Gemini Fund Services TA-1/A Registration as a transfer agent (amended)

Form TA-1 Filer Information	UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 FORM TA-1/A	OMB APPROVAL
FORM TA-1/A		OMB Number: 3235-0084 Estimated average burden hours per response: 1.5

TA-1/A : Filer Information

Form Version X0405

1(a). Filer CIK:	0001253179
1(b). Filer CCC:	********
1(c). Is this a LIVE or TEST submission?	Live Test
1(d). Would you like a Return Copy?	Yes

Submission Contact Information

The registrant may provide a single e-mail address for contact purposes.

1(f)(i). Contact Name:

1(f)(ii). Contact Phone Number:

1(f)(iii). Contact E-Mail Address:

Notification Information

The registrant may provide additional e-mail addresses for those persons the filer would like to receive notification e-mails regarding the filing.

1(g). Notification E-mail Address:

TA-1/A : Registrant Information

2. Appropriate regulatory agency (check one): Securities and Exchange Commission Federal Deposit Insurance Corporation Comptroller of the Currency

3(a). Full Name of Registrant:	GEMINI FUND SERVICES, LLC
3(a)(i). Previous name, if being amended:	GEMINI FUND SERVICES LLC
3(b). Financial Industry Number (FINS) number:	277186

3(c). Address of principal office where transfer agent activities are, or will be, performed:

3(c)(i). Address 1	4221 N. 203rd Street
3(c)(ii). Address 2	Suite 100
3(c)(iii). City	Elkhorn
3(c)(iv). State or Country	NEBRASKA
3(c)(v). Postal Code	68022
3(d). Is Mailing address different from response to Question 3c? If "yes" provide address(es):	Yes No
3(e). Telephone Number (Include Area Code)	402-522-6318
4. Does Registrant conduct, or will it conduct, transfer agent activities at any location other than that given in Questions 3(c) above? If "Yes" provide address (es):	Yes No
Other Business Location Record: 1
4(a)(i). Address 1	80 Arkay Drive
4(a)(ii). Address 2	Suite 110
4(a)(iii). City	Hauppauge
4(a)(iv). State or Country	NEW YORK
4(a)(v). Postal Code	11788
Other Business Location Record: 2
4(a)(i). Address 1	225 Pictoria Drive
4(a)(ii). Address 2	Suite 450
4(a)(iii). City	Cincinnati
4(a)(iv). State or Country	OHIO
4(a)(v). Postal Code	45246
5. Does registrant act, or will it act, as a transfer agent solely for its own securities, and/or securities of an affiliate(s)?	Yes No
6. Has registrant, as a named transfer agent, engaged, or will it engage, a service company to perform any transfer agent functions?	Yes No

If "yes," provide the name(s) and address(es) of all service companies engaged, or that will be engaged, by the registrant to perform its transfer agent functions: Engaged sevice company information Related to item 6 Record: 1

6(a). Name	Rydex Fund Services, LLC
6(b). File Number	084-05475
6(c)(i). Address 1	805 King Farm Blvd.
6(c)(ii). Address 2	Suite 600
6(c)(iii). City	Rockville
6(c)(iv). State or Country	MARYLAND
6(c)(v). Postal Code	20850

7. Has registrant been engaged, or will it be engaged as a service company by a named transfer agent to perform transfer agent functions? Yes No

TA-1/A : Independent, Non-Issuer Registrant Information

Completion of Question 8 on this form is required by all independent, non-issuer registrants whose appropriate regulatory authority is the Securities and Exchange Commission. Those registrants who are not required to complete Question 8 should select "Not Applicable".

8. Is registrant a: Other Limited Liability Company

Section for Initial Registration and for Amendments Reporting Additional Persons.

