In connection with his investments in certain funds, the customer alleges that his registered representative, not Ms. Monchik, made certain misrepresentations that the funds purchased shared of identified private issuers from the secondary market despite the customer receiving offering documents explicitly disclosing that the funds would purchase such shares from secondary sources or invest in interests of investment funds, special purpose vehicles or other entities that held such shares or investment rights. There is no allegation that the ever customer spoke with Ms. Monchik in connection with investing in any fund. The customer asserts direct claims against the funds or other legal claims against "Respondents"; however, the only cause of action that directly identifies Ms. Monchik is the respondeat superior cause of action based on her position at the managing member of the funds. The matter will be defended vigorously and Ms. Monchik fully expects to prevail at a hearing on the merits.

Claimant alleges that Ms. Monchik is liable solely in her executive capacity at. Claimant does not make any allegations that Ms. Monchik had any contact with Claimant or any role in the underlying transactions. Ms. Monchik was not the relevant registered representative's supervisor nor does she have any role in the supervision of registered representatives. The Claims against Ms. Monchik are wholly without merit. Ms. Monchik will defend this matter vigorously and expects that he will prevail at a hearing on the merits.

None of the subject 8210 requests were ever directed to Ms. Monchik. She was not the subject of any of the requests, nor did she have any regulatory responsibility for responding to the referenced requests. Ms. Monchik intends to defend the matter vigorously and expects to prevail at a hearing on the merits.

Claimant alleges that Ms. Monchik is liable solely in her executive capacity. Claimant does not make any allegations that Ms. Monchik had any contact with Claimant or any role in the underlying transactions. Ms. Monchik was not the relevant registered representative's supervisor nor does she have any role in the supervision of registered representatives. The Claims against Ms. Monchik are wholly without merit. Ms. Monchik will defend this matter vigorously and expects that he will prevail at a hearing on the merits.

Ms. Monchik was named solely in her capacity as chief administrative officer of the firm. Ms. Monchik was not the designated supervisor for the registered representative(s) who serviced the account(s). Ms. Monchik does not have any supervisory responsibility for customer accounts. The allegations are wholly without merit. Ms. Monchik intends to defend the matter vigorously and expect to prevail on a hearing on the merits.

?On March 28, 2023, a decision was rendered by FINRA (the "Decision") finding that Ms. Kim Monchik (CAO) failed to properly update her FINRA Form U4 to include certain arbitrations or lawsuits that she was named in, solely due to her role at the company. Moreover, there were no sales practice violations found against Ms. Monchik. ?On April 19, 2023, Ms. Monchik filed an Appeal of the Decision to the National Adjudicatory Counsel (NAC). Ms. Monchik believes that the Decision makes multiple errors of fact and law; improperly applies the wrong disclosure standard for arbitrations which named Ms. Monchik; and improperly applied an erroneous standard for imposing sanctions. In particular, the findings are belied by, among other things, the fact that Ms. Monchik 'conduct in deciding disclosure issues was supported by and opinions of legal counsel, an interpretation of FINRA Rules and Guidance, a Good Faith determination of reporting requirements for the legal proceedings, as well as review by multiple compliance officers. ?As will be presented on appeal, with regard to Ms. Monchik, the legal proceedings that were not reported on the Form U4 involved cases in which Ms. Monchik was not involved in the underlying securities transactions or accounts, for which she was not the supervising individual on the accounts, and where the respective statements of claim failed to make specific allegations against Ms. Monchik. ?Ms. Monchik did not report certain legal proceedings on her U-4 because the arbitrations were filed against Ms. Monchik were solely because she held an executive position at the firm. Under FINRA's rules, these arbitrations are not reportable by Respondents. This opinion was confirmed by several attorneys and several compliance personnel. ?The commentary provides that "[firms and registered persons should review each claim on a case-by-case basis and make a good faith determination as to whether reporting is required." Good Faith was exercised in decisions not to report these legal proceedings. ?Ms. Monchik' determination on reporting was further supported by the testimony of the Director in the Regulatory Review and Disclosure Unit of FINRA in which it was acknowledged that "General" or "Broad" Allegations against an officer need not be reported - and that only "specific" allegations need to be reported. Testimony from FINRA further clarified that if a failure to supervise claim is made against an officer merely because of their position as an officer they should use their good faith to determine if it is reportable - and that such broad allegations would not be reportable. ?Based upon the above, and other arguments to be presented on appeal, Ms. Monchik believes that the Decision will be reversed or modified in her favor. On November 4, 2024, Ms. Monchik filed an Appeal of the Decision to the Securities Exchange Commission (SEC)

Ms. Monchik was not the broker on the account nor did she ever have direct contact with the client or have supervisory responsibility in any capacity. She was named in the arbitration solely due to her role at Spartan.