UNITED STATES OF AMERICA

UNITED STATES OF AMERICA

Before the

SECURITIES AND EXCHANGE COMMISSION

SECURITIES EXCHANGE ACT OF 1934

Release No. 106000 / July 28, 2026

ADMINISTRATIVE PROCEEDING

File No. 3-21405

In the Matter of

Pinnacle Investments, LLC,

Respondent.

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ORDER DIRECTING DISBURSEMENT

OF FAIR FUND

On June 30, 2025, 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.

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2

Exchange Act Rel. No. 103346 (June 30, 2025).

17 C.F.R. § 201.1103.

On July 11, 2025, the Commission issued an order appointing Simpluris, Inc., as the

Fund Administrator to oversee the administration and distribution of the Fair Fund. 3

On August 27, 2025, the Division of Enforcement, pursuant to delegated authority, issued

an order approving the Modified Plan of Distribution, 4 and posted the approved Modified Plan of

Distribution (the “Plan”). 5

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

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

Plan.

Pursuant to the Plan, the Fund Administrator has submitted a payment file to

Commission staff with a reasonable assurances letter as to the completeness and accuracy of the

information contained therein. The Commission staff has reviewed and accepted the payment file

and requests, pursuant to Rule 1101(b)(6) of the Commission’s Rules, 17 C.F.R. §

201.1101(b)(6), that the Commission authorize the transfer of $174,555.85 from the Fair Fund to

the Fair Fund’s escrow account at Huntington National Bank for distribution by the Fund

Administrator in accordance with the Plan.

Accordingly, it is hereby ORDERED, that Commission staff shall transfer $174,555.85

from the Fair Fund to the Fair Fund’s escrow account, for a total distribution of $174,555.85 by

the Fund Administrator in accordance with the Plan.

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

Vanessa A. Countryman

Secretary

See Exchange Act Rel. No. 103441 (July 11, 2025)

See Exchange Act Rel. No. 103791 (Aug. 27, 2025)

5

The Proposed Plan was modified to name Simpluris, Inc. as the Fund Administrator.

6

17 C.F.R. § 200.30-4(a)(21)(v).

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