UNITED STATES OF AMERICA

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 103579 / July 29, 2025

ADMINISTRATIVE PROCEEDING

File No. 3-20880

In the Matter of

Kahn Brothers Advisors, LLC and

Thomas Kahn,

Respondents.

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ORDER DIRECTING DISBURSEMENT

OF FAIR FUND

On August 14, 2023, the Division of Enforcement, pursuant to delegated authority,

published a Notice of Proposed Plan of Distribution and Opportunity for Comment (“Notice”), 1

pursuant to Rule 1103 of the Commission’s Rules on Fair Fund and Disgorgement Plans

(“Commission’s Rules”); 2 and simultaneously posted the Proposed Plan of Distribution (the

“Proposed Plan”). The Notice advised interested persons that they could obtain a copy of the

Proposed Plan from the Commission’s public website or by submitting a written request to

Sondra Panahi, United States Securities and Exchange Commission, 801 Brickell Ave, Suite

1950, Miami, FL 33131. The Notice also advised that all persons desiring to comment on the

Proposed Plan could submit their comments, in writing, within 30 days of the Notice. The

Commission received no comments on the Proposed Plan during the comment period. On

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Exchange Act Rel. No. 98119 (Aug. 14, 2023).

17 C.F.R. § 201.1103.

October 10, 2023, the Division of Enforcement, pursuant to delegated authority, issued an order

approving the Proposed Plan, 3 and posted the approved Plan of Distribution (the “Plan”).

The Plan provides for the distribution of the Fair Fund, 4 plus accumulated interest, less

taxes, fees, and expenses, to the harmed investors according to the methodology set forth in the

Plan.

In accordance with the Plan, a Payee List has been submitted to the Commission staff in a

Commission-approved format. The Commission staff has reviewed and accepted the Payee List

and requests, pursuant to Rule 1101(b)(6) of the Commission’s Rules on Fair Fund and

Disgorgement Plans, 5 that the Commission authorize the transfer of $766,060.67 from the Fair

Fund in accordance with the Payee List to the escrow account at The Huntington National Bank,

N.A. for distribution in accordance with the Plan.

Accordingly, it is hereby ORDERED that the Commission staff transfer $766,060.67

from the Fair Fund to the escrow account at The Huntington National Bank, N.A. for distribution

in accordance with the Plan.

For the Commission, by the Division of Enforcement, pursuant to delegated authority. 6

Vanessa A. Countryman

Secretary

See Order Approving Plan of Distribution, Exchange Act Rel. No. 98714 (Oct. 10, 2023).

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

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17 C.F.R. § 201.1101(b)(6).

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17 C.F.R. § 200.30-4(a)(21)(v).

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