Keitz Investment Management Ltd. Consent Order - $12,000 Administrative Assessment

IC OMMONWEALTH OF PENNSYLVANIA

DEPARTMENT OF BANKING AND SECURITIES COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING AND BUREAU OF SECURITIESSECURITIES, (sEC-CAo)EXAMINATIONSAND COMPLIANCE No. Docket : 26 0003

1. KETTZ INVESTMENT MANAGEMENI LTD. : CONSENT AGREEMENT A}[D ORDER

of Banking andThe Commonwealth of Pennsylvania, acting through the Department of ("Department'), ("Bureau"), Securities Compliance and Examinations Bureau Securities has of Keitz Investment of the conducted an investigation practices Management, Ltd.business ("KIM") of its investigation, the Bureau hasand its officers employees. results and Based on the of 1972,70 P.S.KIM Act violation of in that concluded Pennsylvania Securities has the operated Act"). KIM, in lieu of or denying thelitigation, and without admiuing (*1972 $ et seq. 1-101

legally this of herein, and intending to be bound, hereby agrees to the terms allegations Consent ("Order').Agreement and Order BACKGROT]I[D1. The Department Commonwealth of is the Pennsylvania's administrative agency enforce the 1972 Act.authorized and empowered to administer and 2. The primarily Act for administering and enforcing the 1972 is responsible Bureau for the Department.

FILED 2026 JAN 29 AM 9:03 PA DEPARTMENT OF BANKING AND SECURITIES

1. # ('oKlM"), Ltd. was, at all materialKeitz CRD Investnaent Management, 123770, at with a Pennsylvania corporation an ,times herein, address Redacted4. From on or KIM was until the 10, about February present, 1995, registered Act,70 P.S. of the 1972 to Section 301(c) pursuant 1-301(c), as investment $ an adviser.5. provides "[a]n that investment adviser Regulation 303.012(0 theregistered under in its FormAct] shall material information contained necessary to ensure that take steps U972

and accurate. If ADV made in Form ADV material statement and exhibits remains current and a

file with the Department anor inaccurate becomes incorrect the investment adviser shall exhibits of of ADV within 30 days which requires the the occrrrence amendment on Form event the filing of the amendment." 10 Pa. Code$ 303.012(0.6. untit January 2024, KIM did not take stepsFrom on or about January 2020 ADV and exhibits in its information contained Form necessary to ensure that material remains current and accurate. YIOLATION above, KIM 6 engaging in 3 through the acts and conduct set forth in 7.By paragraphs in its Form ADV andsteps necessary to enflre that material information contained failed to take

Act and accurate to achieve compliance with the and remains current exhibits 1972 other

basis to deny, suspend, revoke, orform which acts and conduct laws and regulations, securities a the registration of KIM or to censure KIM of to Section 305(a)(v) the condition pursuant 1972 Act,70 303.012(i), 10 $ promulgatedCode 303.012(i), 1-305(a)(v), and Regulation $ Pa. P.S. thereunder.

RELIEF'8. KIM shall amount of in the pay the Deparffnent an administrative assessment by or to certified money $12,000.00. order made Payment shall be made check payable the "Department to the of Banking shall be mailed or delivered in and Securities" and person Bureau N. Second of Securities at 17 Street, Suite 1300,Compliance and Examinations located Harrisburg, Pennsylvania fiLAI. as follows: paid The shall assessment be a. on or before May 1, 2026;$1000.00 b. 1,2026;on or before August $1000.00 c- before November 1,2A26;on or $1000.00 d. on or before February 1,2027;$1000.00 e. on orbefore May 1, 2A27;$1000.00 f. or before August 1,2027;on $1000.00 g. or before November l, 2027 on $1000.00 ;h. 1,2A28;February on or before $1000.00 i. May l, 2A28;on before or $1000.00 j. on or before August 1,2A28;$1000.00 k. on or before November 1,2A28; and$1000.00 1. or before February t,2029.on $1000.00 ORDERED to comply with adopted by theis 9.KIM 1972 Act, and Regulations the Section 305(aXv) of the 1972 Act,70 in particular $ Department, and l-305(a)(v).Should P.S.

in KIM 8 above, fail to the sanctions set forthset forth pay the assessment as paragraph

force and effect until full continue in fulI is made.in the Order shall payment elsewhere

as affording KIM the option of provision paying shall not be construed However, this either the indefinitely subject to the sanctions.assessment or being 10. Should of this Order, the and/or all KIM fail to comply with any provisions

relief additional sanctions may impose and other appropriate subjectand costs Department seek KIM's right to a L972 Act.to the to pursuant hearing F'URTHER PROYISIONS11. Consent. KIM hereby willingly, voluntarily knowingly, and irrevocably consents

1972 Act and agrees that itto authority entry of this Order to the under the pursuant the Bureau's

KIM, by voluntarily contained herein. all of the entering intoterms and conditions understands right to a hearing or appeal conceming this Ordeq the terms, conditions, waives any alrrd/or

set forth in this Order.penalties 12. Entire This contains the Agreement. entire agreement between Order theand KIM. There are oo other terrrs, obligations, covenants, Department representations,

Order. or otherwise, of any kind this This Orderconditions, whatsoever concerning statements,

and KIM.in writing agreement by by mutual the Department may be amended 13. KlM, and all officers, Binding Nature. The Department, owners, directors, the terms of KIM intend and are legally bound by heirs and assigns of to be thisemployees, Order.

|4.Counsel.Thisorderisenteredintobythepartiesuponfullopportunityforlegal

counsel'from legal advice 15. order shall the become that KIM and agrees hereby stipulates Effectiveness. Date")' ("Effective order the Bureau executes the the on effective date

1. Action' Enforcement Other (a) The to all enforce all its of authority and rights, duties, reserves Departrnent in KIM the all future regarding jurisdiction its against under rules, regulations and statutes, this by Order'resolved not matters (b) is this only upon binding KIM that Order and the agrees acknowledges or office or federal regarding local, not any departrnent, other agency, state and Departrnent within this Order.matters 17. &is Order legally to and execute below Authorization. authorized parties The are parties.their bind respective 18. by in facsimile This counterparts, Order may executed be separate Count€rparr[S. by and/or PDF.19. of this for the identiff the to Titles. are document The titles paragraphs used of this document. the interpretation control only and do not of reference convenience 20. in that it is necessary Finding. public the appropriate and finds The Department fairly intended by with the of investors, for protection purposes and consistent and the interest policy provisions to issue this Order.of the 1972 Act and the

LWIIEREFORE, in consideration of the foregoing, including the recital paragraphs, the of Securities of Department of Banking and Commonwealth Securities, Bureau Pennsylvania, to be legally Keitz Investment Management, Ltd., intending Compliance and Examinations and

bound, do hereby execute this Consent Agreement and Order.

FOR THE COMMONWEALTH PENNSYLVANIA OF OF BANKING AND SECURITIESDEPARTMENT AND EXAMINATIONSBUREAU OF SECURITIES COMPLIANCE

for SecuritiesEric Pistilli, Deputy Secretary Date:

rOR KEITZ INVESTMENT MANAGEMENT LTD.

'Zb Officerand Chief Michael Owner Compliance -Jqr*u '2 b L=fr'&) Date:

RedactedRedacted

01/27/2026