STATE OF MINNESOTA Board of Private Detective and Protective Agent Services

Board Member Packet – May 2021

Sequence follows the Synopsis. Numbers correspond to the page numbers listed below:

Pgs. 1-5: Synopsis Pgs. 6-11: Meeting Minutes Pgs. 12-15: PDC 903/PAC 1173 – Letter of Explanation Pgs. 16-17: PDC 903/PAC 1173 – Disciplinary History

SEPARATE ATTACHMENTS PREVIOUSLY PROVIDED. IF ANY BOARD MEMBER DOES NOT HAVE THESE DOCUMENTS, OR NEEDS ANY OTHER RESOURCES PLEASE LET THE AGENCY KNOW:

• MNPDB Letter that Accompanies License Application Packets• MNPDB Letter that Accompanies License Renewal Packets• Tennessen Verbal• Penalty Schedule• Minnesota Statutes• Minnesota Rules• Board Manual• Minnesota Statute Chapter 13D Open Meeting Law

STATE OF MINNESOTA PRIVATE DETECTIVE AND PROTECTIVE AGENT SERVICES BOARD

1430 Maryland Avenue East, St. Paul, Minnesota May 25, 2021 TELECONFERENCE MEETING

SYNOPSIS *Closed Session Required

• Decision in case of application denial – Code 4, LLC 1. REVIEW OF APRIL 2021 MEETING MINUTES

• Backlog currently has 34 outstanding renewals 2. TRAINING CONSENT AGENDA:

TYPE PROVIDER/LICENSE HOLDER AGENCY NOTES New Training Instructor (5) G4S Secure Solutions (USA) Inc. No issues.

New Training Instructor Atlas Defense No issues. Request for CEUs Talon Investigation Ltd. No issues. Request for CEUs Joseph Dolan No issues. Request for CEUs Kyle P. Corrigan No issues.

New Training Course Sentinel Asset Protection No issues. New Training Course PI Education No issues.

3. RENEWAL CONSENT AGENDA:

LICENSE HOLDERS PAC 219 – Granite City Armored Car. Inc. PDC 486/PAC 1175 – Kleinberg Protective Agency, Inc. PAC 2097/PDC 2096 – Tier 1 Security, Inc. PDC 2102 – Advantage Surveillance, LLC PDC 1083 – Fund Holder Reports, LLC PDI 2040 – Paul Johnson ** Indicates license holder provided a renewal with no issues upon original submission. 4. RENEWALS IN NEED OF BOARD REVIEW: PDC 2103 – Delta Associated Investigations, Inc. Original License Date: 5/28/2019 # of Employees: 5

1. QR and MM unable to locate background check records. a. Fingerprints re-submitted to get another check done so the new date is reported for future

reference. 2. No disciplinary history. 3. Renewal is otherwise complete.

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PDC 903/PAC 1173 – American Security, LLC Original License Date: 8/26/2002 & 5/26/2015 # of Employees: 15 & 684

1. 1 employee under PD license with 200+ day gap in preassignment training2. 4 employees under PD license missed 2019 continuing education

a. Took two, six hour courses for 2020 CE year3. 3 employees under PA license with late preassignment training4. Please see letter of explanation for these issues on PAGES 11-14. Labeled Tab 1, 5, and 65. Please see disciplinary history on PAGES 15-166. Let it be noted that the license holder was also operating on stacking continuing education for licensing

requirements, and has since been informed that it is not accepted by Board standards.7. Renewal is otherwise complete

PDI 1086 – Joseph Dolan Original License Date: 5/28/2013 # of Employees: 1

1. License Holder is missing partial payment for renewal feea. Check has been sent, but not received as of 5/20/2021

2. No disciplinary history3. Renewal is otherwise complete

Not Ready for Board Review:

• PAC 1170 – Ahtna Facility Services, Inc.• PAC 1169 – Cero’s LLC• PAI 2099 – Cori Winkleman• PAC 2104 – All Star Security Services, Inc.

