Pennsylvania CONTACT: COUNSEL VERONICA HOOF (717)-783-2495

AS OWNER OF PIP, PETER ZEULI ACTED AS AN "AFFILIATE" OF PIP WITHIN THE MEANING OF SECTION 102(B) OF THE PA SECURITIES ACT OF 1972 (1972 ACT) AND, AS SUCH, CAUSED PIP TO VIOLATE THE 1972 ACT. PETER ZEULI AND PIP CONDUCTED BUSINESS AS AN INVESTMENT ADVISER IN WILLFUL VIOLATION OF THE REGISTRATION PROVISIONS OF THE 1972 ACT.

FINAL ORDER

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

$108,000.00

PETER ZEULI AND OTHER NAMED RESPONDENT PAID A $108,000.00 ADMINISTRATIVE ASSESSMENT.

In April of 2022, Peter C. Zeuli, as a respondent for Philadelphia Investment Partners, LLC, was found to be in violation of Section 301(f) and Section 602.1(c) of the P.S of 1972 for failing to notice file and register with the State of Pennsylvania ("the state") once Philadelphia Investment Partners, LLC exceeded the de minis number of clients within the state. It is noted that once Philadelphia Investment Partners, LLC discovered the error, they proactively requested registration, provided requested information to the state and promptly undertook efforts to become properly registered within the state and was successful in those efforts. Philadelphia Investment Partners, LLC was assessed an administrative assessment which the firm promptly paid and sent to the State on June 25, 2022. The firm is awaiting the final acceptance of this process which is targeted for completion on or about August 11, 2022.