FINANCIAL INDUSTRY REGULATORY AUTHORITY LETTER OF ACCEPTANCE, WAIVER, AND CONSENT NO. 2021072094101 TO: Department of Enforcement Financial Industry Regulatory Authority (FINRA) RE: Cambria Capital, LLC (Respondent) Member Firm CRD No. 133760 Pursuant to FINRA Rule 9216, Respondent Cambria Capital, LLC submits this Letter of Acceptance, Waiver, and Consent (AWC) for the purpose of proposing a settlement of the alleged rule violations described below.

FINANCIAL INDUSTRY REGULATORY AUTHORITY OFFICE OF HEARING OFFICERS Department of Enforcement, Complainant, v. Jonathan E. Best CRD No. 2225091, Respondent. Disciplinary Proceeding No. 2020068641501 COMPLAINT The Department of Enforcement alleges: SUMMARY 1. Between December 2017 and December 2019, while he was associated with Raymond James Financial Services, Inc. (CRD No. 6694), Respondent Jonathan E. Best violatedFINRA Rule 2010 by effecting 71 unauthorized trades in the account of a senior customer with diminished capacity (Customer A). 2.