CREO Global Capital LLC and Peter Savarino - Consent Order

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& Consent Order Creo. Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of b. A Notice and Order to. Cease and Desist to Peter Savarino. 2. are not presently in any capacity under the Act. Peter Savarino is a resident of the state of Michigan who was as an adviser representative in Michigan through Creo Global Capital, LLC ("Creo"), a. Michigan-registered adviser, until on or around January 1, 2021, when Creo and Peter Savarino failed to renew their registrations as adviser and adviser representative, respectively. 3. Following issuance of the Orders, the Bureau and (collectively, "the Parties") engaged in settlement negotiations through this and Consent Order ("Consent Order"). 4. consulted with or had an opportunity to consult with legal counsel of their choosing before executing the following Stipulation. B. STIPULATION The. Parties agree to resolve the Orders based on the following terms: 1. neither admit nor deny any wrongdoing in with these matters and consent to the entry of this Consent Order only for the purpose of resolving the Orders in an expeditious fashion that avoids the time and expense associated with an and any appeals.

& Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of 2. agree to comply with the Act in with all future conduct and activities, including but not limited to ensuring that they are or exempt from when providing advice for compensation. 3. agree to pay a civil fine in the amount of one thousand Dollars ($1,000.00) within calendar days after the issued and entered date of this Consent Order. It must be paid by check or money order made payable to the "State of Michigan," contain information (name and "Complaint Nos. 344387 & 344388"), and be mailed to: & Licensing Bureau & Audit Division — Final Order Monitoring P.O. Box 30018 Lansing, MI 48909 4. If any portion of the fine is overdue, the may refer it to the Michigan Department of Treasury for collection action against or take other available legal action to collect the fine. 5. retained an acceptable to the Bureau to conduct a review of the adequacy of Creo's policies, systems, and procedures (written and otherwise) and to make to Creo and Peter Savarino to enhance their abilities to remain in with the regulatory requirements of the Act, associated rules, and orders issued under the Act, 6. are responsible for enforcing the terms of their engagement with the Consultant.

& Consent. Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of 7. are responsible for all costs and expenses incurred in complying with the terms of this Consent Order and must do so within the timeframes specified. The retains the right to pursue any action or permitted by law to enforce its provisions. 8. will cooperate with the Compliance. in all respects, including by providing staff support if necessary. will place no restrictions on the Consultant's communications with any Bureau staff and, upon request, will make available to Bureau staff all communications between and among the and and all documents reviewed by the in with his or her engagement. Once retained, may not terminate the relationship with the without the Bureau's written approval. are not in and do not have an attorney-client relationship with the and agree that they may not invoke the attorney-client privilege or other doctrine or privilege to prevent the from transmitting any information, reports, or documents to the Bureau. 9. At the conclusion of the review, and no more than days after the issued and entered date of this Consent Order, will direct the to submit to the Bureau, at the address identified in Paragraph B.3 above, or to LARA-CSCL-Securities-Auditmichigan.gov to the & Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of 1. are responsible for all costs and expenses incurred in complying with the terms of this Consent Order and must do so Within the timeframes specified. The retains the right to pursue any action or permitted by law to enforce its provisions. 8. will cooperate with the Compliance. in all _respects, including by providing staff support if necessary: will place no restrictions on the Consultant's communications with any Bureau staff and, upon request, will make available to Bureau staff all communications between and among the and and all documents reviewed by the in with his or her engageMent. Once retained, may not terminate the relationship with the without the Bureau's written approvaL are not in and do not have an attorney-client relationship with the and agree that they may not invoke the attorney-client privilege or other doctrine or privilege to prevent the from transmitting any information, reports, or documents to the Bureau. 9. At the conclusion of the review, and no more than days after the issued and entered date of this Consent Order, will direct the to submit to the Bureau, at: the address identified in Paragraph B.3 above, or to LARA-CSCL-Securities-Audit@raichigan.eov to the

& Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of 11 attention of Final Order Monitoring, a written Report, and a Proposed Client, Notification letter. 10. The Report required by paragraph B.9 must address, at a minimum: a. The adequacy of policies, procedures, systems, and training regarding with its regulatory obligations under the Act and its rules and orders; b. a description of the review performed, and the conclusions reached; c. the Consultant's for modifications and additions to policies, systems, procedures, and training; and d. a written implementation statement, certified by attesting to, containing documentation of, and setting forth the details of implementation of the Consultant's 11. The Proposed Client Notification letter required by paragraph B.9 must include: a. A description of the Orders and this Consent Order; b. a statement that fees were charged to the client while were not to provide advisory services, and that the clients may have legal rights under the Michigan Uniform Act; and c. a copy of updated Form ADV, Parts 2, A and B. & Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of 11 attention of Final Order Monitoring, a written Report, and a Proposed Client, Notification letter. 10. The Report required by paragraph B.9 must address, at a minimum: a. The adequacy of policies, procedures, systems, and training regarding with its regulatory obligations under the Act and its rules and orders; b. a description of the review performed, and the conclusions reached; c. the Consultant's for modifications and additions to policies, systems, procedures, and training; and d. a written implementation statement, certified by attesting to, containing documentation of, and setting forth the details of implementation of the Consultant's 11. The Proposed Client Notification letter required by paragraph B.9 must include: a. A description of the Orders and this Consent Order; b. a statement that fees were charged to the client while were not to provide advisory services, and that the clients may have legal rights under the Michigan Uniform Act; and c. a copy of updated Form ADV, Parts 2, A and B.

& Consent Order etto Global Capital, LLC, and Peter Savarino Complaint Nos, 344387 &.344388 Page of 11 12. A copy of the proposed Client Notification. Letter required by paragraph B.9 must be provided to the Bureau before send it to all clients from whom advisory fees were: collected from January 1, 2Q21, through the issued and. entered date of this order. The Bureau will have ten business days to object to the proposed Client Notification. If the Bureau does not object, must send the correspondence to all advisory firm clients. no later than days after submitting the. Proposed. Notification to the Bureau. 13. Within days of issued and entered date of this Consent Order, must submit to the Bureau at the address identified in Paragraph B.3, or to. LARA-CSCL-Securities-Audit@michiean.eov to the attention of Final Order Monitoring, a certification that the. Notification to Clients was mailed. The submission murk include a list each client to whom the notification was mailed and the method of delivery. 14. must also retain the to conduct a follow-up review and submit a written Final Report to the Parties, including the Bureau. The Final Report must be submitted to the Bureau one year from the issued and entered date of this Consent Order. In the Final Report, the must address Respondent's; implementation of the made in the report required by paragraphs B.9 and B.10. The Final Report must be submitted to the Bureau at the address identified in paragraph & Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos, 344387 &.344388 Page of 11 12. A copy of the proposed Client Notification. Letter required by paragraph B.9 must be provided to the Bureau before send it to all clients from whom advisory fees were: collected from January 1, 2Q21, through the issued and. entered date of this order. The Bureau will have ten business days to object to the proposed Client Notification. If the Bureau does not object, must send the correspondence to all advisory firm clients. no later than days after submitting the. Proposed. Notification to the Bureau. 13. Within days of issued and entered date of this Consent Order, must submit to the Bureau at the address identified in Paragraph B.3, or to. LARA-CSCL-Securities-Audit@michiean.eov to the attention of Final Order Monitoring, a certification that the. Notification to Clients was mailed. The submission murk include a list each client to whom the notification was mailed and the method of delivery. 14. must also retain the to conduct a follow-up review and submit a written Final Report to the Parties, including the Bureau. The Final Report must be submitted to the Bureau one year from the issued and entered date of this Consent Order. In the Final Report, the must address Respondent's; implementation of the made in the report required by paragraphs B.9 and B.10. The Final Report must be submitted to the Bureau at the address identified in paragraph

& Consent Order Creo Global Capital, LLC; and Peter Savarino Complaint Nos. 344387 &.344388 Page 7 Of it B.3 above,. 'or to LARA.CSCL-SecuritiestAudit@michigan.gov the attention of Final Order Monitoring. 16. Upon written request showing good cause, the Bureau may extend any of the procedural dates set forth above in writing. 16. Hearing Requests are revoked without further action by the: Parties. 17. Following the issuance and entry of this Consent Order, the Bureau will file Forms U6 with the Central Registration Depository reflecting the Parties' resolution of the Orders. 18. This mutter is a public record required to be published and made available to the public, under section of the Michigan Freedom of Information Act, MCL 16.241. The Bureau publishes copies of orders issued under the Act to its website and includes a. summary of order content in monthly disciplinary action reports separately published there, 19. The may use any of the facts set out in the Orders when considering future applications for by and agree to waive any assertion or claim under MCL 461.2412(9) which would otherwise bar the from consideration of such facts in making her determination. & Consent Order Creo Global Capital, LLC; and Peter Savarino Complaint Nos. 344387 &.344388 Page 7 Of it B.3 above,. 'or to LARA.CSCL-SecuritiestAudit@michigan.gov the attention of Final Order Monitoring. 16. Upon written request showing good cause, the Bureau may extend any of the procedural dates set forth above in writing. 16. Hearing Requests are revoked without further action by the: Parties. 17. Following the issuance and entry of this Consent Order, the Bureau will file Forms U6 with the Central Registration Depository reflecting the Parties' resolution of the Orders. 18. This mutter is a public record required to be published and made available to the public, under section of the Michigan Freedom of Information Act, MCL 16.241. The Bureau publishes copies of orders issued under the Act to its website and includes a. summary of order content in monthly disciplinary action reports separately published there, 19. The may use any of the facts set out in the Orders when considering future applications for by and agree to waive any assertion or claim under MCL 461.2412(9) which would otherwise bar the from consideration of such facts in making her determination.

& Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387& 344388 Page of 1.1 20. must comply with any reasonable investigative demands made by the Bureau in the future for purposes of ensuring with this Consent Order or the Act. 21. The Parties acknowledge and agree that the retains the right to pursue any action or permitted by law to, enforce the provisions of this Consent order. 22. waive any right to a hearing or appeal of this Consent Order and the Orders under the. Act, the rules promulgated under the Act, the Administrative Procedures Act of 1969, PA. 306, MCL 24.201 et seq., or other applicable law. 23. This Consent Order is fully effective and binding on its issued and entered date. The may accept or reject it. If the rejects it,. the Bureau will submit the Hearing. Requests for adjudication through a formal proceeding. 24. This. Consent Order resolves only activities, cOnduct, and statutory violations alleged in the Orders; but it does not address or resolve any other conduct or potential statutory violations engaged in. by not expressly contained in the Orders or occurring after the date this Consent Order is entered. Further, this Consent Order does not preclude any other individual or entity, including but not limited to other authorized state or federal agencies or officials, from initiating or pursuing civil or' criminal & Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387& 344388 Page of 1.1 20. must comply with any reasonable investigative demands made by the Bureau in the future for purposes of ensuring with this Consent Order or the Act. 21. The Parties acknowledge and agree that the retains the right to pursue any action or permitted by law to, enforce the provisions of this Consent order. 22. waive any right to a hearing or appeal of this Consent Order and the Orders under the. Act, the rules promulgated under the Act, the Administrative Procedures Act of 1969, PA. 306, MCL 24.201 et seq., or other applicable law. 23. This Consent Order is fully effective and binding on its issued and entered date. The may accept or reject it. If the rejects it,. the Bureau will submit the Hearing. Requests for adjudication through a formal proceeding. 24. This. Consent Order resolves only activities, cOnduct, and statutory violations alleged in the Orders; but it does not address or resolve any other conduct or potential statutory violations engaged in. by not expressly contained in the Orders or occurring after the date this Consent Order is entered. Further, this Consent Order does not preclude any other individual or entity, including but not limited to other authorized state or federal agencies or officials, from initiating or pursuing civil or' criminal

& Consent Order CS Global Capital, LLC, and. Peter Savarino Complaint Nos. 344337 & 344388. of action against and does not preclude Bureau staff from referring this matter to any law enforcement agency. The Consent Order does not preclude the Bureau or its staff from fully cooperating with any state or federal agency or official that may investigate or pursue its own civil or criminal enforcement against Respondent. 25. This Consent Order may only be modified in writing signed by each Party and approved by the Administrator's subsequent. Order. 26. The Parties agree that facsimile or electronically transmitted signatures may be submitted in with this Consent Order and are binding on that party to the same extent as an original signature. [The remainder of this page intentionally left blank] & Consent Order CS Global Capital, LLC, and. Peter Savarino Complaint Nos. 344337 & 344388. of action against and does not preclude Bureau staff from referring this matter to any law enforcement agency. The Consent Order does not preclude the Bureau or its staff from fully cooperating with any state or federal agency or official that may investigate or pursue its own civil or criminal enforcement against Respondent. 25. This Consent Order may only be modified in writing signed by each Party and approved by the Administrator's subsequent. Order. 26. The Parties agree that facsimile or electronically transmitted signatures may be submitted in with this Consent Order and are binding on that party to the same extent as an original signature. [The remainder of this page intentionally left blank]

& Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of Through their signatures, the Parties agree to the above terms and conditions. Signed: Dated: Peter avarino Signed: Dated: Global Capital, LLC By: Peter Savarino, its Managing Member Approved by: Signed: Dated: Lindsay B. DeRosia Interim & Audit Division Director and Licensing Bureau Reviewed and Drafted by: Signed: Michael Hill (P73084) Aaron Levin (P81310) Assistant Attorneys General Attorneys for the Bureau Dated: & Consent Order Creo Global Capital, LLC, and Peter Savarino Complaint Nos. 344387 & 344388 Page of Through their signatures, the Parties agree to the above terms and conditions. Signed: Dated: Peter avarino Signed: Dated: Global Capital, LLC By: Peter Savarino, its Managing Member Approved by: Signed: Dated: Lindsay B. DeRosia Interim & Audit Division Director and Licensing Bureau Reviewed and Drafted by: Signed: Michael Hill (P73084) Aaron Levin (P81310) Assistant Attorneys General Attorneys for the Bureau Dated: 2/11/2022/s/ Lindsay DeRosia2/11/22

& Consent Order Creo Global Capital, LLC,.and Peter Savarino Complaint Nos. 344387.& 344388 Page of II C. ORDER The NOW, THEREFORE, ORDERS: THE TERMS AND CONDITIONS IN THE ABOVE FULLY EXECUTED STIPULATION ARE INCORPORATED IN THIS. CONSENT ORDER. By: Linda Clegg and Director and. Licensing Bureau. & Consent Order Creo Global Capital, LLC,and Peter Savarino Complaint Nos. 344387.& 344388 Page of II C. ORDER The NOW, THEREFORE, ORDERS: THE TERMS AND CONDITIONS IN THE ABOVE FULLY EXECUTED STIPULATION ARE INCORPORATED IN THIS. CONSENT ORDER. By: Linda Clegg and Director and. Licensing Bureau. /s/ Linda Clegg

STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS CORPORATIONS, SECURITIES, AND COMMERCIAL LICENSING BUREAU In the matter of: Agency No. 344387 CREO GLOBAL CAPITAL, LLC Unregistered, IARD# 159771 Respondent. This day of re a s s entered , NOTICE AND ORDER TO CEASE AND DESIST Linda Clegg, the Director ("Administrator") of the and Licensing Bureau ("Bureau"), pursuant to her statutory authority and responsibility to administer and enforce the Michigan Uniform Act (2002), PA 551, as amended, MCL 451.2101 et seq ("Securities Act"), hereby orders Creo Global Capital, LLC ("Respondent") to cease and desist from acting as an unregistered adviser, contrary to the Act. is notified of the opportunity to request a hearing in this matter. I. BACKGROUND A. The 1. Creo Global Capital, LLC is a Michigan limited liability company which is not in any capacity under the Act in Michigan. It was as an adviser until December 31, at which time it failed to renew its registration. B. Findings of Fact Bureau staff began an investigation of Respondent's activities under the Act in Michigan after failed to renew its as an adviser at the end of 2020, and failed to complete an application to re-register itself thereafter.

Page of 2. Bureau staff's investigation developed evidence that holds itself out to the public as an adviser by maintaining a public-facing website advertising advisory services to Michigan investors. 3. is not as an adviser and has failed to claim an exemption, exception, preemption, or exclusion justifying the failure to register. II. RELEVANT STATUTORY PROVISIONS 1. Section 102(e) of the Act, MCL 451.2102(e) defines "investment adviser", in part, as: "Investment adviser" means a person that, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or the advisability of investing in, purchasing, or selling securities or that, for compensation and as a part of a regular business, issues or promulgates analyses or reports concerning securities. The term includes a financial planner or other person that, as an integral component of other financially related services, provides advice to others for compensation as part of a business or that holds itself out as providing advice to others for compensation... (Emphasis added). 2. Section 403(1) of the Act, MCL 451.2403(1), states: A person shall not transact business in this state as an adviser unless the person is under this act as an adviser or is exempt from as an adviser under subsection (2). 3. Section 503(1) of the Act, MCL 451.2503(1), states: In a civil action or under this act, a person claiming an exemption, exception, preemption, or exclusion has the burden to prove the applicability of the exemption, exception, preemption, or exclusions. III. CONCLUSIONS OF LAW 1. Creo Global Capital, LLC meets the defmition of adviser under the Act, is not as an adviser, and has failed to claim a relevant exemption from registration, in violation of MCL 451.2403(1). IV. ORDER IT IS THEREFORE ORDERED, pursuant to section of the Act, MCL 451.2604, that: Notice & Order to Cease & Desist Creo Global Capital, LLC (CN 344387) Page of Page of 2. Bureau staff's investigation developed evidence that holds itself out to the public as an adviser by maintaining a public-facing website advertising advisory services to Michigan investors. 3. is not as an adviser and has failed to claim an exemption, exception, preemption, or exclusion justifying the failure to register. II. RELEVANT STATUTORY PROVISIONS 1. Section 102(e) of the Act, MCL 451.2102(e) defines "investment adviser", in part, as: "Investment adviser" means a person that, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or the advisability of investing in, purchasing, or selling securities or that, for compensation and as a part of a regular business, issues or promulgates analyses or reports concerning securities. The term includes a financial planner or other person that, as an integral component of other financially related services, provides advice to others for compensation as part of a business or that holds itself out as providing advice to others for compensation... (Emphasis added). 2. Section 403(1) of the Act, MCL 451.2403(1), states: A person shall not transact business in this state as an adviser unless the person is under this act as an adviser or is exempt from as an adviser under subsection (2). 3. Section 503(1) of the Act, MCL 451.2503(1), states: In a civil action or under this act, a person claiming an exemption, exception, preemption, or exclusion has the burden to prove the applicability of the exemption, exception, preemption, or exclusions. III. CONCLUSIONS OF LAW 1. Creo Global Capital, LLC meets the definition of adviser under the Act, is not as an adviser, and has failed to claim a relevant exemption from registration, in violation of MCL 451.2403(1). IV. ORDER IT IS THEREFORE ORDERED, pursuant to section of the Act, MCL 451.2604, that: Notice & Order to Cease & Desist Creo Global Capital, LLC (CN 344387) Page of

