NH Consent Order: Redwood Private Wealth, LLC and Thomas Space - Unsuitable Options Trades

DocusI9n Envelope ID: 94C1 F6D9-598F-497E-B401-0E77C7F93FFD STATE OF NEW HAMPSHIRE DEPARTMENT OF STATE BUREAU OF SECURITIES REGULATION 25 CAPITOL STREET CONCORD, NH 0330 I IN THE MATTER OF: Redwood Private Wealth, LLC, and Thomas Space Respondents COM-2024-0008 CONSENT ORDER 1. For purposes of settling the above-referenced matter and in lieu of further administrative proceedings, Redwood Private Wealth, LLC (RPW), LLC (CRD #312942) and Thomas Space ("Space") (CRD #2382115) (Space will be collectively referred to as "Respondents") have submitted an offerofsettlement, which the Bureau ofSecurities Regulation, Department ofState, State of New Hampshire (the "Bureau") has detem1ined to accept. Accordingly, without admitting or denying the allegations or findings contained herein, Respondents do hereby consent to the entry ofthis Consent Order and the following undertakings and sanctions: STATEMENT OF FACTS I. Redwood Private Wealth, LLC ("RPW"), was an SEC licensed investment advisor until March 31, 2025. with a principal place ofbusiness in Phoenix, Arizona. 2. Space is a licensed investment adviser representative in Gilford, New Hampshire. 3. Space was employed by RPW in July 2021 until March of2025. He is currently registered with Brookwood Investment Group (CRD 316544) as an investment advisor representative ... 4. DT, a former public school teacher, lived in Dover, New Hampshire, and Somersworth, New Hampshire until on or around March of2023 when she moved to South Carolina, where she currently resides. She was a client ofSpace from July 2019 until approximately October 2024.

Docusign Envelope ID: 94C1F6D9-598F-497E-8401-0E77C7F93FFD Space and RPW received compensation for providing investment advice to DT. 5. DT describes herself as a conservative investor and filled out forms with Space that described her as a conservative investor. 6. While Space was employed by RPW and under their supervision, he engaged in unsuitable options trades in DT's accounts, such as naked puts, which resulted in account losses of $81,426. 7. During the course of this matter, RPW implemented enhanced internal supervisory procedures for Space as part ofits ongoing compliance obligations. STATEMENTS OF LAW I. RPW and Space are "persons" as defined in RSA 421-B: 1-102(39). 2. RPW and Space provided investment advice for compensation to DT pursuant to RSA 421- B:5-502(a). 3. Pursuant to N.H. RSA 421-8:6-602, the Bureau has the power to investigate ifthere has been a violation ofN.H. RSA 421-B or to aid in the enforcement ofthe chapter. 4. Pursuant to RSA 42 l-B:5-502(b )(2), investment advisers owe a duty of care and must ensure their recommendations are consistent with a client's stated investment profile. The Bureau alleges that the investments recommended to DT did not align with her stated risk tolerance, and therefore asserts a violation of this provision. 5. Pursuant to RSA421-B:6-604(e), the Secretary of State can order Respondents to pay restitution for losses. associated with their conduct to the affected investor. Respondents are jointly and severally subject to this provision. 6. Pursuant to RSA I-B:6-604(d), the secretary ofstate may impose a civil penalty of$2,500 for each violation of RSA 421-B. Respondents are jointly and severally subject to this prov1s1on. 7. Pursuant to RSA 421-B:6-604(g), in any investigation to determine whether any person has violated any rule or order under this title, the Secretary ofState shall be entitled to recover the costs ofthe investigation. Respondents are jointly and severally subject to this provision. 8. Pursuant to RSA 42 l-B:6-604(a)(l whenever it appears to the secretary of state that any person has engaged or is about to engage in any act or practice constituting a violation ofthis chapter or order issued under this chapter, he shall have the power to issue and cause to be served upon such person an order requiring the person to cease and desist from violations of this chapter. BIG and Space are jointly and severally subject to this provision and should be ordered to pem1anently cease and desist from violating RSA 421-B. In view ofthe foregoing, the Respondents agree to the following undertakings and sanctions:

Docusign Envelope ID: 94C1F6D9-598F-497E-8401-0E77C7F93FFD 9. Respondents agree that Respondents have voluntarily consented to the entry of this Consent Order and represent and aver that no employee or representative of the Bureau has made any promise, representation or threat to induce Respondents' execution. Respondents agree to waive Respondents' rights to an administrative hearing and any appeal therein under this chapter. I0. Respondents consent to judgment ofrestitution in the amount of$81,426. Respondents shall make a check payable in this amount to DT and mail it to her at her current address. 11. Respondents shall be ordered and agree to pay an administrative fine of$25,000 and costs of the Bureau's investigation in the amount of$25,000 for a total of$50,000. Payment must be made to the State of New Hampshire, which will be applied to settlement of this matter. Payment must be made by I) certified check, or postal money order; 2) made payable to the State ofNew Hampshire; and 3) mailed to the Bureau ofSecurities Regulation, Department of State, State House, Room 204, Concord, New Hampshire, 03301. 12. Respondents agree that this Order is entered into for purpose ofresolving only the matter as described herein. This Order shall have no collateral estoppel, res judicata or evidentiary effect in any other lawsuit, proceeding, or action, not described herein. Likewise, this Order shall not be construed to restrict the Bureau's right to initiate an administrative investigation or proceeding relative to conduct by Respondents which the Bureau has no knowledge at the time of the date offinal entry ofthis Order 13. The Respondents may not take any action or make or permit to be made any public statement, including in regulatory filings or otherwise, denying, directly or indirectly, any allegation in this Consent Oder or create the impression that the Consent Order is without factual basis. Nothing in this provision affects the Respondent's testimonial obligations or right to take legal positions in litigation in which the State ofNew Hampshire is not a party. 14. Should Respondents fail to comply with this Consent Order, the Bureau may rescind the Consent Order without a hearing and institute formal enforcement proceedings under RSA 421-B. Based on the foregoing, the Bureau deems it appropriate and in the public interest to accept and enter into this order. THEREFORE, IT IS HEREBY ORDERED THAT: 15. Respondents cease and desist from further violations of the New Hampshire Securities Act pursuant to RSA 421-B. 16. Respondents pay restitution in the amount of$81,426. 17. Respondents pay administrative penalties in the amount of$25,000.

Docusign Envelope ID: 94C1F6D9-598F-497E-8401-0E77C7F93FFD 18. Respondents pay costs of the Bureau's investigation in the amount of $25,000. 19. Respondents comply with the above-referenced undertakings and sanctions. JanuaryExecuted this day o f _, 2026. Redwood Private Wealth, LLC Please print name below: Kimberley A. Raimondo, Esq. Thomas Space Please print name below: . 14 January Entered this day of _, 2026. ~ F--o·Enc orc1er, irector NH Bureau ofSecurities Regulation