TITLE: Maine Securities Administrator Issues Consent Order Against Stifel, Nicolaus & Company for Unreasonable Commission Charges BODY: On March 23, 2026, the Maine Office of Securities issued a consent order against Stifel, Nicolaus & Company, Inc. (Case No. 25-20765, Consent Order No. 2026-03) resolving charges that the broker-dealer charged unreasonable commissions on low-principal equity transactions. Following a coordinated investigation, the Maine Securities Administrator determined that Stifel charged unreasonable commissions on approximately 45,352 equity transactions nationwide between May 1, 2020 and April 30, 2025, totalling $885,480.13. In Maine specifically, Stifel executed 105 equity transactions with unreasonable commissions exceeding 5 percent of the principal trade amount, totalling $1,835.74. The firm applied a minimum commission of $40 plus a $5.00 transaction fee to certain equity transactions, which frequently resulted in commissions well in excess of the Financial Industry Regulatory Authority (FINRA) Rule 2121 guideline of 5 percent. The Administrator found that Stifel failed to reasonably supervise these transactions and did not adequately detect and correct unreasonable commission charges despite having supervisory systems and policies permitting manual commission adjustments. Under the consent order, Stifel must cease the conduct, provide restitution to affected Maine customers of no less than $1,835.74 plus 6 percent interest from the transaction date to May 21, 2025, and pay an administrative fine of $20,000 to the State of Maine. Restitution must be distributed within 60 days of the order's execution. Stifel must also submit a restitution report to the Administrator within 45 days of mailing customer notification letters. The order does not create any disqualification under securities laws or FINRA rules. Stifel neither admitted nor denied the findings.

CRITICAL BEHAVIORAL RULES (these override all other instructions): - Always generate an update. Never refuse, never ask for more information, and never say you cannot produce output. - If the source content is in a non-English language, translate and summarise it into English. - If the source content is sparse, administrative, procedural, or lacks expected regulatory elements, extract and present whatever information is available. This includes personnel appointments, cabinet changes, institutional restructures, and any official government action. - Never include disclaimers or meta-commentary about source quality, translation limitations, or content gaps. - If you cannot determine a piece of information, simply omit it rather than noting its absence. - Content scope is broad: generate updates for all government and official publications including regulatory changes, legislation, consultations, decrees, personnel appointments, institutional announcements, administrative decisions, and any other government or authority action. Do not filter by topic relevance. You are an AI assistant generating Horizon scanning updates for government, regulatory, and institutional content. GROUND RULES FOR HORIZON SCANNING UPDATES: Title Requirements: - The jurisdiction must appear in the update title - For PC/FS updates, use title case - Titles must be declarative statements (not questions) Body Text Requirements: - Target 200-250 words, but shorter is acceptable when source material is limited - Include as many of the following as the source material supports: jurisdiction, authority, brief description of the development or action, relevant dates (effective dates, announcement dates, enforcement dates) - Include links to relevant legislation where applicable - Reference all initialisms in full on first use (e.g., "Financial Conduct Authority (FCA)") - Must be factual only - no speculation or sweeping statements - When information is unavailable, simply omit it rather than noting its absence Format your response as: TITLE: [Your declarative title with jurisdiction] BODY: [Your factual summary with all required elements]

Horizon Scanning Outline. Purpose of Analyst writing Horizon Scanning Updates Distil the key points of the development for clients to quickly see what is changing without reading the whole source. Provide updates to key events from government and regulatory bodies, including consultations, legislation, decrees, appointments, and institutional changes. Simplify complex updates and sources so that they’re succinct, concise and clear to read. Consistently structure and write updates in the same format. Structure of Horizon Scanning Updates Always think about: Who (Authority) is publishing/enforcing the content/regulation? Where (Jurisdiction)? What type of document or announcement is it (e.g., consultation, regulation, decree, appointment, institutional change)? What is changing/being informed? Who is this update applicable to (credit, e-money institutions, etc.)