Proprietor or other entity information Related to item 8 Record: 1

8(a)(i). Full Name	Kara Brianna Baird
8(a)(ii). Relationship Start Date	05/01/2012
8(a)(iii). Title or Status	Senior Vice President
8(a)(iv). Description of Authority	daily management of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 2

8(a)(i). Full Name	Kevin Eric Wolf
8(a)(ii). Relationship Start Date	05/01/2012
8(a)(iii). Title or Status	Executive Vice President
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 3

8(a)(i). Full Name	Kristin Sara McCann
8(a)(ii). Relationship Start Date	06/01/2012
8(a)(iii). Title or Status	Chief Compliance Officer
8(a)(iv). Description of Authority	compliance oversight of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 4

8(a)(i). Full Name	William John Strait
8(a)(ii). Relationship Start Date	10/08/2012
8(a)(iii). Title or Status	General Counsel/Secretary
8(a)(iv). Description of Authority	legal/management oversight of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 5

8(a)(i). Full Name	Mark Daniel Applegarth
8(a)(ii). Relationship Start Date	10/24/2006
8(a)(iii). Title or Status	Treasurer/Manager
8(a)(iv). Description of Authority	financial/management oversight
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 6

8(a)(i). Full Name	NorthStar Financial Services Group, LLC (NFSG)
8(a)(ii). Relationship Start Date	04/10/2003
8(a)(iii). Title or Status	Holding company of registrant
8(a)(iv). Description of Authority	Sole member of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 7

8(a)(i). Full Name	NorthStar Topco, LLC (Topco)
8(a)(ii). Relationship Start Date	04/30/2015
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	sole member of NFSG
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 8

8(a)(i). Full Name	TA XI NS AIV, L.P.
8(a)(ii). Relationship Start Date	04/30/2015
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	majority owner of Topco
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 9

8(a)(i). Full Name	TA Associates XI GP, L.P. (TA XI GP)
8(a)(ii). Relationship Start Date	04/30/2015
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	general partner of TA XI NS AIV, L.P.
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 10

8(a)(i). Full Name	TA Associates, L.P.
8(a)(ii). Relationship Start Date	04/30/2015
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	general partner of TA XI GP
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 11

8(a)(i). Full Name	Kevin James Hesselbirg
8(a)(ii). Relationship Start Date	04/10/2017
8(a)(iii). Title or Status	Chief Executive Officer/Manager
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 12

8(a)(i). Full Name	William Sayler Wostoupal
8(a)(ii). Relationship Start Date	03/01/2018
8(a)(iii). Title or Status	Manager
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 13

8(a)(i). Full Name	Julie Ann Lane
8(a)(ii). Relationship Start Date	03/01/2018
8(a)(iii). Title or Status	Manager
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 14

8(a)(i). Full Name	David James Young
8(a)(ii). Relationship Start Date	03/01/2018
8(a)(iii). Title or Status	Manager
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 15

8(a)(i). Full Name	Michael Joseph Wagner
8(a)(ii). Relationship Start Date	04/01/2018
8(a)(iii). Title or Status	Manager
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date	02/01/2019

Proprietor or other entity information Related to item 8 Record: 16

8(a)(i). Full Name	Gary Richard Tenkman
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	Chief Executive Officer
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 17

8(a)(i). Full Name	William Jacob Tomko
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	Executive Vice President
8(a)(iv). Description of Authority	directs affairs of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 18

8(a)(i). Full Name	David Kenneth James
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	Chief Risk Officer
8(a)(iv). Description of Authority	risk oversight of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 19

8(a)(i). Full Name	Kurt Bruno Krebs
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	Chief Financial Officer
8(a)(iv). Description of Authority	financial/management oversight
8(a)(v). Relationship End Date	10/18/2019

Proprietor or other entity information Related to item 8 Record: 20

8(a)(i). Full Name	The Ultimus Group Midco, LLC (Midco)
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	holding company of registrant
8(a)(iv). Description of Authority	sole member of registrant
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 21

8(a)(i). Full Name	The Ultimus Group Intermediate, LLC (Intermediate)
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	sole member of Midco
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 22

8(a)(i). Full Name	The Ultimus Group, LLC (UG)
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	sole member of Intermediate
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 23

8(a)(i). Full Name	GTCR Fund XII/B LP (Fund)
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	majority owner of UG
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 24

8(a)(i). Full Name	GTCR Partners XII/B LP (Partners)
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	general partner of Fund
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 25

8(a)(i). Full Name	GTCR Investment XII LLC
8(a)(ii). Relationship Start Date	02/01/2019
8(a)(iii). Title or Status	indirect owner
8(a)(iv). Description of Authority	general partner of Partners
8(a)(v). Relationship End Date

