BACKGROUND RESEARCH INVESTIGATION

ON SUBJECT(S):

Joe T. Sample

FOR CLIENT(S):

Shiny Black Pebble Capital LLC (member SIPC, FINRA, FIIDO)

BY RESEARCH ANALYST(S):

Eric Melin, Bill Popp

RESEARCH SCOPE:

Standard ICBC, 10 year minimum OUR FILE NUMBER:

0001047

January 25, 2020

Dear Sir or Madam,

We have completed our research project on your subject notated above. In order to conduct this research project we first secured a signed release form from the subject so as to provide this information to the listed client for the permissible purposes established. This report is protected by Confidentiality Agreements and may not be further shared or disseminated.

The report is designed to provide our clients with a variety of research and investigative services. Specifically, FINRA Rule 3110 (e) requires that FINRA member firms investigate the good character, business reputation, qualifications and experience of any applicant before the applicant can apply to FINRA via a Form U4.

Similarly, FIIDO (Fair Information Internal Determination Office) via Rule 213.22 requires that all applicants complete a full and complete Comprehensive Background Check. Member firms must have a written process for completing verifications which include a national public records search.

PopuTrust meets these requirements for searching “reasonably available public records” by searching & compiling no fewer than ten (10) public and paid/proprietary databases with our staff of trained Research Analysts. At a minimum our reports will include:

• a) Criminal History Search
• b) Civil History Search
• c) Bankruptcy, Judgments and Liens Search
• d) Education Verification (Diploma Database)
• e) Sex Offender Search
• f) FINRA (Financial Industry Regulatory Authority) “BrokerCheck” Search
• g) FBI (Federal Bureau of Investigation) Search
• h) SDN (Specially Designated Nationals) Search
• i) FSE (Foreign Sanctions Evaders List) Search
• j) OFAC (Office of Foreign Assets Control, i.e. “Terrorists”)
• k) Media Searches (Newspapers, Facebook, Google, Twitter, LinkedIN, etc.)
• l) Employment Verification (at least three outbound phone calls/emails)
• m) Personal Reference Checks (at least three outbound phone calls/emails)

EXECUTIVE SUMMARY:

During our research of Mr. Joseph T. Sample (aka Joe Sample) we secured scans of a Passport, Education Diploma, CFA credential, Driver’s License, and Three Professional References. We did not process fingerprint nor in-depth FBI database search which can take up to two weeks. Two of three reference requests responded positively via email; a third reference was contacted by telephone, responded positively and told to expect an email.

Subject CV noted professional experience working primarily for the same firm, Firm XYZ, which was verified via various 3rdparty data sources and our phone calls. Our research did not uncover any cause for concern, however, due to a lack of information for Molvian nationals and difficulty with non-USA data-sources the overall risk assessment is a 4 of 10 (medium-to-low). Some items are highlighted in the screenshots below.

Subject studied at ITM (Instituto Tecnologico de Molvania) and comes from a wealthy family. The Sample family, used to be in the footwear business, now they are in the oil and gas business. The family company is called JTS industries and they appear to have contracts with the government for public infrastructure. We contacted an Attorney and other resources on the ground in Molvania; and there are no legal processes or law suits against him that we could find. Screenshots from both Molvania and USA public databases are below. Including a "carta de no antecedentes penales" or “non-criminal record certificate” which was secured by our agent physically visiting an official government office in Molvania during business hours on/about July 14 2019.

RISK SUMMARY:

Overall Risk Assessment

RESEARCH SOURCES:

SCREENSHOTS & EXHIBITS:

CV, as provided by Subject, not Verified.

UNITED STATES DOJ: OFAC – “terrorist” database search – no records found

UNITED STATES DOJ: SMART – “sex offender” database search was performed – a Joe Sample was in the database however, his middle name was Earvin and Photo does not match subject provided ID.

NMLS Consumer Access database search – no records found

FINRA “Broker-Check” - never registered – no records found

FINRA “Broker-Check” – COMPLAINT WAS FILED IN 2001

TELEPHONE ASSESSMENT: Subject was called on 1/1/2020 for a review/intake/discussion of the situation/dispute in 2001 – it was determined that FINRA was correct in its decision to deny the Claims of a Complainant.

COURT RECORDS – In our review of Court Records involving the Subject, we found several cases of interest requiring further review.

FOREIGN GOVERNMENT PROVIDED CERTIFICATES:

A "carta de no antecedentes penales" or “non-criminal record certificate” was secured by a PopuTrust agent physically visiting an official government office in Molvanian Capital City:

SUBJECT ULTITY BILL WAS OBTAINED TO VERIFY PROPERTY ADDRESS

PROFESSIONAL CREDENTIALS:

• PROFESSIONAL CREDENTIAL: CFA
• PROFESSIONAL CREDENTIAL: CMPS
• PROFESSIONAL CREDENTIAL: Real Estate
• PROFESSIONAL CREDENTIAL: Securities Course Completed

Three Professional References (as Provided by Subject)

1. John Smith, Doctor, 617-555-1212 - Mr. Smith was called on 7/12/19 – provided a positive reference.
2. Paul Jones, CPA, 617-555-2222- Mr. Jones was called on 7/13/19 – provided a positive reference.
3. Adam Miller, Attorney, 617-555-1111 - Mr. Miller replied by email (see screenshot below)

Three Telephone References (as Determined from Research Sources / Affiliations)

1. Sam Brown, Co-Worker as Determined by CV/Resume; 212-555-3333- Mr. Smith was called on 7/14/19 – provided a positive reference.
2. Susan Black, Neighbor as determined by Address History; 202-555-5555- Ms. Jones was called on 7/13/19 – provided a positive reference.
3. Sage White, College Classmate, as determined by Education Records, 617-555-2222 - Mr. Miller replied by email (see screenshot below).

OPTIONAL TESTING AND ASSESSMENTS:

OPTIONAL PERSONALITY ASSESSMENT – PROVIDED BY MYERS BRIGGS®

OPTIONAL EMOTIONAL INTELLIGENCE ASSESSMENTS:

PopuTrust is not a Private Investigation Service (“PI” Service) should you wish physical assistance of a PI – please contact us for a Referral.