanctions Ordered:

Sanction Details: HARBOUR IS CENSURED AND ORDERED TO CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONSOF SECTIONS 206(2), 206(4), AND 207 OF THE ADVISERS ACT AND RULE206(4)-7 THEREUNDER. HARBOUR SHALL PAY DISGORGEMENT OF$157,327, PREJUDGMENT INTEREST OF $9,152, AND A CIVIL PENALTY INTHE AMOUNT OF $75,000, FOR A TOTAL OF $241,479. HARBOUR IS ALSOORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.

Firm Statement RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER")WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. HARBOURWILLFULLY VIOLATED SECTIONS 206(2), 206(4) AND 207 OF THE ADVISERSACT AND RULE 206(4)-7 THEREUNDER. IT IS ORDERED THAT HARBOUR ISCENSURED AND SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS206(2), 206(4), AND 207 OF THE ADVISERS ACT AND RULE 206(4)-7THEREUNDER. HARBOUR SHALL PAY DISGORGEMENT OF $157,327,PREJUDGMENT INTEREST OF $9,152, AND A CIVIL PENALTY IN THEAMOUNT OF $75,000, FOR A TOTAL OF $241,479. HARBOUR IS ALSOORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS.

Sanctions Ordered: CensureMonetary/Fine $75,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order

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Initiated By: NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.



Docket/Case Number: C8A930018

Principal Product Type:


Allegations:









Resolution:


Sanction Details:

Regulator Statement COMPLAINT NO. C8A930018 (DISTRICT NO. 8) FILED MARCH 31, 1993AGAINST RESPONDENTS HARBOUR INVESTMENTS, INC., LAWRENCEAUTHURHORBINSKI, KATHERINE ANN KALMER, JOHN EDWARD KALMER, AND NICKWILLIAM SONDEL ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1,27 AND 40 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTSHORBINSKI, J. KALMER AND K. KALMER ENGAGED IN PRIVATESECURITIES TRANSACTIONS WHILE FAILING TO OBTAIN PRIOR WRITTENAPPROVAL FROM THEIR MEMBER FIRM; AND, FAILED TO RESPOND TONASDREQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION5OF THE RULES OF FAIR PRACTICE; RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENT SONDEL, FAILED TO SUPERVISE THERECORDING OFTHE SALES OF COMMON STOCK ON THE FIRM'S BOOKS AND RECORDSANDFAILED TO SUPERVISE THE PARTICIPATION OF RESPONDENTS HORBINSKI,J. KALMER AND K. KALMER PROPERLY IN THE SALE OF COMMON STOCK.

DECISION RENDERED AUGUST 24, 1995 WHEREIN RESPONDENTSHORBINSKI, J. KALMER AND K. KALMER ARE CENSURED, FINED$528,000, JOINTLY AND SEVERALLY (WHICH FINE MAY BE REDUCED BY AMAXIMUM OF $318,000 BY ANY RESTITUTION OF THE FUNDS TOCUSTOMERS) AND BARRED FROM ASSOCIATION WITH ANY NASD MEMBERINANY CAPACITY. IF NO FURTHER ACTION, DECISION IS FINAL OCTOBER9, 1995.

ON AUGUST 24, 1995, THE DECISION AND ORDER OF ACCEPTANCE OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS MEMBER ANDSONDELWAS ISSUED; THEREFORE, THEY EACH ARE CENSURED AND FINED $5,000.

OCTOBER 9, 1995 - DECISION IS FINAL.

**$5,000.00 FULLY PAID AS OF 10/3/95, INVOICE # 95-8A-551**

Sanctions Ordered: CensureMonetary/Fine $5,000.00

Consent






COMPLAINT NO. C8A930018 (DISTRICT NO. 8) FILED MARCH 31, 1993AGAINST RESPONDENTS HARBOUR INVESTMENTS, INC., LAWRENCEAUTHURHORBINSKI, KATHERINE ANN KALMER, JOHN EDWARD KALMER, AND NICKWILLIAM SONDEL ALLEGING VIOLATIONS OF ARTICLE III, SECTIONS 1,27 AND 40 OF THE RULES OF FAIR PRACTICE IN THAT RESPONDENTSHORBINSKI, J. KALMER AND K. KALMER ENGAGED IN PRIVATESECURITIES TRANSACTIONS WHILE FAILING TO OBTAIN PRIOR WRITTENAPPROVAL FROM THEIR MEMBER FIRM; AND, FAILED TO RESPOND TONASDREQUESTS FOR INFORMATION MADE PURSUANT TO ARTICLE IV, SECTION5OF THE RULES OF FAIR PRACTICE; RESPONDENT MEMBER, ACTINGTHROUGH RESPONDENT SONDEL, FAILED TO SUPERVISE THERECORDING OFTHE SALES OF COMMON STOCK ON THE FIRM'S BOOKS AND RECORDSANDFAILED TO SUPERVISE THE PARTICIPATION OF RESPONDENTS HORBINSKI,J. KALMER AND K. KALMER PROPERLY IN THE SALE OF COMMON STOCK.