5. CURRENT CONTINGENCIES:

MAY CONTINGENCIES – STATUS WOULD END IN JUNE

Not Ready for Board Review:

• PDC 746/PAC1174 – Talon Investigation Ltd.• PDI 414 – William J. O’Keefe• PDC 2038 – Guardian Investigations, Inc.• PDI 2101 – Steven Broom

MARCH CONTINGENCIES – STATUS WOULD END IN MAY

Not Ready for Board Review:

• PAC 2037 – Ehni Enterprises, LLC

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FEBRUARY CONTINGENCIES – STATUS WOULD END IN APRIL Not Ready for Board Review:

• PDC 620 – Active Research Investigations, Inc. • PDI 2092 – Michaela Knower • PDI 861 – Peter J. Legus

JANUARY CONTINGINCIES – STATUS WOULD END IN MARCH Not Ready for Board Review:

• PAC 305 – Shield Services, LLC • PDI 2087 – Bashir Abdi

DECEMBER CONTINGENCIES – STATUS WOULD END IN FEBRUARY Not Ready for Board Review:

• PAC 261 – Lakeside Protection, Inc. OCTOBER CONTINGENCIES – STATUS WOULD END IN DECEMBER Not Ready for Board Review:

• PDI 1063 – Christopher L. Geister • PAC 2079 – Northstar Protective Services, LLC

SEPTEMBER CONTINGENCIES – STATUS WOULD END IN NOVEMBER Not Ready for Board Review:

• PDI 1018 – William G. Nelson AUGUST CONTINGENCIES – STATUS WOULD END IN OCTOBER Not Ready for Board Review:

• PDC 2019 – Assets International, LLC • PAC 2075/PDC 2074 – Sandlie Consulting

JULY CONTINGENCIES – STATUS WOULD END IN SEPTEMBER Not Ready for Board Review:

• PDC 1125 – Claims Verification, Inc.

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JUNE CONTINGENCIES – STATUS WOULD END IN AUGUST Not Ready for Board Review:

• PDC 2013 – Albin Acquisition Corporation • PAC 1121 – Security Solutions Protective Agency

MAY CONTINGENCIES – STATUS WOULD END IN JULY Not Ready for Board Review:

• PAC 2068 – Guardian Protective Agency • PDC 2067 – Semper Fi Security, LLC

MARCH CONTINGENCIES - STATUS WOULD END IN MAY Not Ready for Board Review:

• PAC 2005 & PDC 2006 – Universal Security Corp. FEBRUARY CONTINGENCIES – STATUS WOULD END IN APRIL

Not Ready for Board Review:

• PAC 2053 – Intermediate District 287 • PAC 2052 – Boutchantharaj Corporation

6. LAPSED LICENSES:

• PDI 929 – Warren J. Robinson • PAC 1190 – Blueline Services

7. EXPIRED LICENSES: NONE. 8. SURRENDERED LICENSES: NONE.

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9. OFFICER CHANGES:

NAME OF ENTITY American Security, LLC LICENSE TYPE & NUMBER PAC 1173 & PDC 903

TYPE OF CHANGE QR CHANGE FROM Steven Klein

CHANGE TO Francisco Flores Jr. DATE RECEIVED 5/6/2021

MINNESOTA ADDRESS 1717 University Ave. W St. Paul, MN 55104 PREVIOUS RELEVANT EMPLOYMENT TITLE FROM TO

American Security, LLC President and COO Dec-18 Present Vital Security and Investigations COO Mar-16 Dec-18 Universal Protection Services Reg VP Nov-01 Mar-16 AGENCY NOTES: No Issues.

10. REQUEST TO SPEAK TO THE BOARD: NONE. 11. OTHER ISSUES AND DISCUSSIONS:

• Licensing subcommittee – tabled discussion

12. ANNOUNCEMENTS: NONE. Board Chair: We may be having a closed session per the statute below. If necessary, please read these statutes aloud for the record. 13. CLOSED SESSION: Pursuant to Minn. Stat. 13D.05, subd. 3 (b) attorney-client privilege discussions.

Next meeting scheduled for June 29, 2021 at 10:00 AM.