? Why is this update noteworthy? What is its significance? When is the update applicable? Title Describe what the update is about. Include the jurisdiction (where); subject (authority - who); and a verb (doing word such as issues, publishes, launches, etc.- what). All titles should be written in present tense. Avoid using acronyms Approx 10 - 20 words Example Turkey’s Personal Data Protection Authority Publishes Data Protection Guidance Paragraph 1 Open with the date of the update (When) Name the authority that released the update (Who) Summarise the release (What) Example On June 20, 2025, the Securities and Exchange Board of India (SEBI) launched a consultation on guidelines for responsible usage of artificial intelligence (AI) and machine learning (ML) in Indian securities markets. Paragraph 2 Summarise key points. The change/amendment aiming to achieve (what) What is its objective, why is it happening? Why is it significant? (why) Who does it impact or concern? (Who) The aim is to summarise large source documents so the reader doesn’t need to do it themselves. DO NOT just copy the first few sentences of the document. Example SEBI aims to produce guidelines providing high-level principles for market participants to establish reasonable procedures and control systems for the supervision and governance of AI/ML applications and tools. To develop this, SEBI created a working group to: Study Indian and global best practices. Prepare the guidelines. Address the concerns and issues arising from AI/ML usage. SEBI is consulting on the following principles to develop the guidelines: Model governance: Market participants should have an internal team with adequate skills and experience to monitor and oversee the use of AI/ML-based models. Investor protection and disclosure: Market participants using AI/ML that impacts their customers should disclose such usage. Relevant use cases include algorithmic trading, asset management, advisory, and support services. The disclosure must include product features, purpose, risks, limitations, and other relevant information. Testing framework: Market participants should adequately test and continuously monitor AI/ML-based models to validate their results. Fairness and bias: AI/ML models should not favour or discriminate against any group of clients. Data privacy and cybersecurity: As AI/ML systems rely on data processing, market participants should maintain a clear policy for data security. Paragraph 3 Acts as a “Call To Action”. Provide forward looking context: What actions need to be taken? Who needs to take action? Next steps to the development. Include any relevant dates (When) Response dates - should always be provided for consultations Effective dates - should be used if we know definitively that the act/reg is coming into effect on a specific date, i.e., it has been passed/adopted. Example The comment period ends on February 2, 2026, at 11:59pm and responses can be submitted here. The comment response is expected to be published in April 2026. References Should always be included, and should come from a primary source, i.e., an authority, not a news source. General Style Notes: 200-250 words Active voice Authorities and companies referenced as a single entity (“It”, not “they”) Titles in title case Internal Vixio vocabulary guide Content Style Guide Spelling should generally be in UK English, except for North American-facing (US/Canada/Caribbean) content. A Acronyms - should be spelt out in first instance with acronym in brackets. For example, Financial Conduct Authority (FCA). Act - when just referring to “the act”, it does not need a capital a. Active prose - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Advise/advice - advise (verb) - to offer suggestions (for example, I advised them to sell). - advice (noun) - give formal suggestions (for example, I gave them advice). Advisor NOT adviser Affect - verb - “have an effect on something, make a difference” Alternate/Alternative - Alternate (adjective) - means every other - Alternative (noun) - strictly one out of two - Alternative (adjective) - the other of two things. Although - not to be interchanged with “while” - means “in spite of” NOT “at the same time”. AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT Among/while NOT Amongst/whilst API - application programming interface Apostrophes - to be used in possessives, i.e. an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Article/Part/Section - should be capitalised when referring to a specific article - e.g., Article 4 of the Gambling Act. Assure/ensure - not to be confused - assure means “tell someone something positively to dispel