Sanford C. Bernstein & Co.., LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CHICAGO BOARD OF OPTIONS EXCHANGE
2.
Principal Sanction:
Censure
Other Sanctions: 
$10,000 FINE
3.
Date Initiated (MM/DD/YYYY): 
05/26/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
STAR NO. 20150453074
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REGISTRATIONS PURSUANT TO CBOE RULE 3.6A
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ACTS, PRACTICES, AND CONDUCT DESCRIBED BELOW CONSTITUTE VIOLATIONS OF EXCHANGE RULE 3.6A BY SANFORD C. BERNSTEIN & CO., LLC
FROM ON OR ABOUT AUGUST 13, 2013 THROUGH ON OR ABOUT JANUARY 1, 2015, SANFORD FAILED TO QUALIFY AND REGISTER ONE (1) ASSOCIATED
PERSON[1] AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD. FROM ON OR ABOUT AUGUST 13, 2013 THROUGH ON OR
ABOUT SEPTEMBER 2, 2014, SANFORD FAILED TO REGISTER A SECOND ASSOCIATED PERSON AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE
EXCHANGE IN WEBCRD. FROM ON OR ABOUT AUGUST 13, 2013 THROUGH ON OR ABOUT SEPTEMBER 2, 2014, SANFORD FAILED TO REGISTER ITS CO-
CHIEF COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
07/23/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
NONE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE ACTS, PRACTICES, AND CONDUCT DESCRIBED BELOW CONSTITUTE VIOLATIONS OF EXCHANGE RULE 3.6A BY SANFORD.. FROM ON OR ABOUT
AUGUST 13, 2013 THROUGH ON OR ABOUT JANUARY 1, 2015, SANFORD FAILED TO QUALIFY AND REGISTER ONE (1) ASSOCIATED PERSON[1] AS A
PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE IN WEBCRD. FROM ON OR ABOUT AUGUST 13, 2013 THROUGH ON OR ABOUT SEPTEMBER

(
)
2, 2014, SANFORD FAILED TO REGISTER A SECOND ASSOCIATED PERSON AS A PROPRIETARY TRADER PRINCIPAL (TP) WITH THE EXCHANGE IN
WEBCRD. FROM ON OR ABOUT AUGUST 13, 2013 THROUGH ON OR ABOUT SEPTEMBER 2, 2014, SANFORD FAILED TO REGISTER ITS CO-CHIEF
COMPLIANCE OFFICER AS A PROPRIETARY TRADER COMPLIANCE OFFICER (CT) WITH THE EXCHANGE IN WEBCRD. ALL NOTED INDIVIDUALS NOW
APPROPRIATELY LICENSED PURSUANT TO CBOE RULE 3.6A.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE EDGX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND $5,000.00 FINE

3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
RESULT OF THE 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
2016051337106
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED EDGX RULE 2.3(C) FOR THE PERIOD MAY 1, 2013 THROUGH FEBRUARY 16, 2015 AND 2.5, INTERPRETATION .01(D) FOR THE
PERIOD OF FEBRUARY 17, 2015 THROUGH DECEMBER 2, 2015 BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/09/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED EDGX RULE 2.3(C) FOR THE PERIOD MAY 1, 2013 THROUGH FEBRUARY 16, 2015 AND 2.5, INTERPRETATION .01(D) FOR THE
PERIOD OF FEBRUARY 17, 2015 THROUGH DECEMBER 2, 2015 BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:

11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE EDGA EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND FINE $5,000.00
3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
ISSUE NOTED DURING 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
2015045281607
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED EDGA RULE 2.3(C) FOR THE PERIOD MAY 1, 2013 THROUGH FEBRUARY 16, 2015 AND 2.5, INTERPRETATION .01(D) FOR THE
PERIOD OF FEBRUARY 17, 2015 THROUGH DECEMBER 2, 2015 BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/09/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED EDGA RULE 2.3(C) FOR THE PERIOD MAY 1, 2013 THROUGH FEBRUARY 16, 2015 AND 2.5, INTERPRETATION .01(D) FOR THE
PERIOD OF FEBRUARY 17, 2015 THROUGH DECEMBER 2, 2015 BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE BYX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND FINE $5,000.00
3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
ISSUE NOTED DURING 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
2016051337103
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED BYX RULE 2.5, INTERPRETATION .01(D) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/09/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED BYX RULE 2.5, INTERPRETATION .01(D) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.