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STATE OF MINNESOTA PRIVATE DETECTIVE AND PROTECTIVE AGENT SERVICES BOARD

1430 Maryland Avenue East, St. Paul, Minnesota April 27, 2021 TELECONFERENCE MEETING

SYNOPSIS MEMBERS PRESENT: Richard Hodsdon, Jim Hessel, Douglas Belton, Jeff Hansen MEMBERS NOT PRESENT: Melinda Elledge ATTORNEY GENERAL REPRESENTATIVE: Steve Melchionne EXECUTIVE DIRECTOR: Hugo McPhee ADMINISRATIVE ASSISTANT: Stephanie Maresh

• New Executive Director – Hugo McPhee Hodsdon commenced the meeting, noted for the record that Member Elledge is not present for the meeting. Hodsdon introduced and welcomed the new Executive Director, Hugo McPhee, and invited him to say a few words. McPhee introduced himself and expressed his excitement to work with the staff and the Board and learn more about what they do and find ways to help in any way he can. 1. REVIEW OF MARCH 2021 MEETING MINUTES

• Backlog currently has 32 outstanding renewals Hodsdon asked Board members if there were any additions or edits for the March Meeting Minutes. Hearing none, he asked for a motion to approve the minutes.

• Motion: Hessel made a motion to approve the March Meeting Minutes. Hansen seconded. Motion carried.

2. TRAINING CONSENT AGENDA:

TYPE PROVIDER/LICENSE HOLDER AGENCY NOTES New Training Instructor (3) JBM Patrol & Protection No issues. New Training Instructor (2) American Security & Investigations, LLC No issues.

Request for CEUs Metro One Loss Prevention Services Group (Guard Division) Inc.

No issues.

Request for CEUs Leaf Investigations, LLC No issues.

New Training Course Minnesota Association of Private Investigators and Protective Agents (MAPI)

No issues.

Hodsdon read aloud for the record the items on the Training Consent Agenda, and asked if there was a motion to approve said items.

• Motion: Belton made a motion to approve the items on the Training Consent Agenda. Hessel seconded. Motion carried.

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3. RENEWAL CONSENT AGENDA:

LICENSE HOLDERS PDC 675 – McCarthy & Associates Investigative Services, Inc. PDI 877 – Pamela Paulsen-Sveen** PDC 2098 – Anderson Engineering of New Prague, Inc.** PDI 2100 – Lisa Ditlefsen** PDC 721 – INPRO, LLC PAC 330 – Walden Security Company PDC 780 – Investigative Technologies, Inc. PDC 1167 – Annglish, Inc. PAC 1165 – Protection Security, Inc. PDC 46/PAC 1168 – General Security Services Corporation (GCCS)** PDC 1025 – Sturm Consulting and Investigations, LLC** PDC 533 – Schroeder Fire, Inc. PAC 2094 – Metro One Loss Prevention Services Group (Guard Division) Inc. ** Indicates license holder provided a renewal with no issues upon original submission. Hodsdon advised license holders that have not yet completed the renewal process, to do so as soon as possible, as the Executive Order may not be active for much longer and would then run the risk of going into a lapsed status for the license. Hodsdon read into record the licenses on the Renewal Consent Agenda, and asked for a motion of approval.

• Motion: Hansen made a motion to approve the Renewal Consent Agenda. Hessel seconded. Motion carried.

4. RENEWALS IN NEED OF BOARD REVIEW: PDC 1166 – Marshall Investigative Group Hodsdon summarized the preassignment date concerns for the Board and asked staff if there were any updates. Maresh confirmed that the employees in question did not work in a licensable capacity until training was complete. Hodsdon noted that there seemed to be one instance of disciplinary action for the license and asked if he was correct in that statement. Maresh confirmed there had been one Letter of Education issued previously for preassignment issues in the past. Hodsdon elaborated on why the issue is a lesser concern for him because the employees were not working outside of a training capacity. Maresh confirmed that the license holder explained that for various reasons, each employees’ training period lasted for different amounts of time, and they were not eligible to work in the field until the training was completed. Hodsdon also noted for the Board that the license is not a security company, so there may have been more concern if that were the case. Hansen asked if the management was the same as when they had the disciplinary action before. Maresh stated that it seemed to be the same management.

• Motion: Hansen made a motion to approve the renewal and issue a single $100 penalty. Belton seconded. Motion carried.