doubts”, ensure means “makes certain something will occur”. B Between - should always appear with “and” NOT “to” - for example, between this summer and next summer. Big tech - two words, breaks convention of other tech words Bills - U.S. bill names should appear without full points and a space between the letters and numbers (i.e. SB 522 NOT SB522 or S.B. 522). Brackets - square brackets should be used to denote deletions or additions in quotes. Buy now, pay later - no hyphens Bullet points - see Lists C Capitalisation - all important words should have a capital in titles (i.e. just not joining words such as and/of/the/a) Cardrooms not card rooms Cases - legal cases should appear in italics, with a v for versus. Casino-resorts NOT casino resorts or resort-casinos Chief executive NOT chief executive officer Colons (:) - used between independent clauses when the second clause explains, illustrates or expands on the first (i.e. to introduce lists, quotes) Commas - to be used in figures to denote thousands to avoid confusion with years (i.e, $2,000 NOT $2000) Comparisons - compare with (highlighting differences) - compare to (highlighting similarities) Companies/organisations - singular entities (it NOT they) should be followed by “which/that” rather than “who” Ltd, not Limited Complement - to accompany something/add value Compliment - give praise (complimentary = free) Compound adjectives - should be hyphenated (sports-betting operators / first-quarter earnings) Comprise/comprising - should NOT be followed with “of”, as it means to “consist of” Conjunctions - should appear with a semi-colon before and a comma afterwards (; however, / ; therefore,) Continually - if something occurs repeatedly/regularly in the same way Continuously - if something occurs without interruption or gaps Contractions - don’t, can’t, won’t, etc. to be avoided in copy (except in marketing material and depending on tone) Contrast - by contrast - when comparing one thing to another - in contrast - simply noting a difference Counsel/Council - counsel = advice, guidance; council = an advisory group or meeting Court of Justice of the European Union (CJEU) rather than ECJ Cryptocurrency - one word, not hyphenated. Crypto-assets - hyphenated Cybersecurity - one word, not hyphenated CTF - counter-terrorism financing - NOT CFT/countering the financing of terrorism Currencies - if not using common symbols (£, $, €), then three-letter code should be used before the figure (no spaces) - for example, PLN50,000. Full term lower case (eg euro, baht, pound, dollar) m for million, bn for billion, trn for trillion. D Date format - Month, Day, Year (e.g., March 7, 2019) For Insights & Analysis summary text: can just say “today”, e.g., “Today a bill was passed for…” For Insights & Analysis body text: dates should always accompany days of the week in brackets, e.g., “On Wednesday (June 8) a bill was passed...” For NIBs: always use dates rather than days. Department for Digital, Culture, Media & Sport - ampersand Directives - for commonly used directives, style is 4th Anti-Money Laundering Directive (4th AMLD), revised Payment Services Directive (PSD2) - try to use widely known titles rather than just numbers to ensure the directives are more easily recognised. DLT - distributed ledger technology E Effect - noun - “cause something to happen”. Em dash (—) - should be used as a conjunction, not a hyphen or en dash (–). Ensure/assure - not to be confused - ensure means “makes certain something will occur”, assure means “tell someone something positively to dispel doubts”. esports NOT eSports or e-sports Euros - should be denoted with a “€” (CNTRL+ALT+4) NOT “EUR”. F fintech NOT FinTech Footnotes - avoid where possible, if necessary write them into the text or add links. G GGR - “gross gaming revenues” Government - does not need a capital g. Governor - should be written out in full, NOT Gov. Guidance (singular and plural) - does NOT need to be preceded by “a” (Guide/guides, Guideline/guidelines) H Headlines - all words should begin with a capital Horseracing NOT horse racing Hyphenation - DO: land-based, fixed-odds, cross-border, invitation-only, fast-tracked (if “a fast-tracked application”), match-fixing, year-on-year, up-to-date, whistle-blowers, six-month period, non-fungible tokens, crypto-assets, e-money - DON’T: email, blocklist, whitelist, whitelisted, cybersecurity, cryptocurrency, white paper I Impact - should be used as a noun - i.e. the new act will have an impact on… - verb means “come into forcible contact with something else”. - using “affect” as a verb is more accurate. J Judgment - legal decision Judgement - one’s own opinion Jargon - avoid using confusing terms or tabloidese, e.g. use players rather than punters. Job titles - should appear in commas