Oppenheimerfunds Inc.

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
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
INVESCO LTD
(For individuals, Last, First,
Middle)
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) 
FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/30/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
WA 17-WP 3120-2020/0003; WA 17-WP 3120-2020/0004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO LTD
6.
Principal Product Type:
Other
Other Product Types: 
THE MATTER RELATED TO OWNERSHIP FILINGS WITH THE GERMAN REGULATOR IN RELATION TO GERMAN LISTED COMPANIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE
REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD. ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS
REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING
TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS.
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:
Decision
11. Resolution Date (MM/DD/YYYY):
05/31/2021
 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: $ 309,595.00
 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: 
DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021
DEADLINE.
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).
BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS
BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.

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
CRD
Number:
125601
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO CAPITAL
MANAGEMENT LLC
(For individuals, Last, First,
Middle)
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) 
SECURITIES AND FUTURES COMMISSION OF KOREA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/29/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO CAPITAL MANAGEMENT LLC
6.
Principal Product Type:
Other
Other Product Types: 
EXCHANGED TRADED FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ALLEGATION IS THAT ON MARCH 19, 2021 THE FUND SOLD SECURITIES THAT WERE NOT IN CUSTODY IN VIOLATION OF KOREAN REGULATORY
PROHIBITIONS ON SHORT SALES.
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:
Decision
11. Resolution Date (MM/DD/YYYY):
01/09/2023
 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: $ 48,797.47
 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: 
IN DECEMBER 2022, THE SECURITIES AND FUTURES COMMISSION OF KOREA HAS FINED INVESCO CAPITAL MANAGEMENT LLC KRW 60 MILLION
($48,797.47 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON MARCH 19, 2021. INVESCO CAPITAL MANAGEMENT LLC PAID THE FINE
ON JANUARY 9, 2023.
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).
IN DECEMBER 2022, THE SECURITIES AND FUTURES COMMISSION OF KOREA IMPOSED A FINE OF AGAINST INVESCO CAPITAL MANAGEMENT LLC FOR
KRW 60 MILLION ($48,797.47 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON MARCH 19, 2021. INVESCO CAPITAL MANAGEMENT LLC
PAID THE FINE ON JANUARY 9, 2023.

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
CRD
Number:
7369
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO DISTRIBUTORS, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
105360
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO ADVISERS, INC.
(For individuals, Last, First,
Middle)
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) 
U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALTY/FINE, CENSURE, AND UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY): 
05/15/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-22165
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):
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN
ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW.
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:
Order
11. Resolution Date (MM/DD/YYYY):
09/24/2024
 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: $ 35,000,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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 SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") PAY A CIVIL MONETARY PENALTY OF $35
MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL
MONETARY PENALTY ON OCTOBER 1, 2024.
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).
ON SEPTEMBER 24, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF OPPENHEIMERFUNDS, INC. AND INVESCO
DISTRIBUTORS, INC. ("IDI"), AN AFFILIATED BROKER-DEALER (TOGETHER, WITH IAI, "INVESCO") HAVE ENTERED INTO A SETTLEMENT WITH THE U.S.
SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE MAINTENANCE AND
PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE
SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL
MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT
ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT
STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS, INCLUDING BY
ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE USE OF ELECTRONIC COMMUNICATIONS, AND
BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.

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
CRD
Number:
105360
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO ADVISERS, INC.
(For individuals, Last, First,
Middle)
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) 
U.S SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL AND ADMINISTRATIVE PENALTY AND CENSURE
3.
Date Initiated (MM/DD/YYYY): 
11/28/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-22306
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
ETFS AND SEPARATELY MANAGED ACCOUNTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF
COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS
CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED.
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:
Order
11. Resolution Date (MM/DD/YYYY):
11/08/2024
 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: $ 17,500,000.00
 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: 
THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL
MONETARY PENALTY ON NOVEMBER 14, 2024.
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).
ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF OPPENHEIMERFUNDS, INC., ENTERED INTO A
SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND
THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT
("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE
OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF
THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.

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
CRD
Number:
125601
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO CAPITAL
MANAGEMENT LLC
(For individuals, Last, First,
Middle)
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) 
SECURITIES AND FUTURES COMMISSION OF KOREA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/29/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO CAPITAL MANAGEMENT LLC
6.
Principal Product Type:
Other
Other Product Types: 
EXCHANGE TRADED FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ALLEGATION IS THAT ON JUNE 29, 2022 THE FUNDS SOLD SECURITIES THAT WERE NOT IN CUSTODY IN VIOLATION OF KOREAN REGULATORY
PROHIBITIONS ON SHORT SALES.
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:
Decision
11. Resolution Date (MM/DD/YYYY):
11/20/2025
 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: $ 375,000.00
 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: 
IN OCTOBER 2025, THE SECURITIES AND FUTURES COMMISSION OF KOREA FINED INVESCO CAPITAL MANAGEMENT LLC KRW 532,300,000
(EQUIVALENT TO APPROXIMATELY $375,000 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON JUNE 29, 2022. INVESCO CAPITAL
MANAGEMENT LLC PAID THE FINE ON NOVEMBER 20, 2025.
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).
IN OCTOBER 2025, THE SECURITIES AND FUTURES COMMISSION OF KOREA FINED INVESCO CAPITAL MANAGEMENT LLC KRW 532,300,000
(EQUIVALENT TO APPROXIMATELY $375,000 USD) FOR THE VIOLATION OF SHORT SALE RESTRICTIONS ON JUNE 29, 2022. INVESCO CAPITAL
MANAGEMENT LLC PAID THE FINE ON NOVEMBER 20, 2025.