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PDC 1084 – Blue Eagle Investigations, Inc. Hodsdon noted another preassignment training issue. Hodsdon explained that the license holder seemed to believe that his preassignment training requirement was waived when the license was issued. Hodsdon asked staff if there was any record of the waiver in the meeting minutes or otherwise. Maresh confirmed that there is no record of a waiver. Hodsdon asked what the pleasure of the Board would be. Belton asked if the license holder had received preassignment training retroactively. Maresh stated that there had been no preassignment training completion. Hodsdon asked Belton if he would motion to renewing the license, contingent upon proof of preassignment training completion.

• Motion: Belton made a motion to approve the renewal, contingent upon completion of preassignment training. Hessel seconded. Motion carried.

Hodsdon read the following licenses aloud for the record, that are not yet ready for review, that require no Board action given the authority of Executive Order 20-25. Not Ready for Board Review:

• PAC 2097/PDC 2096 – Tier 1 Security Inc. • PDC 746/PAC1174 – Talon Investigation Ltd. • PDI 414 – William J. O’Keefe • PDC 2038 – Guardian Investigations, Inc. • PDI 2040 – Paul Johnson • PDI 2101 – Steven Broom

5. CURRENT CONTINGENCIES: MARCH CONTINGENCIES – STATUS WOULD END IN MAY

• PAC 2037 – Ehni Enterprises, LLC FEBRUARY CONTINGENCIES – STATUS WOULD END IN APRIL PAC 2089 – American Guard Services, Inc. Hodsdon summarized another preassignment training issue for the Board. Hodsdon noted that the preassignment training is now complete.

• Motion: Hansen made a motion to approve the renewal. Belton seconded. Motion carried. Hodsdon read the following licenses aloud for the record, that are not yet ready for review, that require no Board action given the authority of Executive Order 20-25. Not Ready for Board Review:

• PDC 620 – Active Research Investigations, Inc. • PDI 2092 – Michaela Knower • PDI 861 – Peter J. Legus

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JANUARY CONTINGINCIES – STATUS WOULD END IN MARCH

• PAC 305 – Shield Services, LLC • PDI 2087 – Bashir Abdi

DECEMBER CONTINGENCIES – STATUS WOULD END IN FEBRUARY

• PAC 261 – Lakeside Protection, Inc. OCTOBER CONTINGENCIES – STATUS WOULD END IN DECEMBER

• PDI 1063 – Christopher L. Geister • PAC 2079 – Northstar Protective Services, LLC

SEPTEMBER CONTINGENCIES – STATUS WOULD END IN NOVEMBER

• PDI 1018 – William G. Nelson AUGUST CONTINGENCIES – STATUS WOULD END IN OCTOBER

• PDC 2019 – Assets International, LLC • PAC 2075/PDC 2074 – Sandlie Consulting

JULY CONTINGENCIES – STATUS WOULD END IN SEPTEMBER

• PDC 1125 – Claims Verification, Inc. JUNE CONTINGENCIES – STATUS WOULD END IN AUGUST

• PDC 2013 – Albin Acquisition Corporation • PAC 1121 – Security Solutions Protective Agency

MAY CONTINGENCIES – STATUS WOULD END IN JULY

• PAC 2068 – Guardian Protective Agency • PDC 2067 – Semper Fi Security, LLC

MARCH CONTINGENCIES - STATUS WOULD END IN MAY

• PAC 2005 & PDC 2006 – Universal Security Corp. FEBRUARY CONTINGENCIES – STATUS WOULD END IN APRIL

• PAC 2053 – Intermediate District 287 • PAC 2052 – Boutchantharaj Corporation

6. LAPSED LICENSES:

• PDI 929 – Warren J. Robinson • PAC 1190 – Blueline Services

7. EXPIRED LICENSES: NONE.

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8. SURRENDERED LICENSES:

• PAC 1141 – Ira E. Clark Detective Agency, Inc. Hodsdon noted for the record the above license had chosen to surrender its active status. 9. NEW LICENSE APPLICANTS – PRESENT:

NAME OF ENTITY Aspis, LLC LICENSE TYPE Corporate Protective Agent

QUALIFIED REPRESENTATIVE Dale Krueger MINNESOTA MANAGER Dale Krueger

CEO Dale Krueger CFO Dale Krueger

Hodsdon welcomed the applicant, Dale Krueger, to the meeting. Hodsdon deferred to the Board members if they had any questions. Belton asked the applicant what the plans for the license are including how many employees he plans on having. Krueger stated that there are no plans for armed employees and stated that the number is subjective to the client needs, but that they hope for 25. Hodsdon asked if there are any other questions or a motion.