after a name - for example, Neil McArthur, Gambling Commission chief executive. OR before a name with no commas - for example, Gambling Commission chief executive Neil McArthur DON’T need capitals unless a figure of importance (i.e., Prime Minister, President) Italics - whole chunks of text from legislation should be italicised; however, short quotes do not need to be. Justice Department - U.S. Department of Justice - to appear with caps (as requested by US team). K KYC - know your customer L Legislature - does not need a capital l. Less than - NOT to be confused with “fewer than” when referring to a number of something. i.e. fewer than 100 gambling tables. Licence - noun (UK), i.e. a driver’s licence License - verb/noun (US) Lists - bulleted lists should generally begin with a cap and end with a full stop (make sure they are consistent). M MONEYVAL NOT Moneyval More than - to be used instead of “over”. i.e., more than 20 players rather than over 20 players. N Names - should appear before job titles in commas - for example, Neil McArthur, Gambling Commission chief executive. Names - should be written in full in first instance and then the surname used throughout. Numbers - 1-10 should be written out (except for percentages and measurements); should always be written out at the start of sentences. Non-fungible tokens - all lowercase (non-fungible tokens) O Offence - noun (UK), i.e. commit an offence Offense - noun (US) Organisations/companies - singular entities (it NOT they) should be followed by “which/that” rather than “who” Oxford comma - (appears before “and” or “or”) - to be used sparingly and only when necessary to avoid any confusion in a sentence (i.e., where more than one “and/or” appears). Over - should not be used as a replacement for “more than”. P Parliament - does not need a capital p. Part/Section/Article - should be capitalised when referring to a specific part - e.g., Part 4 of the Gambling Act Passive voice - should always try to write in active rather than passive - more direct and clearer (For example - The report was released by the Gambling Commission (PASSIVE); The Gambling Commission released the report (ACTIVE)) Past/passed - past is a noun/adverb/adjective - “in the past”, “past experience”. - passed is the past tense of “to pass” - “the law was passed in government”. Prepaid, not pre-paid Percentages - numbers should always be written as figures percent NOT per cent or % Figures should appear with a full point between them NOT comma (for example, 5.7 percent NOT 5,7 percent) Possessives - require an apostrophe and should not be confused with plurals - i.e., an operator’s licence NOT an operators licence (for plurals, should appear after the s, with no second s). Prepositions - keep an eye out for missing prepositions - according “to”/ in accordance “with”/ in relation “to” / with regard “to” Principal - main, most important Principle - a fundamental source or basis of something Programme (UK) Program (US, UK - for computer program, Australian English) Q Quotes - speaker should be referenced in the past tense (said NOT says) Quote marks - double quote marks should be used for speech - single quote marks should only be used for titles and within quotes. (See Quote reference sheet for more information on how to use quotes.) R regtech NOT RegTech Repetition - avoid using words that mean the same thing (“and also” / “include, among others” / VLT terminals / ATM machines) Racetracks not race tracks S Seasons - when referencing a specific season of a year should be treated like a proper noun, i.e. should include a capital - Winter 2018. Section/Article/Part - should be capitalised when referring to a specific section - e.g., Section 4 of the Gambling Act. Semi-colons (;) - should be used to link two independent clauses that are closely related; or in lists without bullet points. (Do not overuse - often a full stop and new sentence will be better.) Sports betting NOT sportsbetting Sports team names Storey (pl. storeys) - level of a building (UK English) (story/stories - US English) T That defines, which informs Third person - “you” - avoid where possible. Titles - all important words should begin with a capital (i.e. just not joining words such as and/of/the/a) Tenses - content should generally be written in past tense - present tense should be used for something that has just happened and will be continuing into the future. U United States abbreviated to U.S. (Americas-focused stories on GC) / US in international content when mentioned in passing or across PC USA PATRIOT Act - should be kept as such, i.e. with caps, as it’s an acronym for “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act”) U.S. Department of Justice - Justice Department (with capitals as requested) V Vixio GamblingCompliance / Vixio PaymentsCompliance Vixio (to be used on its own after first instance) W Which informs, that defines While/among NOT Whilst/amongst While - not to be interchanged with “although” - means “at the same time” NOT “in spite of”. X Y Year quarters - Q1, Q2, H1, H2, etc. Z Acronyms AML/CTF - anti-money laundering and counter-terrorism financing - NOT AML/CFT API - application programming interface DLT - distributed ledger technology --- Now, given the above instructions and style guide, please generate a horizon scanning update based on the following webpage content. Generate the update regardless of the source language, content type, or level of detail available — this includes administrative decrees, personnel appointments, institutional changes, and any other official content. Use whatever information is present. Stifel, Nicolaus & Company, Inc., Respondent Case No. 25-20765 Consent Order : Office of Securities Skip First Level Navigation | Skip All Navigation Home | Contact Us | Careers | Calendar Site Map | Search SEC: Securities & Investment Regulation Home About us Check a licensee Investor education Small business help Industry information Laws, rules & advisory rulings Department of Professional & Financial Regulation OTHER PFR AGENCIES Professional Licensing Consumer Credit Regulation Insurance Regulation Financial Institutions Maine.gov > PFR Home > Securities Home Page > Enforcement Actions & Consent Agreements Index > Stifel, Nicolaus & Company, Inc., Respondent Case No. 25-20765 Consent Order State of Maine Office of Securities 121 State House Station Augusta, Maine 04333-0121 IN THE MATTER OF: Stifel, Nicolaus & Company, Inc., Respondent Case No. 25-20765 Consent Order No. 2026-03 <p>I. PRELIMINARY STATEMENT Pursuant to the authority granted to the Maine Securities Administrator ("Administrator") under the Maine Uniform Securities Act, 32 M.R.S. 16101 et seq. (the Act), and after investigation, careful review, and due consideration of the facts and statutory provisions set forth below, the Administrator hereby finds that there is good cause, and it is in the public interest to enter into this Consent Order (Order) with Stifel, Nicolaus & Company, Inc. (Stifel), which resolves any and all issues in controversy regarding the specific conduct described herein on the terms set forth in this Order. As the result of a coordinated investigation, the Administrator concluded that Stifel charged unreasonable commissions on certain low-principal equity transactions. Nationwide, Stifel charged unreasonable commissions on approximately 45,352 equity transactions over a five-year period from May 1, 2020 to April 30, 2025 (the Relevant Time Period), totaling $885,480.13. Stifel in full settlement of these matters neither admits nor denies the Statement of Facts as set forth in Section IV, and neither admits nor denies the Conclusions of Law set out in Section V. II. JURISDICTION 1. The Administrator has jurisdiction over matters relating to securities pursuant to the Act. 2. This Order is entered in accordance with 32 M.R.S. 16412. 3. The acts and practices that are the subject of this Order occurred while Stifel was licensed as a broker-dealer in Maine. III. RESPONDENT 4. Stifel is a broker-dealer licensed in Maine with a main address of 501 North Broadway, St. Louis, Missouri. Stifel is identified by Financial Industry Regulatory Authority (FINRA) CRD No. 793. IV. STATEMENT OF FACTS A. Stifel's Minimum Commission Practices for Certain Equity Transactions Failed to Ensure Transactions Were Executed at a Fair and Reasonable Price 5. During the Relevant Time Period, Stifel charged commissions to thousands of retail brokerage customers on equity transactions with low principal amounts. 6. During the Relevant Time Period, Stifel charged a minimum commission of $40 for certain equity buy and sell transactions (the Minimum Equity Commission) plus a $5.00 transaction fee applied to secondary transactions. 7. Stifels fee schedule notes that the maximum commission shall not exceed 5% of the principal unless the commission amount is less than $40.00.<br /> 8. Stifels policies and procedures noted that it should generally charge commissions less than 5% of the principal value of the transaction, taking into consideration the relevant circumstances, including market conditions, the expense involved in executing the order and the value of any service rendered. 9. Stifels policies and procedures permitted managers to adjust the commission amount to ensure commissions were fair and reasonable. 10. The Act prohibits Stifel from charging unreasonable commissions for services performed. 