Proprietor or other entity information Related to item 8 Record: 26

8(a)(i). Full Name	Ian Andrew Martin
8(a)(ii). Relationship Start Date	03/01/2020
8(a)(iii). Title or Status	Chief Administrative Officer
8(a)(iv). Description of Authority	direct affairs of registrant
8(a)(v). Relationship End Date

9. Does any person or entity not named in the answer to Question 8:

9(a). directly or indirectly, through agreement or otherwise exercise or have the power to exercise control over the management or policies of applicant, or;…. Yes No

9(b). wholly or partially finance the business of the applicant, directly or indirectly, in any manner other than by a public offering of securities made pursuant to the Securities Act of 1933 or by credit extended in the ordinary course of business by suppliers, banks and others?….. Yes No

TA-1/A : 10. Applicant and Control Affiliate Disciplinary History

The following definitions apply for purposes of answering this Question 10

Control Affiliate	- An individual or firm that directly or indirectly controls, is under common control with, or is controlled by applicant. Included are any employees identified in 8(a), 8(b), 8(c) of this form as exercising control. Excluded are any employees who perform solely clerical, administrative support of similar functions, or who, regardless of title, perform no executive duties or have no senior policy making authority.
Investment or investment related	- Pertaining to securities, commodities, banking, insurance, or real estate (including, but not limited to, acting as or being associated with a broker dealer, investment company, investment adviser, futures sponsor, bank, or savings and loan association).
Involved	- Doing an act of aiding, abetting, counseling, commanding, inducing, conspiring with or failing reasonably to supervise another in doing an act.

10(a). In the past ten years has the applicant or a control affiliate been convicted of or plead guilty or nolo contendere ("no contest") to:

10(a)(1). a felony or misdemeanor involving: investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, or bribery, forgery, counterfeiting, or extortion? Yes No

10(a)(2). any other felony? Yes No

10(b). Has any court in the past ten years:
10(b)(1). enjoined the applicant or a control affiliate in connection with any investment-related activity?	Yes No

10(b)(2). found that the applicant or control affiliate was involved in a violation of investment-related statutes or regulations? Yes No

10 (c). Has the U.S. Securities and Exchange Commission or the Commodity Futures Trading Commission ever:
10(c)(1). found the applicant or control affiliate to have made a false statement or omission?	Yes No

Entity information Related to item 10(c)(1) Record: 1

10(c)(1)(i). The individuals named in the Action	Gemini Fund Services, LLC (the registrant)
10(c)(1)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(1)(iii). Date of Action	05/02/2013
10(c)(1)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(1)(v). Description of the Action	In connection with a notice served on two series trusts serviced by registrant as fund administrator, the SEC alleged that, during the period January 2009 through December 2010, the registrant caused the trusts to violate certain federal securities laws. The SEC alleged that the registrant, in its capacity as fund administrator to certain series formed under the trusts, failed to ensure that certain shareholder reports contained adequate disclosure of the process by which the trustees evaluated the terms of certain advisory contracts entered into by the trusts and, in doing so, violated Section 30(e) of the Investment Company Act of 1940 and Rule 30(e)(1) promulgated thereunder. The SEC also alleged that the registrant failed to ensure that certain series of the trusts maintained and preserved copies of written materials that the trustees considered in reviewing and approving certain advisory contracts in violation of Section 31(a) of the Investment Company Act of 1940 and Rule 31a-2(a)(6) promulgated thereunder.
10(c)(1)(vi). The disposition of the proceeding	In settlement, registrant agreed to cease and desist from committing or causing any future violations, pay a $50,000 fine, and hire an independent consultant to review the compliance program relating to the trusts.

