Keitz Investment Management Fined $12,000 for Securities Violations

C OMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIESCOMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING ANDSECURITIES, BUREAU OF SECURITIES COMPLIANCE AND EXAMINATIONSv.KETTZ INVESTMENT MANAGEMENI LTD. :Docket No. : 26(sEC-CAo)BACKGROT]I[D1. The Department is the Commonwealth of Pennsylvania's administrative agencyauthorized and empowered to administer and enforce the 1972 Act. 2. The Bureau is primarily responsible for administering and enforcing the 1972 Actfor the Department.ICONSENT AGREEMENT A}[D ORDERThe Commonwealth of Pennsylvania, acting through the Department of Banking and Securities ("Department'), Bureau of Securities Compliance and Examinations ("Bureau"), hasconducted an investigation of the business practices of Keitz Investment Management, Ltd.("KIM") and its officers and employees. Based on the results of its investigation, the Bureau has concluded that KIM has operated in violation of the Pennsylvania Securities Act of 1972,70 P.S. $ 1-101 et seq. (*1972 Act"). KIM, in lieu of litigation, and without admiuing or denying the allegations herein, and intending to be legally bound, hereby agrees to the terms of this ConsentAgreement and Order ("Order').FILED 2026 JAN 29 AM 9:03 PA DEPARTMENT OF BANKING AND SECURITIES

1. Keitz Investnaent Management, Ltd. ('oKlM"), CRD # 123770, was, at all material times herein, a Pennsylvania corporation with an address at , 4. From on or about February 10, 1995, until the present, KIM was registeredpursuant to Section 301(c) of the 1972 Act,70 P.S. $ 1-301(c), as an investment adviser.5. Regulation 303.012(0 provides that "[a]n investment adviser registered under theU972 Act] shall take steps necessary to ensure that material information contained in its Form ADV and exhibits remains current and accurate. If a material statement made in Form ADV andexhibits becomes incorrect or inaccurate the investment adviser shall file with the Department an amendment on Form ADV within 30 days of the occrrrence of the event which requires thefiling of the amendment." 10 Pa. Code$ 303.012(0. 6. From on or about January 2020 untit January 2024, KIM did not take steps necessary to ensure that material information contained in its Form ADV and exhibits remainscurrent and accurate.YIOLATION7.By engaging in the acts and conduct set forth in paragraphs 3 through above, KIM failed to take steps necessary to enflre that material information contained in its Form ADV and exhibits remains current and accurate to achieve compliance with the Act and othersecurities laws and regulations, which acts and conduct form a basis to deny, suspend, revoke, or condition the registration of KIM or to censure KIM pursuant to Section 305(a)(v) of the Act,70 P.S. $ 1-305(a)(v), and Regulation 303.012(i), 10 Pa. Code $ 303.012(i), promulgatedthereunder.Redacted RELIEF'8. KIM shall pay the Deparffnent an administrative assessment in the amount of $12,000.00. Payment shall be made by certified check or money order made payable to the"Department of Banking and Securities" and shall be mailed or delivered in person to the Bureauof Securities Compliance and Examinations located at 17 N. Second Street, Suite 1300, Harrisburg, Pennsylvania fiLAI. The assessment shall be paid as follows: a. $1000.00 on or before May 1, 2026; b. $1000.00 on or before August 1,2026;c- $1000.00 on or before November 1,2A26;d. $1000.00 on or before February 1,2027; e. $1000.00 on orbefore May 1, 2A27; f. $1000.00 on or before August 1,2027; g. $1000.00 on or before November l, 2027 ;h. $1000.00 on or before February 1,2A28;i. $1000.00 on or before May l, 2A28; j. $1000.00 on or before August 1,2A28;k. $1000.00 on or before November 1,2A28; and1. $1000.00 on or before February t,2029. 9.KIM is ORDERED to comply with the 1972 Act, and Regulations adopted by the Department, and in particular Section 305(aXv) of the 1972 Act,70 P.S. $ l-305(a)(v).ShouldJ

KIM fail to pay the assessment as set forth in paragraph 8 above, the sanctions set forth elsewhere in the Order shall continue in fulI force and effect until full payment is made. However, this provision shall not be construed as affording KIM the option of either paying theassessment or being indefinitely subject to the sanctions. 10. Should KIM fail to comply with any and/or all provisions of this Order, the Department may impose additional sanctions and costs and seek other appropriate relief subjectto KIM's right to a hearing pursuant to the L972 Act. F'URTHER PROYISIONS11. Consent. KIM hereby knowingly, willingly, voluntarily and irrevocably consentsto the entry of this Order pursuant to the Bureau's authority under the 1972 Act and agrees that it understands all of the terms and conditions contained herein. KIM, by voluntarily entering intothis Ordeq waives any right to a hearing or appeal conceming the terms, conditions, alrrd/orpenalties set forth in this Order. 12. Entire Agreement. This Order contains the entire agreement between theDepartment and KIM. There are oo other terrrs, obligations, covenants, representations,statements, conditions, or otherwise, of any kind whatsoever concerning this Order. This Ordermay be amended in writing by mutual agreement by the Department and KIM. 13. Binding Nature. The Department, KlM, and all officers, owners, directors, employees, heirs and assigns of KIM intend to be and are legally bound by the terms of thisOrder.

|4.Counsel.Thisorderisenteredintobythepartiesuponfullopportunityforlegaladvice from legal counsel'15. Effectiveness. KIM hereby stipulates and agrees that the order shall becomeeffective on the date the Bureau executes the order ("Effective Date")'16. Other Enforcement Action'(a) The Departrnent reserves all of its rights, duties, and authority to enforce allstatutes, rules, and regulations under its jurisdiction against KIM in the future regarding allmatters not resolved by this Order'(b) KIM acknowledges and agrees that this Order is only binding upon theDepartrnent and not any other local, state or federal agency, departrnent, or office regardingmatters within this Order. 17. Authorization. The parties below are authorized to execute &is Order and legallybind their respective parties.18. Count€rparr[S. This Order may be executed in separate counterparts, by facsimileand/or by PDF.19. Titles. The titles used to identiff the paragraphs of this document are for the convenience of reference only and do not control the interpretation of this document. 20. Finding. The Department finds that it is necessary and appropriate in the publicinterest and for the protection of investors, and consistent with the purposes fairly intended by the policy and provisions of the 1972 Act to issue this Order.

WIIEREFORE, in consideration of the foregoing, including the recital paragraphs, theCommonwealth of Pennsylvania, Department of Banking and Securities, Bureau of Securities Compliance and Examinations and Keitz Investment Management, Ltd., intending to be legally bound, do hereby execute this Consent Agreement and Order.FOR THE COMMONWEALTH OF PENNSYLVANIADEPARTMENT OF BANKING AND SECURITIES BUREAU OF SECURITIES COMPLIANCE AND EXAMINATIONS Eric Pistilli, Deputy Secretary for Securities Date:rOR KEITZ INVESTMENT MANAGEMENT LTD.Michael Owner and Chief Compliance OfficerDate: -Jqr*u fr'&) 'Zb '2 b L L=01/27/2026RedactedRedacted