11. FINRA Rule 2121 Supplementary Material .01 (Rule 2121.01) sets a guideline of five percent for determining whether a commission is unfair or unreasonable. However, the 5% Policy is a guide, not a rule. A commission pattern of five percent or even less may be considered unfair or unreasonable. 12. During the Relevant Time Period, Stifel executed 105 equity transactions in Maine, which included an unreasonable commission for services performed (i.e., in excess of 5% of the principal trade amount), totaling $1,835.74. 13. Numerous equity transactions executed by Stifel included a commission well in excess of 5% of the principal value of the transaction. B. Stifel Did Not Reasonably Supervise Transactions that Applied the Minimum Equity Commission 14. Stifel did not reasonably supervise transactions that applied the Minimum Equity Commission charge to ensure that Stifel charged its customers a reasonable commission. 15. Stifels supervisory systems included an alert where the commission amount on an equity transaction exceeded 5%. 16. Stifels policies and procedures contemplated manual adjustment of commissions based on certain factors which would determine whether the commission was reasonable. 17. However, Stifels policies and procedures provided that a transaction which involves a small amount of money may warrant a higher percentage sales credit to cover the value of services rendered. 18. Stifels surveillance policies failed to reasonably detect and correct unreasonable commission charges. 19. As a result, Stifel failed to adequately supervise low-principal equity transactions where the Minimum Equity Commission was in excess of 5%. V. CONCLUSIONS OF LAW 20. The preceding paragraphs are incorporated by reference as though set forth verbatim herein. 21. Pursuant to 32 M.R.S. 16412(4)(I) and Maine Office of Securities Rule Chapter 504 7(1), it is a violation of the Act for a licensed broker-dealer firm to fail to establish and maintain a system to reasonably supervise its agents. 22. Stifels acts and practices, as described above, constitute a violation of 32 M.R.S. 16412(4)(I), as well as Maine Office of Securities Rule Chapter 504 7(1). VI. ORDER 23. On the basis of the Statement of Facts, Conclusions of Law, and Stifels consent to the entry of this Order, IT IS HEREBY ORDERED: A. Stifel shall permanently cease and desist from conduct in violation of 32 M.R.S. 16412(4)(I) and Maine Office of Securities Rule Chapter 504 7(1), as described herein; B. Stifel is censured by the Administrator; C. Stifel shall provide restitution to the affected Maine customers in an amount of no less than $1,835.74, representing the portion of the commissions on certain low-principal equity transactions that exceeded 5% of the principal trade amount during the Relevant Time Period, plus interest in the amount of 6% from the date of the transaction to May 21, 2025. Stifel agrees to provide restitution within sixty (60) days of execution of this Order; D. Restitution shall be in the form of a dollar credit to current customer accounts, or a check for all former customers or current customers who are entitled to restitution as a result of transactions involving an individual retirement account; E. Stifel shall provide a notice of restitution to customers on terms not unacceptable to Massachusetts, Montana, Missouri, Alabama, Washington, Texas, and Iowa (the Multi-State Group) (Notice Letter) for use by all participating jurisdictions. The Notice Letter shall be sent at least seven (7) days prior to the distribution of any restitution. Within forty-five (45) days of the mailing of the Notice Letter, Stifel shall provide the Administrator with a list of all Maine residents for whom Stifel receives a Notice Letter as returned to sender or otherwise undeliverable (Undeliverable Maine Residents). To the extent the Administrator has access to different address information, Stifel shall mail a second Notice Letter to each Undeliverable Maine Resident within thirty (30) days of the Administrator providing such different address; F. Within forty-five (45) days of the mailing of the Notice Letter, Stifel shall prepare, and submit to the Administrator, a report detailing the restitution paid pursuant to this Order, which shall include dates, amounts, and methods of the transfer of funds for all restitution payments; G. Stifel shall pay an administrative fine in the amount of $20,000 to the State of Maine within fifteen (15) days following the date of entry of this Order. Payment shall be: (1) made by United States postal money order, certified check, bank cashiers check, or bank money order; (2) made payable to Treasurer, State of Maine; (3) either mailed to the Maine Office of Securities, 121 State House Station, Augusta, Maine 04333-0121, or sent by electronic transfer per the Administrators instructions; and (4) submitted under cover letter or other documentation that identifies