STATE OF ILLINOIS, ILLINOIS SECURITIES DEPARTMENT

1. ROBERT C. ACRI (THE "RESPONDENT") IS A REGISTERED INVESTMENT ADVISER REPRESENTATIVE WHO CREATED AND MANAGED THREE UNREGISTERED PRIVATE POOLED INVESTMENT VEHICLES. SINCE THEN, HE HAS FAILED TO ACT AS A FIDUCIARY FAILED TO HAVE REASONABLE AND DOCUMENTED BASES FOR REPRESENTATIONS WHICH FALSELY LULLED INVESTORS, AND FAILED TO ADEQUATELY MAINTAIN BOOKS AND RECORDS. AS A RESULT OF THE REPEATED FAILURES, RESPONDENT HAS DEMONSTRATED AN INABILITY TO PROPERLY CONDUCT BUSINESS. 2. FURTHERMORE, THE SECURITIES AND EXCHANGE COMMISSION (THE "SEC") AND THE FINANCIAL INDUSTRY REGULATORY AUTHORITY ("FINRA") HAVE BARRED RESPONDENT. 3. RESPONDENT'S CONDUCT CONSTITUTES CAUSE TO IMPOSE SANCTIONS PURSUANT TO SECTIONS 8.E(1)(B), (J), (K), (M) AND (Q) OF THE ILLINOIS SECURITIES LAW [815 ILCS 5/1 ET SEQ.] (THE "ACT") AND VIOLATES SECTIONS 12.A, G, H AND J OF THE ACT.

Order

Prohibition

Suspension

ALL CAPACITIES

PERMANENT

UNITED STATES SECURITIES AND EXCHANGE COMMISSION

SEC RELEASES 33-9599, 34-72370; IA RELEASE 40-3854; INVESTMENT COMPANY RELEASE 40-31077, JUNE 11, 2014: THE SEC DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTIONS 4C, 15(B), AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, SECTIONS 203(F) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, SECTION 9(B) OF THE INVESTMENT COMPANY ACT OF 1940, AND RULE 102(E)(1)(III) OF THE COMMISSION'S RULES OF PRACTICE AGAINST ROBERT C. ACRI. IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER HIM AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, ACRI CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT, SECTIONS 4C, 15(B), AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934, SECTIONS 203(F) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, SECTION 9(B) OF THE INVESTMENT COMPANY ACT OF 1940, AND RULE 102(E)(1)(III) OF THE COMMISSION'S RULES OF PRACTICE, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER. THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF FRAUD BY AN INVESTMENT ADVISER IN CONNECTION WITH THE OFFER AND SALE OF PROMISSORY NOTE SECURITIES. ACRI, AS THE CONTROLLING MANAGING MEMBER OF A COMMISSION-REGISTERED INVESTMENT ADVISER, DEFRAUDED INVESTMENT ADVISORY CLIENTS IN THE OFFER AND SALE OF $240,000 IN PROMISSORY NOTE SECURITIES OF A COMPANY. ACRI TOLD CLIENTS THAT THEIR FUNDS WOULD BE USED IN THE DEVELOPMENT OF A RETAIL PARCEL, AND THAT THEIR INVESTMENTS WOULD BE SECURED BY REAL ESTATE. ACRI, HOWEVER, MISAPPROPRIATED $41,250 OF THE TOTAL PROCEEDS, AND THE INVESTMENTS WERE NEVER SECURED. ACRI ALSO FAILED TO DISCLOSE MATERIAL INFORMATION TO ADVISORY CLIENTS CONCERNING A CONFLICT OF INTEREST ARISING FROM HIS MOTIVATION TO ENGAGE IN THE OFFERING TO HELP OTHER INVESTMENT ADVISER CLIENTS RECOVER ON A PRIOR, DELINQUENT $500,000 LOAN; THE DISTRESSED FINANCIAL CONDITION OF THE REAL ESTATE DEVELOPMENT PROJECT OF WHICH THE COMPANY WAS A PART; AND THE FIVE PERCENT COMMISSION THE INVESTMENT ADVISER WOULD RECEIVE ON SALES OF THE SECURITIES, WHICH TOTALED $13,750. BASED ON THESE ACTIONS, ACRI WILLFULLY VIOLATED SECTION 17(A) OF THE SECURITIES ACT, SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, AND SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT.

Order

Bar (Permanent)

ALL CAPACITIES

ACRI IS BARRED FROM ASSOCIATION WITH ANY BROKER, DEALER, OR RELATED ENTITY. ACRI IS BARRED FROM PARTICIPATING IN ANY OFFERING OF A PENNY STOCK. ACRI IS DENIED THE PRIVILEGE OF APPEARING OR PRACTICING BEFORE THE COMMISSION AS AN ATTORNEY.

Cease and Desist

Civil and Administrative Penalty(ies)/Fine(s)

$55,000.00

Disgorgement

$55,000.00

Monetary Penalty other than Fines

$4,478.96

Prohibition

IT IS ORDERED THAT ACRI CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A) OF THE SECURITIES ACT, SECTION 10(B) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER, AND SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT. ACRI IS PROHIBITED FROM SERVING OR ACTING IN ANY CAPACITY WITH AN INVESTMENT COMPANY.

FINRA

WITHOUT ADMITTING OR DENYING THE FINDINGS, ACRI CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT FINRA COMMENCED AN INVESTIGATION CONCERNING ACRI AND HIS INVOLVEMENT IN THE SALE OF ALTERNATIVE INVESTMENTS, INCLUDING PROMISSORY NOTES THAT HAD DEFAULTED. THE FINDINGS STATED THAT AS PART OF THAT INVESTIGATION, FINRA SERVED REQUEST SEEKING INFORMATION AND DOCUMENTS FROM ACRI. ACRI PROVIDED A PARTIAL BUT INCOMPLETE RESPONSE AND, AFTER A DEFICIENCY LETTER WAS SENT TO HIM, HE PROVIDED A SECOND PARTIAL BUT INCOMPLETE RESPONSE. ALTHOUGH ACRI PROVIDED PARTIAL RESPONSES, HE DID NOT SUBSTANTIALLY COMPLY WITH ALL ASPECTS OF THE REQUEST, AND THE INFORMATION AND DOCUMENTS HE FAILED TO PROVIDE WERE MATERIAL TO FINRA'S INVESTIGATION.

Acceptance, Waiver & Consent(AWC)

Bar (Permanent)

All Capacities

3/28/2014

FINRA

RESPONDENT ROBERT CHRISTIAN ACRI FAILED TO RESPOND TO FINRA REQUEST FOR INFORMATION.

LETTER

Suspension

ANY CAPACITY

N/A

2/24/2014

3/31/2014

PURSUANT TO FINRA RULE 9552 AND IN ACCORDANCE WITH FINRA'S NOTICE OF SUSPENSION LETTER DATED JANUARY 30, 2014, ACRI IS SUSPENDED ON FEBRUARY 24, 2014 FROM ASSOCIATING WITH ANY FINRA MEMBER FIRM IN ANY CAPACITY. IF ACRI FAILS TO REQUEST TERMINATION OF THE SUSPENSION WITHIN THREE MONTHS OF THE DATE OF THE NOTICE OF SUSPENSION, HE WILL AUTOMATICALLY BE BARRED MAY 5, 2014 FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY CAPACITY PURSUANT TO FINRA RULE 9552(H). SUSPENSION LIFTED MARCH 31, 2014.