Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Trustmont Advisory Group, Inc..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Trustmont Advisory Group, Inc...
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-03-30 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | PETER DANIEL DOCHINEZOWNERIndividual | TRUSTMONT ADVISORY GROUP, INC. | 50% to less than 75%Code D | Yes | OWNER12/1997 | Schedule APDF page 33 |
| 2 | LAURA JEAN ABBOTT DECAROLISOWNER/REGISTERED REPRESENTATIVEIndividual | TRUSTMONT ADVISORY GROUP, INC. | Less than 5%Code NA | No | OWNER/REGISTERED REPRESENTATIVE01/2001 | Schedule APDF page 33 |
| 3 | GEORGE PHILLIP HEBERTOWNERIndividual | TRUSTMONT ADVISORY GROUP, INC. | Less than 5%Code NA | No | OWNER01/2001 | Schedule APDF page 33 |
| 4 | ANTHONY CHARLES HLADEKPRESIDENTIndividual | TRUSTMONT ADVISORY GROUP, INC. | 10% to less than 25%Code B | Yes | PRESIDENT04/2007 | Schedule APDF page 33 |
| 5 | MARY LYNNE HIXENBAUGHCHIEF COMPLIANCE OFFICERIndividual | TRUSTMONT ADVISORY GROUP, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER10/2018 | Schedule APDF page 34 |
| 6 | JAMES DANIEL AULTOWNER/REGISTERED REPRESENTATIVEIndividual | TRUSTMONT ADVISORY GROUP, INC. | Less than 5%Code NA | No | OWNER/REGISTERED REPRESENTATIVE12/2019 | Schedule APDF page 34 |
| 7 | DONALD JOHN BARZAKOWNER/REGISTERED REPRESENTATIVEIndividual | TRUSTMONT ADVISORY GROUP, INC. | Less than 5%Code NA | No | OWNER/REGISTERED REPRESENTATIVE12/2019 | Schedule APDF page 34 |
| 8 | LACEY M DOCHINEZDIRECTORIndividual | TRUSTMONT ADVISORY GROUP, INC. | 5% to less than 10%Code A | No | DIRECTOR12/2022 | Schedule APDF page 34 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 3/30/2026 10:06:43 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions5 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 1 source block
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1DOCHINEZ, PETER, DANIELPDF pages 34–37
- Advisory affiliate name — filed text
- DOCHINEZ, PETER, DANIEL
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FINRA RULE 2010, NASD RULES 2110, 3011(C), 3012, MSRB RULE G-27: A MEMBER FIRM, ACTING THROUGH DOCHINEZ, THE FIRM'S PRESIDENT, CHIEF EXECUTIVE OFFICER (CEO) AND PRINCIPAL, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT (A) TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES WERE REASONABLY DESIGNED WITH RESPECT TO THE ACTIVITIES OF THE FIRM AND ITS REGISTERED REPRESENTATIVES AND ASSOCIATED PERSONS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND (B) CREATED ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES WHERE THE NEED WAS IDENTIFIED BY SUCH TESTING AND VERIFICATION. SPECIFICALLY, THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES FAILED TO ADDRESS THESE REQUIREMENTS: DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES; TESTING AND VERIFICATION TO ENSURE REASONABLY-DESIGNED SUPERVISORY PROCEDURES; UPDATING THE FIRM'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS DEFICIENCIES NOTED DURING TESTING; DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE ANNUAL REPORT TO SENIOR MANAGEMENT ON THE FIRM'S SYSTEM OF SUPERVISORY CONTROLS PROCEDURES, SUMMARY OF TEST RESULTS, SIGNIFICANT IDENTIFIED EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED PROCEDURES; IDENTIFYING PRODUCING MANAGERS AND ASSIGNING QUALIFIED PRINCIPALS TO SUPERVISE SUCH MANAGERS; USING THE "LIMITED SIZE AND RESOURCES" EXCEPTION FOR PRODUCING MANAGERS' SUPERVISION, INCLUDING DOCUMENTING THE FACTORS RELIED ON IN DETERMINING THAT THE EXCEPTION IS NECESSARY; ELECTRONICALLY NOTIFYING FINRA OF ITS RELIANCE ON THE "LIMITED SIZE AND RESOURCES" EXCEPTION; REVIEWING AND MONITORING ALL TRANSMITTALS OF CUSTOMER FUNDS AND SECURITIES; REVIEWING, MONITORING AND VALIDATING CUSTOMER CHANGES OF ADDRESS AND CUSTOMER CHANGES OF INVESTMENT OBJECTIVES; AND PROVIDING HEIGHTENED SUPERVISION OVER THE ACTIVITIES OF EACH PRODUCING MANAGER. IN ADDITION, THE FIRM, ACTING THROUGH DOCHINEZ, FAILED TO CONDUCT INDEPENDENT TESTS OF THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM (AMLCP) IN 2007 AND 2008, AS REQUIRED BY NASD RULE 3011.