DECISION RENDERED AUGUST 24, 1995 WHEREIN RESPONDENTSHORBINSKI, J. KALMER AND K. KALMER ARE CENSURED, FINED$528,000, JOINTLY AND SEVERALLY (WHICH FINE MAY BE REDUCED BY AMAXIMUM OF $318,000 BY ANY RESTITUTION OF THE FUNDS TOCUSTOMERS) AND BARRED FROM ASSOCIATION WITH ANY NASD MEMBERINANY CAPACITY. IF NO FURTHER ACTION, DECISION IS FINAL OCTOBER9, 1995.

ON AUGUST 24, 1995, THE DECISION AND ORDER OF ACCEPTANCE OFOFFER OF SETTLEMENT SUBMITTED BY RESPONDENTS MEMBER ANDSONDELWAS ISSUED; THEREFORE, THEY EACH ARE CENSURED AND FINED $5,000.

OCTOBER 9, 1995 - DECISION IS FINAL.

**$5,000.00 FULLY PAID AS OF 10/3/95, INVOICE # 95-8A-551**


Initiated By: NASD


Civil and Administrative Penalt(ies) /Fine(s)



Docket/Case Number: C8A930018

Principal Product Type: Other

Other Product Type(s): PRIVATE STOCK

Allegations: THREE REPRESENTATIVES SOLD STOCK FOR A FAMILY BUSINESS NOT INASSOCIATION WITH HARBOUR INVESTMENTS, INC. NASD RAISED ISSUESCONCERNING SUPERVISION, RECORDING AND WHETHER THE STOCKWAS SOLD FOR A SELLING COMMISSION.



Resolution:


Sanction Details: $5000.00 WAS PAID TO THE NASD BY HARBOUR INVESTMENTS, INC.

Firm Statement WITHOUT ADMITTING OR DENYING CHARGES HARBOUR INVESTMENTS,INC. AGREED TO PAY THE NASD A $5,000.00 SETTLEMENT.

Sanctions Ordered: CensureMonetary/Fine $5,000.00

Settled

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Allegations: ILLINOIS HAS ISSUED A NOTICE OF HEARING TO DETERMINE WHETHER ANORDER OF REVOCATION, SUSPENSION OR CENSURE SHOULD BEIMPOSED AGAINST RESPONDENT HARBOUR INVESTMENTS, INC.ALLEGATIONS ARE THAT RESPONDENT FAILED TO TIMELY FILE REQUIREDFINANCIAL DOCUMENTS WITH THESECRETARY OF STATE. HEARING DATE IS SET FOR JUNE 7, 1989.DOCKET/CASE #H8900191. DATED MARCH 29, 1989







Initiated By: ILLINOIS




Docket/Case Number: H8900191

URL for Regulatory Action:

Principal Product Type: Other


Allegations: ILLINOIS HAS ISSUED A NOTICE OF HEARING TO DETERMINE WHETHER ANORDER OF REVOCATION, SUSPENSION OR CENSURE SHOULD BEIMPOSED AGAINST RESPONDENT HARBOUR INVESTMENTS, INC.ALLEGATIONS ARE THAT RESPONDENT FAILED TO TIMELY FILE REQUIREDFINANCIAL DOCUMENTS WITH THESECRETARY OF STATE. HEARING DATE IS SET FOR JUNE 7, 1989.DOCKET/CASE #H8900191. DATED MARCH 29, 1989


Resolution:


Sanction Details: BY MEANS OF STIPULATION, ILLINOIS HAS ENTERED A CONSENT ORDERAGAINST RESPONDENT. FINDINGS OF FACT AND CONCLUSIONS OF LAWARE THAT RESPONDENT FAILED TO TIMELY FILE A REQUIRED FINANCIALDOCUMENT WITH THE SECRETARY OF STATE THEREBY VIOLATINGSECTION 12.D OF THE ILLINOIS SECURITIES LAW OF 1953, AS AMENDED.AN ADMINISTRATIVE FINE OF $500.00 HAS BEEN ASSESSED.DOCKET/CASE NO. H8900191 DATED MAY 11, 1989.

