SEC Fines North East Asset Management $251,640.83 for Cherry-Picking

UNITED STATES OF AMER ICA Before the SECURITIES AND EXCHAN GE COMMI SSION SECURITIES E XCHANG E ACT OF 1 934 Release No. 1049 13 / March 2, 2026 ADM INI ST RAT IVE PRO CEE DI NG File No. 3 -2 2481 In the Matter of No rth Ea st Asset Manage ment Grou p, Inc. and Gr egory A. Z and lo, Res pon dent s.::::::: ORDER APPOINTIN G FUND ADMINISTRATOR, SETTING ADMINISTRATO R’S BOND AMOUNT, AND AUTHORIZ ING THE APP ROVAL AND PAYMENT O F THE FE ES AND EXPENSE S OF ADMINIST RATION On June 3, 2025, the Commission issued an Order Instituting Administrative and Cease- and -Desist Proceedings, P ursuant to Section 21(c) of the Securities Exchange Act of 1934, and Sections 203(e), 203(f), and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease- and - Desist O rder (the “ Order”) 1 against North East Asset Management Group, Inc. (“North E ast”) and Gregory A. Zandl o (“Zandlo”) (collectively, the “Respondents”). In the Order, the Commission found that between Dec ember 1, 2020, through May 31, 2022 (the “Relevant Period”), Nor th East, a State of Minnesota- registered investment adviser, and Zandlo, North East’s sole principal, owner, and employee, engaged i n cherry -picking when they disproportionally allocated certain profitable trades to accounts for North East, Zandlo, and individuals related to Zandlo, and allocated unpr ofitable tr ades to other North East advisory clients. 1 Advisors Act R el. No. 6881 (June 3, 2 025).

2 The Commission ordered North East to pay $10,609.00 in disgorgement and $2,260.36 in prejudgment interest, and ordered Zandlo to pay $80,599.00 in disgorgement, $17,172.47 in prejudgment interest, and a $141,000.00 civil money penalty, for a collective total of $251,640.83, to the Commission. The Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalty collected, along with the disgorgement and prejudgment interest collected, can be distributed to harmed investors (the “Fair Fund”). The Fair Fund consists of the $251,640.83 collected from the Respondents. The Fai r Fund has been deposited in a Commission- desi gnated acco unt at the U.S. D epartment of the Treasury, and any accrued interest will be added to the Fair Fu nd. The Division of Enforcement (the “Division”) now seeks the appointment of KCC Class Action Services LLC (“ KCC”) as the fund administrator and requests that the administrator’s bond be set at $251,640.83. KCC is included in the Commission’s approved pool of administra tors. The Division further requests that the Commissio n autho rize the Office of Fina ncial Management (“OFM”), at the direction of an Assistant Director of the Office of Distributions, to pay the Fund Administrator’s fees and expenses from the Fair Fund, so long as the total amount paid to the Fund Administrator, including the invoice to be paid, does not exceed the total amount of the approved cost proposal submitted by the Fund Administrator. Accordingly, IT IS HEREBY ORDERED that: A. KCC is appointed as the Fund Administrator, pursuant to Rule 1105(a) of the Commission’s Rules on Fair Fund and Disgorgement Plans (“Commission’s Rules ”); 2 2 17 C.F.R. § 201. 1105(a).

3 B. KCC shall obtain a bond in accordance with Rule 1105(c) of the Commission’s Rules, 3 in the amount of $251,640.83; C. the Fund Administrato r will submit invoic es to the Commission staff for ser vices rendered, in accordance with Rule 1105(d) of the Commission’s Rules; 4 and D. at the dir ection of an Assistant Direc tor of the Office of Distr ibutions, OF M is authorized to pay the Fund Administrator’s fees and expenses from the Fair Fund, in accordance with Rule 1105(e) of the Commission’s Rules, 5 so long as the total amount paid to the Fund Administrator, including the invoice to be paid, does not exceed the total amount of the approved cost proposal submitted by the Fund Administrato r. For the Commission, by the Division of Enforcement, pursuant to delegated authority. 6 Vanessa A. Countryman Secreta ry 3 17 C.F.R. § 201. 1105(c). 4 17 C.F.R. § 201.1 105(d). 5 17 C.F.R. § 201. 1105(e). 6 17 C.F.R. § 200. 30 - 4(a) (17) and 17 C.F.R. § 200.30 - 4(a)(21)(vi).