1. Why did I receive this Plan Notice from Richard Keith Robertson & IFP Advisors, LLC?

You received a Plan Notice because your account(s) was impacted as described in the Settlement Order entered by the United Security and Exchange Commission (the “Commission” or “SEC”) and you have been identified as a Preliminary Claimant.

2. How long do I have to send in the IRS Form W-8 or W-9 as required in the Plan Notice communication?

Preliminary Claimants must return a completed Certification Form by the Certification Date, March 17, 2025, to be eligible for a Distribution Payment. The Certification Date is sixty (60) days from the date on the Plan Notice and Certification Form, which is January 17, 2025.

3. What happens if I do not respond with the IRS Form W-8 or W-9 information requested in the Plan Notice?

The enclosed Certification Form sets forth your Recognized Loss, upon which your final Distribution Payment will be calculated. You are required to complete and return the Certification Form not later than March 17, 2025, the Certification Date. If you fail to return the Certification Form by March 17, 2025, you will be deemed an Unresponsive Preliminary Claimant and will not be eligible for a Distribution Payment. NOTE: The Fund Administrator will email or mail a Final Determination Notice to (a) all Preliminary Claimants who timely submitted a Certification Form, notifying the Preliminary Claimants of the Fund Administrator’s eligibility determination, and (b) those Preliminary Claimants who have not responded to the Plan Notice by returning a Certification Form, and/or other requested documentation as described in paragraph 46 of the Plan, notifying the Preliminary Claimant that he, she, or it has been deemed an Unresponsive Preliminary Claimant.

4. What was the settlement about?

On August 10, 2022, the Commission issued the Order instituting and simultaneously settling cease-and-desist proceedings against the Respondent. In the Order, the Commission found that from January 2011 to October 2020, Robertson engaged in a cherry-picking scheme whereby he unfairly allocated purchases of securities between his personal and family accounts and his other IFP clients’ accounts. Robertson disproportionately allocated profitable trades to his personal and family accounts and disproportionately allocated unprofitable trades to his other advisory clients. IFP failed to supervise Robertson, failed to implement policies and procedures reasonably designed to prevent violations of the Advisers Act and its rules by its supervised persons, and made false and misleading statements in its Forms ADV concerning supposed safeguards it had to prevent investment adviser representatives from placing their own interests ahead of those of its advisory clients.

5. What is the relevant period for those impacted by this settlement?

The settlement timeframe (“Relevant Period”) is between January 2011 through October 2020.

6. How much was Richard Keith Robertson & IFP Advisors, LLC ordered to pay in the settlement?

The Commission ordered Robertson to pay disgorgement of $592,437.00, prejudgment interest of $28,173.12, and a civil money penalty of $300,000; and IFP to pay a civil money penalty of $400,000, for a collective total of $1,320,610.12 to the Commission. In each of the Orders, the Commission also created a Fair Fund, pursuant to Section 308(a) of the Sarbanes-Oxley Act of 2002, so the penalties collected, along with the disgorgement and prejudgment interest collected, can be distributed to harmed investors, and further ordered that it may be combined with the monies paid in a parallel proceeding arising out of the same facts that are the basis for the violations in this matter, and that it is expected for the monies collected pursuant to the Orders to be distributed together.

7. Are there tax implications to receiving this payment?

The Commission appointed Heffler, Radetich & Saitta, and LLP as Tax Administrator in this matter. Heffler, Radetich & Saitta, LLP will review the potential tax consequences and a Statement to Eligible Investors (SEI) will be posted to the Tax Information page on this website prior to the disbursement of Fair Fund payments.

8. When will distribution payments be made?

The distribution is anticipated to mail before the end of June/July 2025, estimated. Please check the website www.IFPAdvisorsFairFund.com for updates.

9. Is the Recognized Loss amount seen on my Plan Notice the amount I will be paid?

As calculated using the methodology detailed in the Plan of Allocation (attached as Exhibit A), investors will be compensated for their losses (“Recognized Loss”) between January 2011 through October 2020 (the “Relevant Period”) due to the misconduct of Robertson in allocating trades to client accounts and IFP Advisors’ failure to supervise Robertson and other violations. The Recognized Loss may not be the amount of the Distribution Payment you will receive. Instead, in accordance with the Plan, you may receive a pro rata portion of the Fair Fund. Payees will receive a Distribution Payment equal to his, her, or its distribution amount. In no event will a Payee receive from the Fair Fund more than his, her, or its Recognized Loss, plus Reasonable Interest, if applicable.

10. Can I dispute the Recognized Loss amount?

Disputes will be limited to calculation of Recognized Loss. If a Preliminary Claimant disputes their Recognized Loss, such dispute must be detailed on the Certification Form and returned to the Fund Administrator along with any supporting documentation by the Certification Date, which is March 17, 2025. The Fund Administrator will investigate the dispute, and such investigation will include a review of the written dispute as well as any supporting documentation in consultation with Commission staff in order to make a final determination. Pursuant to the Plan, all determinations made by the Fund Administrator in accordance with the Plan in any dispute will be final and not subject to appeal.