Global Steward Advisors, LLC Consent Agreement and Order

FILED
2026 JUNE 22 AM 11:03
PA DEPARTMENT OF
BANKING AND SECURITIES

# COMMONWEALTH OF PENNSYLVANIA
## DEPARTMENT OF BANKING AND SECURITIES

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**COMMONWEALTH OF PENNSYLVANIA**
**DEPARTMENT OF BANKING AND**
**SECURITIES, BUREAU OF SECURITIES**
**COMPLIANCE AND EXAMINATIONS**
: Docket No. 260021 (SEC-CAO)
v.
**GLOBAL STEWARD ADVISORS, LLC**

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## 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 Global Steward Advisors, LLC and its officers and employees. Based on the results of its investigation, the Bureau has concluded that Global Steward Advisors, LLC has operated in violation of the Pennsylvania Securities Act of 1972, 70 P.S. § 1-101 *et seq.* (“1972 Act”). Global Steward Advisors, LLC, 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. Global Steward Advisors, LLC (“GSA”), CRD # 119898, was, at all material times herein, a Pennsylvania limited liability company with an address of Redacted,

Redacted

4. From on or about October 28, 2012 until the present, GSA was registered pursuant to Section 301(c) of the 1972 Act, 70 P.S. § 1-301(c), as an investment adviser.

5. Regulation 304.012(a)(18), 10 Pa. Code § 304.012(a)(18), requires that every investment adviser registered under the 1972 Act shall make and keep true, accurate and current certain books, ledgers and records, including written information about an investment advisory client that is the basis for making a recommendation or providing investment advice to the client.

6. At all times material herein, GSA failed to establish and maintain written information about at least one investment advisory client that was the basis for making a recommendation or providing investment advice to the client.

## VIOLATION

7. By engaging in the acts and conduct set forth in paragraphs 3 through 6 above, GSA failed to make and keep true, accurate and current all of the following books, ledgers and records, including written information about an investment advisory client that is the basis for making a recommendation or providing investment advice to the client, which acts and conduct form a basis to deny, suspend, revoke, or condition the registration of GSA or censure GSA pursuant to Section 305(a)(v) of the 1972 Act, 70 P.S. § 1-305(a)(v), and Regulation 304.012(a)(18), 10 Pa. Code § 304.012(a)(18).

## RELIEF

8. GSA shall pay the Department an administrative assessment in the amount of $70,000.00. 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 as follows:

a. $2,916.66 on or before July 5, 2026; and
b. $2,916.66 on or before August 5, 2026; and
c. $2,916.66 on or before September 5, 2026; and
d. $2,916.66 on or before October 5, 2026; and
e. $2,916.66 on or before November 5, 2026; and
f. $2,916.66 on or before December 5, 2026; and
g. $2,916.66 on or before January 5, 2027; and
h. $2,916.66 on or before February 5, 2027; and
i. $2,916.66 on or before March 5, 2027; and
j. $2,916.66 on or before April 5, 2027; and
k. $2,916.66 on or before May 5, 2027; and
l. $2,916.66 on or before June 5, 2027; and
m. $2,916.66 on or before July 5, 2027; and
n. $2,916.66 on or before August 5, 2027; and
o. $2,916.66 on or before September 5, 2027; and
p. $2,916.66 on or before October 5, 2027; and
q. $2,916.66 on or before November 5, 2027; and
r. $2,916.66 on or before December 5, 2027; and
s. $2,916.66 on or before January 5, 2028; and
t. $2,916.66 on or before February 5, 2028; and
u. $2,916.66 on or before March 5, 2028; and
v. $2,916.66 on or before April 5, 2028; and
w. $2,916.66 on or before May 5, 2028; and

x. $2,916.82 on or before June 5, 2028; and

9. GSA 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 GSA fail to pay the assessment as set forth in paragraph 8 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 GSA the option of either paying the assessment or being indefinitely subject to the sanctions.

11. Should GSA 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 GSA’s right to a hearing pursuant to the 1972 Act.

## FURTHER PROVISIONS

12. **Consent.** GSA 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. GSA, 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 GSA. 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 GSA.

14. **Binding Nature.** The Department, GSA, and all officers, owners, directors, employees, heirs and assigns of GSA 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. GSA 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 GSA in the future regarding all matters not resolved by this Order.

(b) GSA 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 Global Steward Advisors, 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: 06/22/2026

FOR GLOBAL STEWARD ADVISORS, LLC
Redacted
(Signature)
Date: 6/22/2026