This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE BZX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND FINE $5,000.00
3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
ISSUE NOTED DURING 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
2016051337104
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED BZX RULE 2.5, INTERPRETATION .01(D) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/09/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00

 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED BZX RULE 2.5, INTERPRETATION .01(D) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES
PRINCIPAL WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE ARCA, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND FINE $5,000.00
3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
ISSUE NOTED DURING 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
20160513371
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED NYSE ARCA RULE 22.1(A) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES PRINCIPAL
WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
03/16/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR

"THE FIRM") VIOLATED NYSE ARCA RULE 22.1(A) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES PRINCIPAL
WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE AMERICAN LLC
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/09/2022
 Exact
 Explanation

If not exact, provide explanation:
4.
Docket/Case Number:
2021069337201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ADEQUATELY DOCUMENT SUPERVISORY SYSTEMS AND KEEP CURRENT WRITTEN COMPLIANCE AND SUPERVISORY POLICIES AND PROCEDURES
REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RECORDKEEPING PROVISIONS THAT REQUIRE THE PROPER MAINTENANCE OF RECORDS OF
CUSTOMERS' ELECTRONIC OPTIONS ORDERS, IN VIOLATION OF NYSE AMERICAN RULE 320. SPECIFICALLY, THE FIRM FAILED TO DEMONSTRATE THAT IT
CONDUCTED A REVIEW FOR THE ACCURACY OF ORDER TIMESTAMPS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Other
11. Resolution Date (MM/DD/YYYY):
08/09/2022
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS FINED $3,500.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MATTER WAS RESOLVED WITH A MINOR RULE VIOLATION PLAN LETTER.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE ARCA, INC.
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/08/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018057171904
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT
NYSE ARCA AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH AND MAINTAIN
WRITTEN SUPERVISORY PROCEDURES ("WSPS"), AND A SYSTEM OF SUPERVISION TO SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED PERSONS AND

THE OPERATION OF ITS BUSINESS. SUCH SYSTEM MUST BE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE APPLICABLE RECORDKEEPING
PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE ARCA RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND
TRANSMISSION TIMES OF OPTIONS ORDERS. SPECIFICALLY, THE FIRM'S WSPS DID NOT INCLUDE ANY REVIEW FOR THE ACCURACY OF ORDER RECEIPT
AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS HANDLED BY THE FIRM.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/08/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 27,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED AND FINED $85,000, OF WHICH $27,500 SHALL BE PAID TO NYSE ARCA. THE BALANCE OF THE FINE SHALL BE PAID TO
NYSE AMERICAN LLC, NASDAQ PHLX LLC, AND NASDAQ ISE, LLC. ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OF SIMILAR
SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND NYSE AMERICAN LLC, NASDAQ PHLX LLC AND NASDAQ ISE, LLC.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE BYX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281605
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), BYX RULES 11.9(D)(1)
(FOR CONDUCT OCCURRING BEFORE OCTOBER 17, 2014), 11.9(D) (FOR CONDUCT OCCURRING ON OR AFTER OCTOBER 17, 2014), 5.1, AND 3.1.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/21/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 9,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") WITH RESPECT TO THE AREAS DESCRIBED IN
PARAGRAPH I.A.5. WITHIN 30 CALENDAR DAYS OF ACCEPTANCE OF THIS AWC BY THE CHIEF REGULATORY OFFICER ("CRO") OF BYX, A
REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE,
SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL
TO MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A
REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS TO ADDRESS THE ABOVE-DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED
PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE EDGX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281607
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), EDGX RULES 11.5(D)
(1) (FOR CONDUCT OCCURRING BEFORE OCTOBER 29, 2014), 11.8(C) (FOR CONDUCT OCCURRING ON OR AFTER OCTOBER 29, 2014), 5.1, AND 3.1.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/21/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 9,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") WITH RESPECT TO THE AREAS DESCRIBED IN
PARAGRAPH I.A.5. WITHIN 30 CALENDAR DAYS OF ACCEPTANCE OF THIS AWC BY THE CHIEF REGULATORY OFFICER ("CRO") OF EDGX, A
REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE,
SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL
TO MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A
REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS TO ADDRESS THE ABOVE-DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED
PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed

This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE BZX EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281604
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), BZX RULES 11.9(D)(1)
(FOR CONDUCT OCCURRING BEFORE OCTOBER 17, 2014), 11.9(D) (FOR CONDUCT OCCURRING ON OR AFTER OCTOBER 17, 2014), 5.1, AND 3.1.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):
06/21/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 9,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") WITH RESPECT TO THE AREAS DESCRIBED IN
PARAGRAPH I.A.5. WITHIN 30 CALENDAR DAYS OF ACCEPTANCE OF THIS AWC BY THE CHIEF REGULATORY OFFICER ("CRO") OF BZX, A
REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE,
SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL
TO MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A
REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS TO ADDRESS THE ABOVE-DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED
PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is

registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281603
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXECUTED ONE
ORDER INTERNALLY BY TRADING AS PRINCIPAL OR CROSSING THE ORDER AS AGENT, THUS ACTING AS A TRADING CENTER, BUT FAILED TO
SIMULTANEOUSLY SEND INTERMARKET SWEEP ORDERS (ISOS) TO ONE OR MORE MARKETS DISPLAYING BETTER-PRICED QUOTATIONS, RESULTING IN A
TRADE-THROUGH, IN VIOLATION OF EXCHANGE ACT RULE 611(A). ADDITIONALLY, THE FIRM EXPERIENCED FIVE SYSTEM PROBLEMS THAT CAUSED THE
FIRM TO ROUTE APPROXIMATELY 2,404 ISOS TO MARKET CENTERS WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS.
SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY
CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE.
ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET
FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT
WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES,
CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611. SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-
PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN
VIOLATION OF EXCHANGE ACT RULE 611(C), NASD RULE 3010(A) AND (B) (FOR CONDUCT OCCURRING BEFORE DECEMBER 1, 2014), FINRA RULES
3110(A) AND (B) (FOR CONDUCT OCCURRING ON OR AFTER DECEMBER 1, 2014) AND 2010.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):
06/26/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
AN UNDERTAKING TO REVISE THE FIRM'S WSPS WITH RESPECT TO THE AREAS DESCRIBED IN PARAGRAPHS I.A.13-14. WITHIN 30 CALENDAR
DAYS OF ACCEPTANCE OF THIS AWC BY THE NATIONAL ADJUDICATORY COUNCIL ("NAC"), A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT
TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE, SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED
LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL TO MARKETREGULATIONCOMP@FINRA.ORG,
PROVIDING THE FOLLOWING INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS
TO ADDRESS THE ABOVE-DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE AMERICAN LLC
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/08/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018057171903
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO FLOOR BROKERS AT
NYSE AMERICAN AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION. ADDITIONALLY, THE FIRM FAILED TO ESTABLISH AND
MAINTAIN WRITTEN SUPERVISORY PROCEDURES ("WSPS"), AND A SYSTEM OF SUPERVISION TO SUPERVISE THE ACTIVITIES OF ITS ASSOCIATED