Entity information Related to item 10(c)(1) Record: 2

10(c)(1)(i). The individuals named in the Action	Michael Miola
10(c)(1)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(1)(iii). Date of Action	05/02/2013
10(c)(1)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(1)(v). Description of the Action	Mr. Miola was a control affiliate with respect to the registrant. In a notice served on two series trusts for which Mr. Miola served as chairman of the Board of Trustees, the SEC alleged that, during the period January 2009 through December 2010, the trustees of the trusts, including Mr. Miola, caused the trusts to violate certain federal securities laws. The SEC alleged that, on certain occasions during the relevant period, disclosures included in shareholder reports concerning the trustees' evaluation process with respect to certain advisory contracts entered into by certain series of the trusts contained boilerplate disclosures that were materially untrue or misleading in violation of Section 34(b) of the Investment Company Act of 1940. Because such disclosures were made based on board minutes reviewed and approved by the trustees, the SEC deemed the violations to have been caused by the trustees. Also during the relevant period, the SEC deemed that the trustees were a cause of certain series' violations of Rule 38a-1(a)(1) under the Investment Company Act of 1940, which requires registered investment companies to adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws. Specifically, the trustees failed to implement those series' policies and procedures to the extent they required the series' chief compliance officer to provide the adviser's compliance manuals to the trustees for their review, or as an alternative, summaries of the compliance programs upon which the trustees could rely in approving the compliance manuals of the series' new advisers.
10(c)(1)(vi). The disposition of the proceeding	Mr. Miola agreed to cease and desist from committing any future violations and hire an independent compliance consultant to review the compliance program relating to the trusts.

Entity information Related to item 10(c)(1) Record: 3

10(c)(1)(i). The individuals named in the Action	Unified Fund Services, Inc. (now know as Ultimus Asset Services, LLC) and Michael E. Durham
10(c)(1)(ii). Title of Action	In the Matter of Unified Fund Services, Inc. and Michael E. Durham
10(c)(1)(iii). Date of Action	05/05/2006
10(c)(1)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(1)(v). Description of the Action	The Commission found that Unified violated or caused to be violated various federal securities laws related to certain fund administration and accounting activities that occurred from 1999 through 2002.
10(c)(1)(vi). The disposition of the proceeding	Cease and Desist Order

10(c)(2). found the applicant or control affiliate to have been involved in a violation of its regulation or statutes? Yes No

Entity information Related to item 10(c)(2) Record: 1

10(c)(2)(i). The individuals named in the Action	Gemini Fund Services, LLC (the registrant)
10(c)(2)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(2)(iii). Date of Action	05/02/2013
10(c)(2)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(2)(v). Description of the Action	In connection with a notice served on two series trusts serviced by registrant as fund administrator, the SEC alleged that, during the period January 2009 through December 2010, the registrant caused the trusts to violate certain federal securities laws. The SEC alleged that the registrant, in its capacity as fund administrator to certain series formed under the trusts, failed to ensure that certain shareholder reports contained adequate disclosure of the process by which the trustees evaluated the terms of certain advisory contracts entered into by the trusts and, in doing so, violated Section 30(e) of the Investment Company Act of 1940 and Rule 30(e)(1) promulgated thereunder. The SEC also alleged that the registrant failed to ensure that certain series of the trusts maintained and preserved copies of written materials that the trustees considered in reviewing and approving certain advisory contracts in violation of Section 31(a) of the Investment Company Act of 1940 and Rule 31a-2(a)(6) promulgated thereunder.
10(c)(2)(vi). The disposition of the proceeding	In settlement, registrant agreed to cease and desist from committing or causing any future violations, pay a $50,000 fine, and hire an independent consultant to review the compliance program relating to the trusts.

Entity information Related to item 10(c)(2) Record: 2

10(c)(2)(i). The individuals named in the Action	Northern Lights Compliance Services, LLC
10(c)(2)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(2)(iii). Date of Action	05/02/2013
10(c)(2)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(2)(v). Description of the Action	In connection with a notice served on two series trusts serviced by registrant as fund administrator, the SEC alleged that, during the period January 2009 through December 2010, Northern Lights Compliance Services, LLC (NLCS), an affiliate under common control with the registrant, caused the trusts to violate certain federal securities laws. The SEC alleged that NLCS, in its capacity as chief compliance officer to certain series formed under the trusts, together with the trustees, failed to ensure that certain series of the trusts implemented their policies and procedures concerning the items upon which the trustees could rely when the trustees approved certain investment advisor compliance programs based on NLCS's report that such advisers' compliance manuals were "sufficient" and "in use" and that their code of ethics and proxy voting policies were "compliant." The SEC deemed that such failure constituted a violation of Rule 38a-1(a)(1) promulgated under the Investment Company Act of 1940.
10(c)(2)(vi). The disposition of the proceeding	In settlement, NLCS agreed to cease and desist from committing or causing any future violations, pay a $50,000 fine, and hire an independent consultant to review the compliance program relating to the trusts.