Other filed details
Description of allegations — filed text
FINRA RULE 2010, NASD RULES 2110, 3011(C), 3012, MSRB RULE G-27: A MEMBER FIRM, ACTING THROUGH DOCHINEZ, THE FIRM'S PRESIDENT, CHIEF EXECUTIVE OFFICER (CEO) AND PRINCIPAL, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT (A) TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES WERE REASONABLY DESIGNED WITH RESPECT TO THE ACTIVITIES OF THE FIRM AND ITS REGISTERED REPRESENTATIVES AND ASSOCIATED PERSONS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND (B) CREATED ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES WHERE THE NEED WAS IDENTIFIED BY SUCH TESTING AND VERIFICATION. SPECIFICALLY, THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES FAILED TO ADDRESS THESE REQUIREMENTS: DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES; TESTING AND VERIFICATION TO ENSURE REASONABLY-DESIGNED SUPERVISORY PROCEDURES; UPDATING THE FIRM'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS DEFICIENCIES NOTED DURING TESTING; DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE ANNUAL REPORT TO SENIOR MANAGEMENT ON THE FIRM'S SYSTEM OF SUPERVISORY CONTROLS PROCEDURES, SUMMARY OF TEST RESULTS, SIGNIFICANT IDENTIFIED EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED PROCEDURES; IDENTIFYING PRODUCING MANAGERS AND ASSIGNING QUALIFIED PRINCIPALS TO SUPERVISE SUCH MANAGERS; USING THE "LIMITED SIZE AND RESOURCES" EXCEPTION FOR PRODUCING MANAGERS' SUPERVISION, INCLUDING DOCUMENTING THE FACTORS RELIED ON IN DETERMINING THAT THE EXCEPTION IS NECESSARY; ELECTRONICALLY NOTIFYING FINRA OF ITS RELIANCE ON THE "LIMITED SIZE AND RESOURCES" EXCEPTION; REVIEWING AND MONITORING ALL TRANSMITTALS OF CUSTOMER FUNDS AND SECURITIES; REVIEWING, MONITORING AND VALIDATING CUSTOMER CHANGES OF ADDRESS AND CUSTOMER CHANGES OF INVESTMENT OBJECTIVES; AND PROVIDING HEIGHTENED SUPERVISION OVER THE ACTIVITIES OF EACH PRODUCING MANAGER. IN ADDITION, THE FIRM, ACTING THROUGH DOCHINEZ, FAILED TO CONDUCT INDEPENDENT TESTS OF THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM (AMLCP) IN 2007 AND 2008, AS REQUIRED BY NASD RULE 3011.
Sanction detail — filed text
IF DISPOSITION RESULTED IN A FINE, PENALTY, RESTITUTION, DISGORGEMENT OR MONETARY COMPENSATION, PROVIDE: MONETARY RELATED SANCTION TYPE: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) TOTAL AMOUNT: $ 10,000.00 PORTION LEVIED AGAINST THE SUBJECT: $ 10,000.00 PAYMENT PLAN: IS PAYMENT PLAN CURRENT? RADIO BUTTON NOT SELECTED YES RADIO BUTTON NOT SELECTED NO DATE PAID BY THE SUBJECT (MM/DD/YYYY): 06/21/2011 RADIO BUTTON SELECTED EXACT RADIO BUTTON NOT SELECTED EXPLANATION IF NOT EXACT, PROVIDE EXPLANATION: WAS ANY PORTION OF PENALTY WAIVED? RADIO BUTTON NOT SELECTED YES RADIO BUTTON SELECTED NO
Full extracted filing text
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: 1062112 This advisory affiliate is a Firm an Individual Registered: Yes No Name: DOCHINEZ, PETER, DANIEL (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) 2. Principal Sanction: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 06/06/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2009016311801 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): TRUSTMONT FINANCIAL GROUP, INC. 