PERSONS AND THE OPERATION OF ITS BUSINESS. SUCH SYSTEM MUST BE REASONABLY DESIGNED TO ENSURE COMPLIANCE WITH THE APPLICABLE
RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS AND NYSE AMERICAN RULES THAT REQUIRE THE ACCURATE DOCUMENTATION OF
THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS. SPECIFICALLY, THE FIRM'S WSPS DID NOT INCLUDE ANY REVIEW FOR THE
ACCURACY OF ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS HANDLED BY THE FIRM.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
09/08/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $ 27,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED AND FINED $85,000, OF WHICH $27,500 SHALL BE PAID TO NYSE AMERICAN. THE BALANCE OF THE FINE SHALL BE
PAID TO NYSE ARCA, INC, NASDAQ PHLX LLC, AND NASDAQ ISE, LLC. ACCEPTANCE OF THIS AWC IS CONDITIONED UPON ACCEPTANCE OF
SIMILAR SETTLEMENT AGREEMENTS IN RELATED MATTERS BETWEEN THE FIRM AND NYSE ARCA, INC., NASDAQ PHLX LLC AND NASDAQ ISE, LLC.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE ARCA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), NYSE ARCA EQUITIES
RULES 7.31(JJ) (FOR CONDUCT OCCURRING BEFORE APRIL 23, 2015), 7.31(E)(2) (FOR CONDUCT OCCURRING ON OR AFTER APRIL 23, 2015) AND NYSE
ARCA EQUITIES RULE 6.18.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/26/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
SANFORD C. BERNSTEIN & CO., LLC SHALL REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE SUPERVISORY
DEFICIENCIES DESCRIBED IN THIS DECISION AND ENSURE IT HAS IMPLEMENTED CONTROLS AND PROCEDURES REASONABLY DESIGNED TO
ACHIEVE COMPLIANCE WITH THE RULES AND REGULATIONS CITED HEREIN. WITHIN 30 CALENDAR DAYS OF THIS DECISION, A REGISTERED
PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE, SUITE 300,
ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE FIRM'S REGISTERED PRINCIPAL TO
MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING INFORMATION: (I) A REFERENCE TO THIS MATTER; (II) A REPRESENTATION
THAT THE FIRM HAS REVISED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THE DEFICIENCIES AS INDICATED ABOVE; AND (III) THE
DATE THE REVISED PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NEW YORK STOCK EXCHANGE LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281603
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), NYSE RULES 13 (FOR
CONDUCT OCCURRING BEFORE JULY 13, 2015), 13(E)(3) (FOR CONDUCT OCCURRING ON OR AFTER JULY 13, 2015), NYSE RULES 342 (FOR CONDUCT
OCCURRING BEFORE DECEMBER 1, 2014), AND 3110 (FOR CONDUCT OCCURRING ON OR AFTER DECEMBER 1, 2014).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/26/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 6,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,

Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
AN UNDERTAKING TO REVISE THE FIRM'S WSPS WITH RESPECT TO THE AREAS DESCRIBED IN PARAGRAPH I.A.5. WITHIN 30 CALENDAR DAYS OF
THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, A REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE
ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE, SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL
FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL TO MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING
INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS TO ADDRESS THE ABOVE-
DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II