Entity information Related to item 10(c)(2) Record: 3

10(c)(2)(i). The individuals named in the Action	Michael Miola
10(c)(2)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(2)(iii). Date of Action	05/02/2013
10(c)(2)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(2)(v). Description of the Action	Mr. Miola was a control affiliate with respect to the registrant. In a notice served on two series trusts for which Mr. Miola served as chairman of the Board of Trustees, the SEC alleged that, during the period January 2009 through December 2010, the trustees of the trusts, including Mr. Miola, caused the trusts to violate certain federal securities laws. The SEC alleged that, on certain occasions during the relevant period, disclosures included in shareholder reports concerning the trustees' evaluation process with respect to certain advisory contracts entered into by certain series of the trusts contained boilerplate disclosures that were materially untrue or misleading in violation of Section 34(b) of the Investment Company Act of 1940. Because such disclosures were made based on board minutes reviewed and approved by the trustees, the SEC deemed the violations to have been caused by the trustees. Also during the relevant period, the SEC deemed that the trustees were a cause of certain series' violations of Rule 38a-1(a)(1) under the Investment Company Act of 1940, which requires registered investment companies to adopt and implement written policies and procedures reasonably designed to prevent violation of the federal securities laws. Specifically, the trustees failed to implement those series' policies and procedures to the extent they required the series' chief compliance officer to provide the adviser's compliance manuals to the trustees for their review, or as an alternative, summaries of the compliance programs upon which the trustees could rely in approving the compliance manuals of the series' new advisers.
10(c)(2)(vi). The disposition of the proceeding	Mr. Miola agreed to cease and desist from committing any future violations and hire an independent compliance consultant to review the compliance program relating to the trusts.

Entity information Related to item 10(c)(2) Record: 4

10(c)(2)(i). The individuals named in the Action	Gemini Fund Services, LLC (the registrant)
10(c)(2)(ii). Title of Action	Order Instituting Cease and Desist Proceedings
10(c)(2)(iii). Date of Action	01/22/2018
10(c)(2)(iv). The Court or body taking the Action and its location	United States Securities and Exchange Commission
10(c)(2)(v). Description of the Action	The registrant served as the administrator for GL Beyond Income Fund, a closed-end interval fund (the "Fund"), during the period from January 2012 until March 2015 and was responsible for calculating and reporting the daily net asset value ("NAV") for the Fund. The SEC alleged that during the period from February 2013 to December 2014, the NAV that the registrant reported was inflated because it included certain fraudulent assets. The SEC acknowledged that the registrant did not know that these assets were fraudulent, but alleged that: (i) the registrant did know that the Fund's custodian bank did not have adequate proof of the existence of many of these fraudulent assets, (ii) there were discrepancies between the registrant's records and those of the custodian bank, and (iii) the registrant failed to notify the investing public or the Fund's board of trustees of such discrepancies.
10(c)(2)(vi). The disposition of the proceeding	In settlement, registrant agreed to cease and desist from committing or causing any future violations; pay a civil monetary penalty, disgorge a portion of its revenue, and hire an independent compliance consultant.

Entity information Related to item 10(c)(2) Record: 5

10(c)(2)(i). The individuals named in the Action	Unified Fund Services, Inc. (now known as Ultimus Asset Services, LLC) and Michael E. Durham
10(c)(2)(ii). Title of Action	In the Matter of Unified Fund Services, Inc. and Michael E. Durham
10(c)(2)(iii). Date of Action	05/05/2006
10(c)(2)(iv). The Court or body taking the Action and its location	U.S. Securities and Exchange Commission
10(c)(2)(v). Description of the Action	The Commission found that Unified violated or caused to be violated various federal securities laws related to certain fund administration and accounting activities that occurred from 1999 through 2002.
10(c)(2)(vi). The disposition of the proceeding	Cease and Desist Order

10(c)(3). found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked or restricted? Yes No

10(c)(4). entered an order denying, suspending or revoking the applicant’s or control affiliate’s registration or otherwise disciplined it by restricting its activities? Yes No

