Silverleaf Advisor Group, LLC

Permitted to Resign

Pogreba was permitted to resign and terminate his agreement with Silverleaf while under investigation for failing to comply with Silverleaf compliance policies, the Broker Protocol and potentially Regulation S-P. The investigation arose from Silverleaf becoming aware prior to termination of (1) his solicitation of clients seeking their agreement to move their investment advisory agreements to another firm to which he also desired to transfer his license before (i) the date of termination and (ii) his IAR license was effectively transferred to and his official association with his new RIA was completed, (2) potentially copying, use and disclosure of nonpublic personal client information via his personal email and or otherwise.

Mr. Pogreba contends that he voluntarily resigned from Silverleaf after which time, the allegations by Silverleaf were made, as stated above. Mr. Pogreba further denies that prior to his resignation he either (1) seek out clients to move to a different firm or (2) copying, use and disclosure of nonpublic personal client information via his personal email and or otherwise.