1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
CBOE EDGA EXCHANGE, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
08/29/2017
 Exact
 Explanation
If not exact, provide explanation:
THIS REPRESENTS THE DATE OF THE "WELLS" LETTER IN WHICH FINRA INFORMED US OF IT RECOMMENDATION THAT DISCIPLINARY ACTION BE
BROUGHT AGAINST THE FIRM.
4.
Docket/Case Number:
2015045281606
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIODS OF OCTOBER 1, 2014 THROUGH MARCH 31, 2015, AND JULY 1, 2015 THROUGH SEPTEMBER 30, 2015, THE FIRM EXPERIENCED
FIVE SYSTEM PROBLEMS THAT CAUSED THE FIRM TO ROUTE APPROXIMATELY 2,404 INTERMARKET SWEEP ORDERS (ISOS) TO MARKET CENTERS
WITHOUT ROUTING ADDITIONAL ISOS TO ONE OR MORE PROTECTED QUOTATIONS. SPECIFICALLY, THE VIOLATIVE ISOS WERE SENT AS A RESULT OF
INCOMPLETE SNAPSHOTS, DROPPED MARKET DATA FEEDS, AND ERRONEOUSLY CONFIGURED SYSTEMS THAT AFFECTED BOOK-BUILDING FUNCTIONS
AND CAUSED MISSING TAGS THAT IDENTIFIED A SECURITY'S LISTING EXCHANGE. ADDITIONALLY, THE FIRM FAILED TO TAKE REASONABLE STEPS TO
ESTABLISH THAT THE ISOS IT ROUTED MET THE DEFINITIONAL REQUIREMENTS SET FORTH IN EXCHANGE ACT RULE 600(B)(30). ADDITIONALLY, THE
FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM THAT WAS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
THE APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE EXCHANGE'S RULES, CONCERNING COMPLIANCE WITH EXCHANGE ACT RULE 611.
SPECIFICALLY, THE FIRM FAILED TO REVIEW THE DATA IT RECEIVED FROM ITS THIRD-PARTY SERVICE PROVIDER TO ENSURE THAT THE RELEVANT
PROTECTED QUOTATIONS WERE BEING CAPTURED. THE FIRM WAS FOUND TO BE IN VIOLATION OF EXCHANGE ACT RULE 611(C), EDGA RULES 11.5(D)
(1) (FOR CONDUCT OCCURRING BEFORE NOVEMBER 13, 2014), 11.8(C) (FOR CONDUCT OCCURRING ON OR AFTER NOVEMBER 13, 2014), 5.1, AND 3.1.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
06/21/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 9,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 

AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES ("WSPS") WITH RESPECT TO THE AREAS DESCRIBED IN
PARAGRAPH I.A.5. WITHIN 30 CALENDAR DAYS OF ACCEPTANCE OF THIS AWC BY THE CHIEF REGULATORY OFFICER ("CRO") OF EDGA, A
REGISTERED PRINCIPAL OF THE FIRM SHALL SUBMIT TO THE COMPLIANCE ASSISTANT, DEPARTMENT OF ENFORCEMENT, 15200 OMEGA DRIVE,
SUITE 300, ROCKVILLE, MD 20850, A SIGNED, DATED LETTER, OR AN E-MAIL FROM A WORK-RELATED ACCOUNT OF THE REGISTERED PRINCIPAL
TO MARKETREGULATIONCOMP@FINRA.ORG, PROVIDING THE FOLLOWING INFORMATION: (1) A REFERENCE TO THIS MATTER; (2) A
REPRESENTATION THAT THE FIRM HAS REVISED ITS WSPS TO ADDRESS THE ABOVE-DESCRIBED DEFICIENCIES; AND (3) THE DATE THE REVISED
PROCEDURES WERE IMPLEMENTED.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ALL MATTERS HAVE BEEN REMEDIATED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign

(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
NYSE AMERICAN LLC
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE AND FINE $5,000.00
3.
Date Initiated (MM/DD/YYYY): 
06/23/2016
 Exact
 Explanation
If not exact, provide explanation:
ISSUE NOTED DURING 2015 FINRA CYCLE EXAMINATION
4.
Docket/Case Number:
2016051337102
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED NYSE AMERICAN RULE 341(A) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES PRINCIPAL
WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
02/22/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
CENSURE AND $5,000.00 FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE PERIOD OF MAY 1, 2013 THROUGH DECEMBER 2, 2015 (THE "RELEVANT PERIOD"), SANFORD C. BERNSTEIN & CO. LLC ("BERNSTEIN" OR
"THE FIRM") VIOLATED NYSE AMERICAN RULE 341(A) BY ALLOWING AN EMPLOYEE TO ACT AS A SUPERVISOR AND GENERAL SECURITIES PRINCIPAL
WITHOUT THE REQUIRED SECURITIES PRINCIPAL QUALIFICATION (SERIES 24).