10(d). Has any other Federal regulatory agency or any state regulatory agency :
10(d)(1). ever found the applicant or control affiliate to have made a false statement or omission or to have been dishonest, unfair, or unethical?	Yes No

10(d)(2). ever found the applicant or control affiliate to have been involved in a violation of investment-related regulations or statutes? Yes No

Entity information Related to item 10(d)(2) Record: 1

10(d)(2)(i). The individuals named in the Action	Unified Financial Securities, LLC
10(d)(2)(ii). Title of Action	C93-03-409
10(d)(2)(iii). Date of Action	05/05/1989
10(d)(2)(iv). The Court or body taking the Action and its location	Iowa Securities Bureau
10(d)(2)(v). Description of the Action	Filed audited financials late.
10(d)(2)(vi). The disposition of the proceeding	$500 civil penalty.

10(d)(3). ever found the applicant or control affiliate to have been a cause of an investment-related business having its authorization to do business Denied, suspended, revoked or restricted? Yes No

Entity information Related to item 10(d)(3) Record: 1

10(d)(3)(i). The individuals named in the Action	Northern Lights Distributors, LLC
10(d)(3)(ii). Title of Action	R-2004-0004
10(d)(3)(iii). Date of Action	01/27/2004
10(d)(3)(iv). The Court or body taking the Action and its location	Commonwealth of Massachusetts-Secretary of the Commonwealth, Securities Division
10(d)(3)(v). Description of the Action	Northern Lights Distributors, LLC (NLD), an affiliate under common control with the registrant, consented to the following with respect to Michael Miola in connection with the regulatory action taken by the National Association of Securities Dealers, Inc. against Mr. Miola as disclosed under Item 10(e)(2) - Mr. Miola's activities with NLD will be limited to a quarterly review of the performance of the firm and its management, he will not serve as a director, officer, principal, supervisor, or manager of NLD, he will have no power to direct the policies, procedures or operations of NLD, he will have no communications with the public on behalf of NLD, he will not be employed as an agent of NLD in Massachusetts, and he will not transact business in Massachusetts as an agent of NLD.
10(d)(3)(vi). The disposition of the proceeding	Consent

Entity information Related to item 10(d)(3) Record: 2

10(d)(3)(i). The individuals named in the Action	Northern Lights Distributors, LLC (f/k/a Aquarius Fund Distributors, LLC)
10(d)(3)(ii). Title of Action	Registration Agreement Restriction Notice
10(d)(3)(iii). Date of Action	10/27/2003
10(d)(3)(iv). The Court or body taking the Action and its location	State of Florida Office of Financial Regulation
10(d)(3)(v). Description of the Action	In connection with an application to the State of Florida Office of Financial Regulation, Northern Lights Distributors, LLC (NLD), an affiliate under common control with the registrant, consented to the following with respect to Michael Miola in connection with the regulatory action taken by the National Association of Securities Dealers, Inc. (NASD) against Mr. Miola as disclosed under Item 10(e)(2) - NLD agreed that Mr. Miola shall have no power to direct the policies, procedures, or operations of NLD, will not be permitted to serve on the Board of NLD or serve as an officer in any capacity and agreed that Mr. Miola will not act in any principal, supervisory, or managerial capacity of NLD, to offer for sale and sell only those securities that are exempt from the provision of Rule 3E-600.012(5), Florida Administrative Code, that its chief compliance officer will be actively involved in the maintenance of the firm's compliance with the rules and regulations of the states in which the firm is registered, the NASD, the SEC, to not engage in any prohibited business practice as that term is defined in Rule 3E-600.013, Florida Administrative Code, to immediately report specified complaints, and to comply with all state and federal securities laws.
10(d)(3)(vi). The disposition of the proceeding	Consent

10(d)(4). in the past ten years entered an order against the applicant or control affiliate in connection with investment-related activity? Yes No

10(d)(5). ever denied, suspended, or revoked applicant’s or control affiliate’s registration or license, or prevented it from associating with an investment-related business, or otherwise disciplined it by restricting its activities? Yes No

