Order Against Keenan, LLC d/b/a Keenan Financial for Unregistered Investment Adviser Activity

FILED 2023 OCT 20 AM 9:32 PA DEPARTMENT OF BANKING AND SECURITIES 230040

3. KF (CRD # 285673) was, at all times material herein, a Massachusetts limited liability company with an address at 11 Beacon Street, 13111 Floor, Boston, MA 02108.

4. From in or about October 2022 until the present, KF transacted business m Pennsylvania as an investment adviser while neither registered nor exempt from registration pursuant to Section 301 of the 1972 Act, 70 P.S. § 1-30 l. VIOLATION

5. By engaging in the acts and conduct set forth in paragraph 4 above, KF transacted business as an investment adviser in Pennsylvania in violation of Section 301(c) of the 1972 Act, 70 P.S. § l-30l(c). RELIEF

6. Within 30 days of the Effective Date of this Order, as defined in paragraph 14, KF shall pay the Department an administrative assessment in the amount of$ 8,500.00. 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 Bureau of Securities Compliance and Examinations located at 17 N. Second Street, Suite 1300, Harrisburg, Pennsylvania 17101.

7. KF is ORDERED to comply with the 1972 Act and Regulations adopted by the Department, and in particular Section 301 ( c) of the 1972 Act, 70 P .S. § 1-301 ( c ).

8. Should KF fail to pay the assessment as set forth in paragraph 6 above, the sanctions set forth elsewhere in the Order shall continue in full force and effect until full payment is made. However, this provision shall not be construed as affording KF the option of either paying the assessment or being indefinitely subject to the sanctions. 2

9. Should KF fail to comply with any and/or all prov1s10ns of this Order, the Department may impose additional sanctions and costs and seek other appropriate relief subject to KF's right to a hearing pursuant to the 1972 Act. FURTHER PROVISIONS

10. Consent. KF hereby knowingly, willingly, voluntarily and irrevocably consents to 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. KF, by voluntarily entering into this Order, waives any right to a hearing or appeal concerning the terms, conditions, and/or penalties set forth in this Order.

11. Entire Agreement. This Order contains the entire agreement between the Department and KF. There are no other terms, obligations, covenants, representations, statements, conditions, or otherwise, of any kind whatsoever concerning this Order. This Order may be amended in writing by mutual agreement by the Department and KF.

12. Binding Nature. The Department, KF, and all officers, owners, directors, employees, heirs and assigns of KF intend to be and are legally bound by the terms of this Order.

13. Counsel. This Order is entered into by the parties upon full opportunity for legal advice from legal counsel.

14. Effectiveness. KF hereby stipulates and agrees that the Order shall become effective on the date the Bureau executes the Order ("Effective Date").

15. Other Enforcement Action. (a) The Department reserves all of its rights, duties, and authority to enforce all statutes, rules, and regulations under its jurisdiction against KF in the future regarding all matters not resolved by this Order. 3

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