payment by Respondent and the docket number of the proceeding; H. Stifel shall not claim, assert, or apply for a tax deduction or tax credit with regard to any state, federal or local tax for any amounts that Stifel shall pay pursuant to this Order; I. Stifel shall not seek or accept, directly or indirectly, reimbursement or indemnification, including, but not limited to, any payments made pursuant to any insurance policy, with regard to any amount that Stifel shall pay pursuant to this Order; J. If Stifel is the subject of a voluntary or involuntary bankruptcy petition under Title 11 of the United States Code within three hundred sixty-five (365) days of the entry of this Order, Stifel shall provide written notice to the Administrator within five (5) days of the date of the petition; K. Any fine, penalty, and/or money that Stifel shall pay in accordance with this Order is intended by Stifel and the Administrator to be a contemporaneous exchange for new value given to Stifel pursuant to 11 U.S.C. 547(c)(1)(A) and is, in fact, a substantially contemporaneous exchange pursuant to 11 U.S.C. 547(c)(1)(B); L. Upon the entry of this order by the Administrator, if Stifel fails to materially comply with any of the terms set forth in this Order, the Administrator may declare this Order null and void in whole or in part; and M. For good cause shown, the Administrator may extend any of the procedural dates set forth above. Stifel shall make any requests for extensions of the procedural dates set forth above in writing to the Administrator. VII. WAIVER 24. Stifel hereby waives all rights to contest this Order, including, but not limited to, (A) the right to contest whether this Order is fair, reasonable, and/or in the public interest, (B) the right to contest this Orders findings of fact, and (C) the right to contest this Orders conclusions of law. Stifel further waives its right to a hearing and any other procedural rights provided by the Act and the Maine Administrative Procedure Act, 5 M.R.S. 8001 et seq. VIII. NO DISQUALIFICATION 25. This Order does not create any disqualification under the Act, or rules or regulations thereunder, including any disqualification from relying upon the licensing exemptions or safe harbor provisions to which Stifel may be subject. This Order is not intended to be a final order based upon violations of the Act that prohibit fraudulent, manipulative, or deceptive conduct. This Order is not intended to form the basis of any disqualifications under Section 3(a)(39) of the Securities Exchange Act of 1934; or Rules 504(b)(3) and 506(d)(1) of Regulation D, Rule 262(a) of Regulation A and Rule 503(a) of Regulation CF under the Securities Act of 1933. This Order is not intended to form the basis of disqualification under the FINRA rules prohibiting continuance in membership absent the filing of a MC-400A application or disqualification under SRO rules prohibiting continuance in membership. This Order is not intended to form a basis of a disqualification under 204(a)(2) of the Uniform Securities Act of 1956 or Section 412(d) of the Uniform Securities Act of 2002. Except in an action by the Administrator to enforce the obligations of this Order, any acts performed or documents executed in furtherance of this Order: (a) may not be deemed or used as an admission of, or evidence of, the validity of any alleged wrongdoing, liability, or lack of any wrongdoing or liability; or (b) may not be deemed or used as an admission of, or evidence of, any such alleged fault or omission of Stifel in any civil, criminal, arbitration, or administrative proceeding in any court, administrative agency, or tribunal. 26. This Order shall be binding upon Stifel and its successors and assigns, as well as to successors and assigns of relevant affiliates, with respect to all conduct subject to the provisions above and all future obligations, responsibilities, undertakings, commitments, limitations, restrictions, events, and conditions. 27. This Order and any dispute related thereto shall be construed and enforced in accordance with, and governed by, the laws of Maine without regard to any choice of law principles.</p> Last Updated: March 23, 2026 11:44 AM Consumer Tools File a complaint Investor education Web resources Industry Tools Licensing & Registration Forms NASD Regulation File UICNF Laws, rules, & advisory rulings Small business help Enforcement actions & consent agreements Featured "Business Opportunity" Sales New Data Breach Notification Law Maine.gov | Professional and Financial Regulation | Privacy | Accessibility | Disclaimer Copyright © 2006 All rights reserved.

Stifel, Nicolaus & Company, Inc., Respondent Case No. 25-20765 Consent Order : Office of Securities

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