UNITED STATES SECURITIES AND EXCHANGE COMMISSION

Plaintiff United States Securities and Exchange Commission ("SEC" or "Commission"), for its Complaint against defendants Adam Kaplan and Daniel Kaplan (together, "Defendants"), alleges that Defendants are identical twin brothers who engaged in several different fraudulent activities to misappropriate more than $5 million from at least 60 of their investment advisory clients. Defendants were associated as investment adviser representatives with an SEC-registered investment adviser from May 2018 until their termination in July 2021, and after leaving that firm, they continued to act as investment advisers to certain clients. Among other things, from at least May 2018 through July 2021, Defendants overcharged clients for advisory fees by fraudulently inflating the fee amounts in clients' advisory agreements, without the clients' knowledge or consent, so that they could collect higher fees than their clients had agreed to pay. In addition, from at least May 2018 through at least October 2022, Defendants misappropriated clients' funds by fraudulently applying charges to their clients' credit card and bank accounts for, among other things, purported investments or additional advisory fees to which Defendants were not entitled. Defendants used the clients' funds obtained from these fraudulent activities for their personal benefit and to repay certain clients who complained about unusual account activity. Defendants also made misrepresentations, falsified documents, and made Ponzi-like payments to clients to conceal their fraudulent activities. By engaging in the conduct described herein, Defendants violated Section 10(b) of the Securities Exchange Act of 1934 and Rule 10b-5, thereunder and Sections 206(1) and 206(2) of the Investment Advisers Act of 1940.

IHT WEALTH MANAGEMENT LLC

Discharged

[REDACTED] PLACED A FORMAL COMPLAINT WITH THE SEC THAT HIS ADVISER FEES WERE IN THE 2.5-3% RANGE WITH A SIGNED AGREEMENT STATING FEES SHOULD BE 1%

[REDACTED] PLACED A FORMAL COMPLAINT WITH THE SEC THAT HIS ADVISER FEES WERE IN THE 2.5-3% RANGE WITH A SIGNED AGREEMENT STATING FEES SHOULD BE 1%

$4,160.27

Merrill Lynch, Pierce, Fenner & Smith Incorporated

Discharged

Conduct involving utilizing client logon credentials to access client accounts.