• Motion: Belton made a motion to approve the license application. Hessel seconded. Motion carried.

10. NEW APPLICANTS – CONSENT AGENDA: NONE. 11. NEW LICENSE APPLICANTS – TABLED:

• Redi Transports LLC Hodsdon asked staff when the tabled applicant was up for consideration again. Guthrie stated that she believed the application is up for review in July. 12. OFFICER CHANGES: NONE. 13. REQUEST TO SPEAK TO THE BOARD: NONE. 14. OTHER ISSUES AND DISCUSSIONS: Hodsdon updated the Board members that a previous issue with a license denial will be coming up again soon and due to that specific instance, there are some propositions for handling license applicants in a more private setting. This is so that if there is any incorrect information, or a contested case hearing is pursued, there is no tarnishing of any reputation in a public meeting and the Board members are not biased if it comes back to the Board. Melchionne explained some different options that the Board may pursue, one of which sounding more appealing to members, is a creation of a sub-committee with the delegated power to approve licenses outside of a public Board meeting.

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The Board members and staff expressed their support, as well as some concerns, with setting up a sub-committee for license approvals. The Board members discussed using this type of delegated power for license applications, renewals, and training applications.

• Motion: Hodsdon made a motion to approve delegated authority to specified staff and Board members to approve license applications as well as reissuance applications in the form of a sub-committee to report back to the Board an attached consent item or items that would require Board discussion and potential for a contested case hearing. Belton seconded. Motion carried.

• Motion: Belton made a motion to table the official creation of the sub-committee until all Board members are present to vote. Hessel seconded. Motion carried.

Hodsdon asked further questions on how this could be accomplished with training. Melchionne stated that he would do some research on options on the topic and write up a delegation form for the following month.

• Motion: Hessel made a motion to have Board counsel write up the proper delegation forms for the Executive Director and/or designees to have the authority to approve continuing education and preassignment courses moving forward. Hansen seconded.

• Motion: Hansen made a motion to table the matter until counsel can provide necessary agreement forms to have the delegation properly documented. Hessel seconded. Motion carried.

• Allied Universal second quarterly Audit – informational only

o See pages 18-20 Hodsdon asked staff to give some update and summary on the audit being presented in the Board docs. Maresh addressed the Board stating that the audit at this time is still informational, and that staff has had continuous communication with the license holder on getting things finalized and ready for renewal. Hodsdon asked Board members, given the communication and work with the license holder there has been, if an extension on the upcoming audit would be permitted. Board members expressed no concerns. Hessel brought to Board attention to some potential unlicensed activity seen on media outlets. Hodsdon stated that if it is a licensed entity, to reach out to the Board, and if not, to reach out to local law enforcement. 15. ANNOUNCEMENTS: NONE. Board Chair: We may be having a closed session per the statute below. If necessary, please read these statutes aloud for the record. 16. CLOSED SESSION: Pursuant to Minn. Stat. 13D.05, subd. 3 (b) attorney-client privilege discussions.

• Motion: Hessel made a motion to adjourn the meeting. Belton seconded. Motion carried.

Next meeting scheduled for May 25, 2021 at 10:00 AM.

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05/10/2021 State of Minnesota Board of Private Detective and Protective Agent Services 1430 Maryland Avenue East St. Paul, MN 55106 RE: Explanations on Affidavit of Training Issues – Tabs 1 to 6 Dear State of Minnesota Board of Private Detective and Protective Agent Services: This letter serves as a letter of explanation for the issues brought forth and explicated in Tabs 1 through 6 of the “2019-2020 ASI Affidavit 4-29-2021 WITH FORMULAS” (the spreadsheet ASI submitted but with Board edits) that was shared in an email from the Board, dated 5/4/2021, that asked for clarification on the issues pointed out within the respective tabs. TAB 1 In Tab 1, a total of 17 officers were listed where the pre-assignment orientation training dates exceeded the 21 days from their stated hire date. Ten of the 17 were the result of taking over two accounts from Securitas and thus absorbing their employees. Although all of the security officers that transferred over to ASI had previously gone through pre-assignment training with their previous employer (Securitas), our practice is to bring all new employees through our 12 hours of state-mandated pre-assignment orientation training. With inheriting a large amount of the existing security staff from the previous vendor (Securitas) and knowing or assuming they had already been through state-mandated 12 hours pre-assignment training with their previous employer, we knew we had time to get them through our own version of the state-mandated pre-assignment training, which is great due to how difficult scheduling can be with transitions; however, the unfortunate reality is we were not able to either obtain a copy of their Securitas pre-assignment training certificate or get them through our own state-mandated pre-assignment training prior to the 21 day threshold. Eight of the 17 listed on Tab 1 are technically in compliance with the 21 day rule, because although the hire date listed on the affidavit is their hire date as it relates to the date they were entered into our computer system, there was zero employment activity for 6 of the 8 officers until their state-mandated pre-assignment training. For the other two officers, their pre-assignment training was completed within 21 days of their first day worked, which is technically the “official” hire date.

