Consent Agreement and Order: Freedom Mountain Investments, LLC

FILED
2026 AUGUST 18 AM 11:10
PA DEPARTMENT OF
BANKING AND SECURITIES

COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF BANKING AND SECURITIES

:
COMMONWEALTH OF PENNSYLVANIA :
DEPARTMENT OF BANKING AND :
SECURITIES, BUREAU OF SECURITIES :
COMPLIANCE AND EXAMINATIONS : Docket No.: 260031 (SEC-CAO) :
v. :
:
FREEDOM MOUNTAIN INVESTMENTS, :
LLC :

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 Freedom Mountain Investments, LLC ("FMI") and its officers and employees. Based on the results of its investigation, the Bureau has concluded that FMI has operated in violation of the Pennsylvania Securities Act of 1972, 70 P.S. § 1-101 et seq. ("1972 Act"). FMI, 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.

3. Respondent Freedom Mountain Investments, LLC ("Respondent FMI"), CRD #
   141745, was, at all material times herein, a Pennsylvania limited liability company with an address at Redacted

4. From on or about January 2007 to the present, Respondent FMI was registered
   pursuant to Section 301(c) of the 1972 Act, 70 P.S. § 1-301(c), as an investment adviser.

5. At all times material herein, Respondent FMI did not have a business continuity
   and succession plan that provided for an assignment of duties to a qualified and responsible person if the death or unavailability of key personnel occurred.

VIOLATION

6. By engaging in the acts and conduct set forth in paragraphs 3 through 5 above,
   Respondent FMI failed to establish, implement, and maintain written procedures relating to a business continuity and succession plan, which acts and conduct form a basis to deny, suspend, revoke, or condition the registration of Respondent FMI or censure Respondent FMI pursuant to
   Section 305(a)(v) of the 1972 Act, 70 P.S. § 1-305(a)(v), and Regulation 304.071(a), 10 Pa. Code
   § 304.071(a).

RELIEF

7. FMI shall pay the Department an administrative assessment in the amount of
   $2,500.00. 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. The assessment shall be paid on or before September 1, 2026.

8. This Order is not intended to indicate that FMI or any of its affiliates or current or
   former employees should be subject to any disqualification contained in the federal securities laws,

the rules and regulations thereunder, the rules and regulations of self-regulatory organizations or various states' securities laws, including the provisions of the 1972 Act and regulations promulgated thereunder; and any disqualification from relying upon the registration exemptions FMI disqualification.

9. FMI is ORDERED to comply with the 1972 Act, and Regulations adopted by the
   Department, and in particular Section 305(a)(v) of the 1972 Act, 70 P.S. § 1-305(a)(v).

10. Should FMI fail to pay the assessment as set forth in paragraph 7 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 FMI the option of either paying the assessment or being indefinitely subject to the sanctions.

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

FURTHER PROVISIONS

12. Consent. FMI 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. FMI, 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.

13. Entire Agreement. This Order contains the entire agreement between the
    Department and FMI. 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 FMI.

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

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

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

17. 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 FMI in the future regarding all matters not resolved by this Order.

(b) FMI acknowledges and agrees that this Order is only binding upon the Department and not any other local, state or federal agency, department, or office regarding matters within this Order.

18. Authorization. The parties below are authorized to execute this Order and legally
    bind their respective parties.

19. Counterparts. This Order may be executed in separate counterparts, by facsimile
    and/or by PDF.

20. Titles. The titles used to identify the paragraphs of this document are for the
    convenience of reference only and do not control the interpretation of this document.

21. Finding. The Department finds that it is necessary and appropriate in the public
    interest and for the protection of investors, and consistent with the purposes fairly intended by the policy and provisions of the 1972 Act to issue this Order.

WHEREFORE, in consideration of the foregoing, including the recital paragraphs, the Commonwealth of Pennsylvania, Department of Banking and Securities, Bureau of Securities Compliance and Examinations and Freedom Mountain Investments, LLC, intending to be legally bound, do hereby execute this Consent Agreement and Order.

FOR THE COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF BANKING AND SECURITIES
BUREAU OF SECURITIES COMPLIANCE AND EXAMINATIONS

Redacted
Eric Pistilli, Deputy Secretary for Securities

Date: 08/18/2026

FOR FREEDOM MOUNTAIN INVESTMENTS, LLC

Redacted
Edward Roche, Owner

Date: August 12, 2026