Page of A. shall immediately CEASE AND DESIST from acting as an unregistered adviser, contrary to the Act. B. Pursuant to section 604(2) of the Act, this Notice and Order to Cease and Desist is IMMEDIATELY EFFECTIVE. C. In a Final Order, the intends to impose civil fines of $10,000.00 against under MCL 451.2604(4). This Notice and Order to Cease and Desist may become final pursuant to Section VI, below. D. Pursuant to section of the Act, MCL 451.2508, a person that willfully violates the Act, or an order issued under the Act, is guilty of a felony punishable by imprisonment for not more than years or a fine of not more than $500,000.00 for each violation, or both. An individual convicted of violating a rule or order under this act may be fined, but shall not be imprisoned, if the individual did not have knowledge of the rule or order. V. NOTICE OF OPPORTUNITY FOR HEARING Section of the Act, MCL 451.2604, provides that has days beginning with the first day after the date of service of this Notice and Order to Cease and Desist to submit a written request to the asking that this matter be scheduled for a hearing. If the receives a written request in a timely manner, the shall schedule a hearing within days after receipt of the request. The written request for a hearing must be addressed to: & Licensing Bureau Regulatory Division P.O. Box 30018 Lansing, MI 48909 By email: CSCL-FOIA@Michigan.gov VI. ORDER FINAL ABSENT HEARING REQUEST A. Under section of the Act, MCL 451.2604, the Respondent's failure to submit a written request for a hearing to the within days after the service date of this NOTICE AND ORDER TO CEASE AND DESIST shall result in this order becoming a FINAL ORDER by operation of law. The FINAL ORDER includes the imposition of the fines cited described in section IV.C., and the fine amounts set forth below will become due and payable to the within sixty (60) days after the date this order becomes final: Notice & Order to Cease & Desist Creo Global Capital, LLC (CN 344387) Page of

Page of $10,000.00 — Creo Global Capital, LLC, under section of the Act, MCL 451.2604. B. CIVIL FINE payments should be payable to the STA h OF MICHIGAN and contain information (e.g., names and complaint numbers) and mailed to the following address: & Licensing Bureau Final Order Monitoring P.O. Box 30018 Lansing, MI 48909 C. Failure to comply with the terms of this Order within the time frames specified may result in additional penalties, including the summary suspension or continued suspension of all registrations held by under the Act, the denial of any renewal, and/or the denial of any future applications for registration, until full is made. may voluntarily surrender or withdraw a under the Act; however, the surrender or withdrawal will not negate the summary suspension or continued suspension of the relevant registrations or any additional proceedings if a violation of this Order or the Act occurred. D. Failure to pay the civil fines within six (6) months after this Order becomes final may result in the referral of the civil fines to the Michigan Department of Treasury for collection action against Respondents. DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS CORPORATIONS, SECURITIES, AND COMMERCIAL LICENSING BUREAU Linda Clegg, Admix trator and Director Da e & Licensing Bureau Notice & Order to Cease & Desist Creo Global Capital, LLC (CN 344387) Page of