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On the “Copy of 2019-2020 ASI Affidavit 4-29-2021 WITH FORMULAS” document, I have added an “Explanation” column for which you will see a detailed explanation for each of the 17 listed officers. Highlighted in yellow are the 8 officers that should not be in violation of the 21 day rule and whose actual hire date is the first day worked, which is defined as the first day they work in an official wage earning capacity. Based on that, none of the 8 highlighted officers should technically not be in violation. TABS 2 - 4 Tabs 2 – 4 are virtually the same in that they all deal with proactively applying or “rolling over” excess CEU’s to the following CEU year or period. So for Tab 2, the reason why the officers listed have a reported 1st year date that falls outside of the 2019 period and a second year date that falls outside of that period (2020) is because all of the officers listed completed their CEU’s early. The same applies for Tab 3; these employees had extra CEU’s completed the previous year that were applied forward to the 2019 period and then they waited until the 2020 CEU timeframe to complete their 2020 CEU’s (year 2). It’s the same for Tab 4 in that the listed employees completed both the 2019 and 2020 CEU’s within the same year; the extra CEU’s were applied forward to the 2020 CEU period. As mentioned in an email dated May 5, 2020, to Stephanie Maresh, Abigail Guthrie, and Kaylin Smith, although we (ASI) understand the logic behind not wanting to allow CEU’s to rollover into the next year or CEU period, ASI has for many years applied forward or “rolled over” extra CEU’s to the next CEU year/period, this has been reflected on previous years’ affidavits of training, and the practice began as a result of material from the State Board. To illustrate, on November 8, 2015, one of the ASI vice president’s sent out an email about the MN State Board training requirements and pasted in the body of the email a section from the Board website in 2015 that I have pasted below for your reference.

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Please note bullet point number 1 where it states, “When taking training, if in one year a course(s) are taken is more than 6-hours, the excess hours may be applied to the following year only.” With the Board approving this practice based on this communication from the website, ASI has been applying the extra CEU courses taken in one year to the following year, and this practice is the reason for what appears to be discrepancies in Tabs 2 – 4. However, at the end of the day, all officers notated on Tabs 2 -4 are technically in compliance with their CEU’s based on how we (ASI) have been applying the extra CEU courses (6 CEU’s) forward. Looking back at previous Affidavits of Training, the Board will find this same practice and will see compliance with CEU’s; the CEU’s may have been obtained in a prior year or CEU period, but because they were extra CEU’s, they were proactively applied to the next CEU year. TAB 5 As it was told by the PDC manager, employee Glen Ernest did not complete his pre-assignment training within the 21 day time period, because he has been a private detective in Minnesota for so many years that he has been “grandfathered” in and therefore did not need to re-attend any pre-assignment training. However, as an organization, we require proof. No proof was submitted and therefore the employee attended an online MN pre-assignment training program for private detectives to meet the pre-assignment training requirement. The pre-assignment training was done very late, but it was completed. TAB 6 The four private investigators listed in Tab 6 simply forgot to complete their 2019 CEU’s, so they did both their 2019 and 2020 CEU’s within the same timeframe. It is our hope that this letter of explanation has helped to clarify the issues that were pointed out in our Affidavit of Training, especially those from Tabs 2 – 4 that emanated from the practice of rolling over extra CEU’s into the next year. As a general statement, ASI takes both training and compliance seriously. In fact, when it comes to training, we pride ourselves on giving more training than what the state requires. For example, after the 12 hours of state-mandated pre-assignment training, we also send every security officer through the 6 hour American Red Cross CPR/AED/First Aid certification course. For those officers who will be going to accounts that require defensive tactics or the carrying of an ancillary weapon, we provide 24 hours (3 days) of initial defensive tactics training in the PPCT/HFS Threat Pattern Recognition system of defensive tactics. Our annual defensive tactics training is six hours. For those going to an account requiring a firearm, we provide 12 hours of initial firearms training and our annual firearm requalification course is six hours. In addition, we offer officers training courses they can take online; some of those courses are certified by the state board that we have subsequently applied towards the general 6 CEU’s for the following year, and some of the material is for added study if officer staff wish to voluntarily do so on their own time. Moreover, the Training and Consultative Services division works with account managers to help them develop training programs for their own accounts on a variety of security