Entity information Related to item 10(d)(5) Record: 1

10(d)(5)(i). The individuals named in the Action	Northern Lights Distributors, LLC
10(d)(5)(ii). Title of Action	R-2004-0004
10(d)(5)(iii). Date of Action	01/27/2004
10(d)(5)(iv). The Court or body taking the Action and its location	Commonwealth of Massachusetts-Secretary of the Commonwealth, Securities Division
10(d)(5)(v). Description of the Action	Northern Lights Distributors, LLC (NLD), an affiliate under common control with the registrant, consented to the following with respect to Michael Miola in connection with the regulatory action taken by the National Association of Securities Dealers, Inc. against Mr. Miola as disclosed under Item 10(e)(2) - Mr. Miola's activities with NLD will be limited to a quarterly review of the performance of the firm and its management, he will not serve as a director, officer, principal, supervisor, or manager of NLD, he will have no power to direct the policies, procedures or operations of NLD, he will have no communications with the public on behalf of NLD, he will not be employed as an agent of NLD in Massachusetts, and he will not transact business in Massachusetts as an agent of NLD.
10(d)(5)(vi). The disposition of the proceeding	Consent

Entity information Related to item 10(d)(5) Record: 2

10(d)(5)(i). The individuals named in the Action	Northern Lights Distributors, LLC (f/k/a Aquarius Fund Distributors, LLC)
10(d)(5)(ii). Title of Action	Registration Agreement Restriction Notice
10(d)(5)(iii). Date of Action	10/27/2003
10(d)(5)(iv). The Court or body taking the Action and its location	State of Florida Office of Financial Regulations
10(d)(5)(v). Description of the Action	In connection with an application to the State of Florida Office of Financial Regulation, Northern Lights Distributors, LLC (NLD), an affiliate under common control with the registrant, consented to the following with respect to Michael Miola in connection with the regulatory action taken by the National Association of Securities Dealers, Inc. (NASD) against Mr. Miola as disclosed under Item 10(e)(2) - NLD agreed that Mr. Miola shall have no power to direct the policies, procedures, or operations of NLD, will not be permitted to serve on the Board of NLD or serve as an officer in any capacity and agreed that Mr. Miola will not act in any principal, supervisory, or managerial capacity of NLD, to offer for sale and sell only those securities that are exempt from the provision of Rule 3E-600.012(5), Florida Administrative Code, that its chief compliance officer will be actively involved in the maintenance of the firm's compliance with the rules and regulations of the states in which the firm is registered, the NASD, the SEC, to not engage in any prohibited business practice as that term is defined in Rule 3E-600.013, Florida Administrative Code, to immediately report specified complaints, and to comply with all state and federal securities laws.
10(d)(5)(vi). The disposition of the proceeding	Consent

10(d)(6). ever revoked or suspended the applicant’s or a control affiliate’s license as an attorney or accountant? Yes No

10(e). Has any self-regulatory organization or commodities exchange ever:

10(e)(1). found the applicant or a control affiliate to have made a false statement or omission? Yes No

10(e)(2). found the applicant or a control affiliate to have been involved in a violation of its rules? Yes No

Entity information Related to item 10(e)(2) Record: 1

10(e)(2)(i). The individuals named in the Action	Michael Miola
10(e)(2)(ii). Title of Action	Letter of Acceptance Waiver and Consent
10(e)(2)(iii). Date of Action	01/23/2002
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers, Inc.
10(e)(2)(v). Description of the Action	While associated with an unaffiliated entity, a regulatory action was initiated on January 23, 2002 by the National Association of Securities Dealers, Inc. (NASD) against Michael Miola primarily involving the misdirected review and approval of advertising materials. Mr. Miola was fined $25,000, which included disgorgement of $4,565.43, and was suspended from association with any NASD member in any capacity for 30 days. The fine was due and payable prior to the earlier of reassociation with any NASD member following the suspension or any request for relief from any statutory disqualification. The suspension was effective March 4, 2002 through the close of business on April 2, 2002. Mr. Miola received a letter from the NASD dated August 7, 2003 that stated that the fine had been paid in full and his obligation to the NASD was fulfilled.
10(e)(2)(vi). The disposition of the proceeding	$25,000 fine and 30 day NASD suspension

Entity information Related to item 10(e)(2) Record: 2

10(e)(2)(i). The individuals named in the Action	Unified Underwriters, Inc. (now known as Unified Financial Securities, LLC)
10(e)(2)(ii). Title of Action	N/A
10(e)(2)(iii). Date of Action	03/16/1971
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers, Inc.
10(e)(2)(v). Description of the Action	Alleged certain violations of the Rules of Fair Practice with respect to the purchase of new issues and free riding.
10(e)(2)(vi). The disposition of the proceeding	Fine of $12,000.