Sanctions Ordered: Monetary/Fine $500.00

Consent


Initiated By: SECRETARY OF STATE OF ILLINIOS


Allegations: HARBOUR INVESTMENTS, INC. WAS CHARGE WITH A LATE FILING FEE FORLATE SUBMITTAL OF ITS 1989 AUDITED FINANCIAL STATEMENTS TO THESTATE OF ILLINOIS.








Civil and Administrative Penalt(ies) /Fine(s)


Docket/Case Number: H8900191

Principal Product Type: No Product



Resolution:


Sanction Details: HARBOUR INVESTMENTS, INC. PAID $500.00 TO THE SECRETARY OF THESTATE OF ILLINIOS ON 5/8/1989.

Firm Statement HARBOUR INVESTMENTS, INC. PAID A $500.00 FINE TO THE SECRETARY OFSTATE OF ILLINIOS.

Sanctions Ordered: Monetary/Fine $500.00

Settled






Civil Bond

This type of disclosure event involves a civil bond for the brokerage firm that has been denied, paid, or revoked by abonding company.

Disclosure 1 of 6

Reporting Source: Firm

Policy Holder: HARBOUR INVESTMENTS, INC.

Bonding Company Name: OHIO CASUALTY

Disposition: Payout

Disposition Date: 02/25/2019

Payout Details: $100,000.00 PAYOUT RECEIVED ON 2/25/2019.

Firm Statement PREVIOUS CLIENT ALLEGED DIVERSION OF MONEY FROM HER TOFORMER HARBOUR REGISTERED REPRESENTATIVE MARK HOLT'SCOMPANY WHICH HAS NO AFFILIATION WITH HARBOUR INVESTMENTS.THE MONEY WAS ALLEGEDLY USED BY HOLT FOR HIS OWN PERSONALPURPOSES. HOLT WAS TERMINATED BY HARBOUR ON 11/8/2013.

Disclosure 2 of 6

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Disposition: Payout


Payout Details: $550,000 ON 07/06/2017

Firm Statement CLAIMANT ALLEGED MISAPPROPRIATION OF CHECKS MADE PAYABLE TOMARK HOLT'S COMPANY NAME, THE HARBOR GROUP, WHICH DOES NOTHAVE ANY AFFILIATION WITH HARBOUR INVESTMENTS. MARK HOLT WASTERMINATED FROM HARBOUR INVESTMENTS ON 11/8/2013.

Disclosure 3 of 6

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Policy Holder: HARBOUR INVESTMENTS, IMC.


Disposition: Payout







Payout Details: $325,000 ON 12/30/2016

Firm Statement CLAIMANT ALLEGED MISAPPROPRIATION OF CHECKS MADE PAYABLE TOMARK HOLT'S COMPANY NAME, THE HARBOR GROUP, WHICH DOES NOTHAVE ANY AFFILIATION WITH HARBOUR INVESTMENTS. MARK HOLT WASTERMINATED FROM HARBOUR INVESTMENTS ON 11/8/2013.

Disclosure 4 of 6

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Disposition: Payout


Payout Details: $175,000.00 ON 4/1/2016

Firm Statement CLAIMANTS ALLEGE MISAPPROPRIATION OF CHECKS MADE PAYABLE TOMARK HOLT'S COMPANY NAME, THE HARBOR GROUP, WHICH DOES NOTHAVE ANY AFFILIATION WITH HARBOUR INVESTMENTS. MARK HOLT WASTERMINATED FROM HARBOUR INVESTMENTS ON 11/8/2013.

Disclosure 5 of 6

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Disposition: Payout


Payout Details: $342470.76 ON 9/9/2015$61292.00 ON 9/16/2015

Firm Statement CLAIMANTS ALLEGE MISAPPROPRIATION OF CHECKS MADE PAYABLE TOMARK HOLT'S COMPANY NAME, THE HARBOR GROUP, WHICH DOES NOTHAVE ANY AFFILIATION WITH HARBOUR INVESTMENTS. MARK HOLT WASTERMINATED FROM HARBOUR INVESTMENTS ON 11/8/2013.

Disclosure 6 of 6

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Bonding Company Name: TRAVELERS INSURANCE COMPANY

Disposition: Payout


Payout Details: BOND PAID HARBOUR $90,000.00 ON 12/14/2010.

Firm Statement CLIENTS, INCLUDING NON-HARBOUR CLIENTS, ALLEGEMISAPPROPRIATION OF CHECKS MADE PAYABLE TO SEMLING'S COMPANYNAME, ADVANTAGE FINANCIAL CENTERS. CLIENTS ALLEGE THEY WERE TOPURCHASE FIXED ANNUITIES OUTSIDE THE SCOPE OF HARBOUR BROKERDEALER ACTIVITIES. SEMLING WAS TERMINATED FROM HARBOUR ON10/12/2005.






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