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topics that can be applied to their specific environment and vertical market. In the end, we are serious about training and development and are always looking to add more to help our protective agents and private detectives to maximize their performance within their respective roles. What we will need to know going forward is whether or not as a licensed protective agent and private detective company we can continue the practice of rolling over extra CEU courses to the following year or, if starting May of 2021, we are to ensure that the six required CEU’s are completed only within the one-year CEU cycle or period. We have no qualms either way and will gladly abide by whatever the decision is. We just need to know, so please advise once a decision has been made. Thank you for your professional correspondence and assistance with all regulatory matters, your professionalism and partnership is truly appreciated. We look forward to continuing to work with the MN Board in not only ensuring minimum training standards are met, but that in the years to come we can help increase the professional standards of the industry as a whole. Thank you. Sincerely, Anthony L. Rootes, Psy.D., M.C.J. Vice President of Training & Consultative Services arootes@americansecurityll.com Cell: 651-755-7492

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PDC 903/PAC 1173 – American Security & Investigations – Disciplinary History March 30, 2009 American Security, LLC Steven Klein, Qualified Representative & Minnesota Manager Corporate/LLC Private Detective American Security, LLC’s contingent license had been extended from the February meeting to allow for time to review their response. Ohman noted that American Security, LLC had previously received a letter of education and conciliation regarding training. The Board discussed factors of actual and potential harm, the licensee’s culpability, and frequency of violation(s). O’Malley motioned a $100.00 administrative penalty for lack of compliance with training, second by Moen. The vote was unanimous. May 23, 2011 American Security, LLC dba/American Security & Investigations Steven Klein, Qualified Representative & Minnesota Manager Corporate/LLC Private Detective There were several training issues with a number of employees not receiving training in the required year and making up that training in this year, and one employee’s state and federal criminal histories were reinitiated because they could not document they occurred. Moen noted the potential for great harm, particularly with armed training not taking place when it should have, the company has a penalty history regarding training and is culpable. Spence motioned that a $250 Administrative Penalty be issued to the company noting the severity and that training concerns are repeated. The motion was seconded by Wohlman. The vote was unanimous. May 26, 2017 PAC 1173 PDC 903 – American Security, LLC Jahnz stated that the company had responded to the Board’s questions. Hodsdon stated that a lot of the explanations were terminated employees that were rehired. Hodsdon stated that the previous disciplinary actions were for very similar issues. Hansen agreed.

MOTION: Hansen made a motion that PAC 1173 PDC 903 – American Security, LLC be granted a license, with a $499 .administrative penalty. Sandoz seconded. The motion carried.

June 25, 2019 PDC 903 – American Security, LLC – Contingency Status ends July 2019 PAC 1173 – American Security, LLC – Contingency Status end July 2019

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Hodsdon stated that the renewal was complete and referred to their disciplinary history. Hodsdon stated that they had some problems a few years ago and that there were some renewal cycles that were not problematic. Cook stated that Mark Ford from American Security was present to address any concerns. Hodsdon asked what question was left blank on the renewal form. Vue stated that they did not answer the question, “What is the Qualified Representative and Minnesota Manager responsible for?” Hodsdon stated that it was an important question. Hodsdon reviewed the disciplinary history and stated that the training seemed to not be an issue.

Moitzheim made a motion for a renewal with a letter of education. Hanson seconded. The motioned carried.

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