Consent Agreement and Order: Commonwealth of Pennsylvania v. Gray Investment Management, LLC and Michael K. Gray

COMMONWEAL TH OF PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES COMMONWEAL TH OF PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES, BUREAU OF SECURITIES COMPLIANCE AND EXAMINATIONS v. GRAYINVESTMENTMANAGEMENT,LLC MICHAEL K. GRAY Docket No. : 26 0023 (SEC-CAO) CONSENT AGREEMENT AND ORDER The Commonwealth of Pennsylvania, acting through the Department of Banking and Securities ("Department"), Bureau of Securities Compliance and Examinations ("Bureau"), has conducted an investigation of the business practices of Gray Investment Management, LLC ("GIM") and its officers and employees. Based on the results of its investigation, the Bureau has concluded that GIM has operated in violation of the Pennsylvania Securities Act of 1972, 70 P.S. § 1-101 et seq. ("1972 Act"). GIM, in lieu of litigation, and without admitting or denying the allegations herein, and intending to be legally bound, hereby agrees to the terms of this Consent Agreement and Order ("Order"). BACKGROUND

1. The Department is the Commonwealth of Pennsylvania's administrative agency authorized and empowered to administer and enforce the 1972 Act.
2. The Bureau is primarily responsible for administering and enforcing the 1972 Act for the Department. 1 FILED 2026 JUNE 25 PM 3:07 PA DEPARTMENT OF BANKING AND SECURITIES