Entity information Related to item 10(e)(2) Record: 3

10(e)(2)(i). The individuals named in the Action	Unified Financial Securities, LLC
10(e)(2)(ii). Title of Action	C8A910016
10(e)(2)(iii). Date of Action	05/20/1991
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers, Inc.
10(e)(2)(v). Description of the Action	Alleged that Unified violated certain provisions of the Rules of Fair Practice in that it failed to accurately compute its special reserve bank account, failed to reflect on its securities ledger three stock positions, and failed to accurately compute net capital.
10(e)(2)(vi). The disposition of the proceeding	Censured and fined $5,000.

Entity information Related to item 10(e)(2) Record: 4

10(e)(2)(i). The individuals named in the Action	Unified Financial Securities, LLC
10(e)(2)(ii). Title of Action	C8A900012
10(e)(2)(iii). Date of Action	11/07/1990
10(e)(2)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers, Inc.
10(e)(2)(v). Description of the Action	Alleged that Unified, acting through Markell Kaiser, violated certain provisions of the Rules of Fair Practice with respect to the withdrawal of funds from its reserve account without adequate support, a reserve account deficiency, and the filing of an inaccurate Focus Report, Part I.
10(e)(2)(vi). The disposition of the proceeding	Censured and fined $4,000.

10(e)(3). found the applicant or a control affiliate to have been the cause of an investment-related business losing its authorization to do business? Yes No

10(e)(4). disciplined the applicant or a control affiliate by expelling or suspending it from membership, by barring or suspending its association with other members, or by otherwise restricting its activities? Yes No

Entity information Related to item 10(e)(4) Record: 1

10(e)(4)(i). The individuals named in the Action	Michael Miola
10(e)(4)(ii). Title of Action	Letter of Acceptance Waiver and Consent
10(e)(4)(iii). Date of Action	01/23/2002
10(e)(4)(iv). The Court or body taking the Action and its location	National Association of Securities Dealers, Inc.
10(e)(4)(v). Description of the Action	While associated with an unaffiliated entity, a regulatory action was initiated on January 23, 2002 by the National Association of Securities Dealers, Inc. (NASD) against Michael Miola primarily involving the misdirected review and approval of advertising materials. Mr. Miola was fined $25,000, which included disgorgement of $4,565.43, and was suspended from association with any NASD member in any capacity for 30 days. The fine was due and payable prior to the earlier of reassociation with any NASD member following the suspension or any request for relief from any statutory disqualification. The suspension was effective March 4, 2002 through the close of business on April 2, 2002. Mr. Miola received a letter from the NASD dated August 7, 2003 that stated that the fine had been paid in full and his obligation to the NASD was fulfilled.
10(e)(4)(vi). The disposition of the proceeding	$25,000 fine and 30 day NASD suspension

10(f). Has any foreign government, court, regulatory agency or exchange ever entered an order against the applicant or a control affiliate related to investments or fraud? Yes No

10(g). Is the applicant or a control affiliate now the subject of a proceeding that could result in a yes answer for questions 10(a) – 10(f) ? Yes No

10(h). Has a bonding company denied, paid out on, or revoked a bond for the applicant or a control affiliate? Yes No

10(i). Does the applicant or a control affiliate have any unsatisfied judgments or liens against it? Yes No

TA-1/A : Signature

ATTENTION: INTENTIONAL MISSTATEMENTS OR OMISSIONS OF FACT CONSTITUTE FEDERAL CRIMINAL VIOLATIONS. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a) SIGNATURE: The registrant submitting this form, and as required, the SEC supplement and Schedules A-D, And the executing official hereby represent that all the information contained herein is true, correct and complete.

11(a). Signature of Official responsible for Form:	/s/ Ian A. Martin
11(b). Telephone Number:	513-869-4299
11(c). Title of Signing Officer:	Chief Administrative Officer
11(d). Date Signed (Month/Day/Year):	03/20/2020