UNITED STATES OF AMERICA

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 105961 / July 21, 2026

ADMINISTRATIVE PROCEEDING

File No. 3-22481

In the Matter of

NORTH EAST ASSET

MANAGEMENT GROUP,

INC. and GREGORY A.

ZANDLO,

Respondents.

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NOTICE OF PROPOSED PLAN OF

DISTRIBUTION AND

OPPORTUNITY FOR COMMENT

Notice is hereby given, pursuant to Rule 1103 of the United States Securities and

Exchange Commission’s (the “Commission”) Rules on Fair Fund and Disgorgement Plans (the

“Commission’s Rules”), 17 C.F.R. § 201.1103, that the Division of Enforcement has submitted

to the Commission a proposed plan of distribution (the “Proposed Plan”) for the distribution of

monies paid in the above-captioned matter.

On June 3, 2025, the Commission instituted and simultaneously settled administrative

and cease-and-desist proceedings (the “Order”) against the Respondents. 1 From December 1,

2020, through May 31, 2022, North East Asset Management Group, a State of Minnesotaregistered investment adviser, and Zandlo, North East Asset Management Group’s sole principal,

owner, and employee, engaged in cherry-picking when they disproportionally allocated certain

profitable trades to accounts for North East Asset Management Group, Zandlo, and individuals

related to Zandlo, and allocated unprofitable trades to other North East Asset Management

Group advisory clients. The Commission ordered the Respondents to pay $91,208.00 in

disgorgement, $19,432.83 in prejudgment interest, and a $141,000.00 civil money penalty, for a

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 interest collected, can be distributed to harmed investors (the “Fair Fund”).

The Fair Fund includes the $251,640.83 paid by the Respondents, and any additional

funds collected from the Respondents, pursuant to the Order, will be added to the Fair Fund. The

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Securities Exch. Act Rel. No. 103173 (Jun. 3, 2025).

Fair Fund and has been deposited in a Commission-designated account at the U.S. Department of

the Treasury, and any accrued interest will be added to the Fair Fund.

OPPORTUNITY FOR COMMENT

Pursuant to this Notice, all interested persons are advised that they may obtain a copy of

the Plan from the Commission’s public website at http://www.sec.gov/litigation/fairfundlist.htm.

Interested persons may also obtain a written copy of the Proposed Plan by submitting a written

request to Michael S. Lim, United States Securities and Exchange Commission, 100 F Street,

NE, Washington, DC 20549-5631. All persons who desire to comment on the Proposed Plan

may submit their comments, in writing, no later than thirty (30) days from the date of this

Notice:

1.

to the Office of the Secretary, United States Securities and Exchange

Commission, 100 F Street, NE, Washington, DC 20549-1090;

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by using the Commission’s Internet comment form

(http://www.sec.gov/litigation/admin.shtml); or

3.

by sending an e-mail to rule-comments@sec.gov.

Comments submitted by email or via the Commission’s website should include “Administrative

Proceeding File No. 3-22481” in the subject line. Comments received will be publicly available.

Persons should submit only information they wish to make publicly available.

THE PROPOSED PLAN

The Net Available Fair Fund 2 is comprised of the $91,208.00 in disgorgement, $19,432.83 in

prejudgment interest, and a $141,000.00 civil money penalty, for a total of $251,640.83 , plus

any interest and income earned thereon, less taxes, fees, and expenses. The Proposed Plan

provides for the distribution of the Net Available Fair Fund, comprised of the Fair Fund, plus any

accrued interest, less taxes and administrative costs, to those investors who incurred losses

between December 1, 2020, and May 31, 2022 (the “Relevant Period”) due to the misconduct of

the Respondents in allocating trades to client accounts, attached as Exhibit A.

For the Commission, by the Division of Enforcement, pursuant to delegated authority. 3

Vanessa A. Countryman

Secretary

All capitalized terms used herein but not defined shall have the same meanings ascribed to them in the Proposed

Plan.

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17 C.F.R. § 200.30-4(a)(21)(iii).

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