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): FINRA RULE 2010, NASD RULES 2110, 3011(C), 3012, MSRB RULE G-27: A MEMBER FIRM, ACTING THROUGH DOCHINEZ, THE FIRM'S PRESIDENT, CHIEF EXECUTIVE OFFICER (CEO) AND PRINCIPAL, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT (A) TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES WERE REASONABLY DESIGNED WITH RESPECT TO THE ACTIVITIES OF THE FIRM AND ITS REGISTERED REPRESENTATIVES AND ASSOCIATED PERSONS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND (B) CREATED ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES WHERE THE NEED WAS IDENTIFIED BY SUCH TESTING AND VERIFICATION. SPECIFICALLY, THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES FAILED TO ADDRESS THESE REQUIREMENTS: DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES; TESTING AND VERIFICATION TO ENSURE REASONABLY-DESIGNED SUPERVISORY PROCEDURES; UPDATING THE FIRM'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS DEFICIENCIES NOTED DURING TESTING; DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE ANNUAL REPORT TO SENIOR MANAGEMENT ON THE FIRM'S SYSTEM OF SUPERVISORY CONTROLS PROCEDURES, SUMMARY OF TEST RESULTS, SIGNIFICANT IDENTIFIED EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED PROCEDURES; IDENTIFYING PRODUCING MANAGERS AND ASSIGNING QUALIFIED PRINCIPALS TO SUPERVISE SUCH MANAGERS; USING THE "LIMITED SIZE AND RESOURCES" EXCEPTION FOR PRODUCING MANAGERS' SUPERVISION, INCLUDING DOCUMENTING THE FACTORS RELIED ON IN DETERMINING THAT THE EXCEPTION IS NECESSARY; ELECTRONICALLY NOTIFYING FINRA OF ITS RELIANCE ON THE "LIMITED SIZE AND RESOURCES" EXCEPTION; REVIEWING AND MONITORING ALL TRANSMITTALS OF CUSTOMER FUNDS AND SECURITIES; REVIEWING, MONITORING AND VALIDATING CUSTOMER CHANGES OF ADDRESS AND CUSTOMER CHANGES OF INVESTMENT OBJECTIVES; AND PROVIDING HEIGHTENED SUPERVISION OVER THE ACTIVITIES OF EACH PRODUCING MANAGER. IN ADDITION, THE FIRM, ACTING THROUGH DOCHINEZ, FAILED TO CONDUCT INDEPENDENT TESTS OF THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM (AMLCP) IN 2007 AND 2008, AS REQUIRED BY NASD RULE 3011. 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): 06/06/2011 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) 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: IF DISPOSITION RESULTED IN A FINE, PENALTY, RESTITUTION, DISGORGEMENT OR MONETARY COMPENSATION, PROVIDE: MONETARY RELATED SANCTION TYPE: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) TOTAL AMOUNT: $ 10,000.00 PORTION LEVIED AGAINST THE SUBJECT: $ 10,000.00 PAYMENT PLAN: IS PAYMENT PLAN CURRENT? RADIO BUTTON NOT SELECTED YES RADIO BUTTON NOT SELECTED NO DATE PAID BY THE SUBJECT (MM/DD/YYYY): 06/21/2011 RADIO BUTTON SELECTED EXACT RADIO BUTTON NOT SELECTED EXPLANATION IF NOT EXACT, PROVIDE EXPLANATION: WAS ANY PORTION OF PENALTY WAIVED? RADIO BUTTON NOT SELECTED YES RADIO BUTTON SELECTED NO 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). FINRA RULE 2010, NASD RULES 2110, 3011(C), 3012, MSRB RULE G-27: A MEMBER FIRM, ACTING THROUGH DOCHINEZ, THE FIRM'S PRESIDENT, CHIEF EXECUTIVE OFFICER (CEO) AND PRINCIPAL, FAILED TO ESTABLISH, MAINTAIN AND ENFORCE AN ADEQUATE SYSTEM OF SUPERVISORY CONTROL POLICIES AND PROCEDURES THAT (A) TESTED AND VERIFIED THAT ITS SUPERVISORY PROCEDURES WERE REASONABLY DESIGNED WITH RESPECT TO THE ACTIVITIES OF THE FIRM AND ITS REGISTERED REPRESENTATIVES AND ASSOCIATED PERSONS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS AND (B) CREATED ADDITIONAL OR AMENDED SUPERVISORY PROCEDURES WHERE THE NEED WAS IDENTIFIED BY SUCH TESTING AND VERIFICATION. SPECIFICALLY, THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES FAILED TO ADDRESS THESE REQUIREMENTS: DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE FIRM'S SUPERVISORY CONTROL POLICIES AND PROCEDURES; TESTING AND VERIFICATION TO ENSURE REASONABLY-DESIGNED SUPERVISORY PROCEDURES; UPDATING THE FIRM'S WRITTEN SUPERVISORY PROCEDURES TO ADDRESS DEFICIENCIES NOTED DURING TESTING; DESIGNATING A PRINCIPAL RESPONSIBLE FOR THE ANNUAL REPORT TO SENIOR MANAGEMENT ON THE FIRM'S SYSTEM OF SUPERVISORY CONTROLS PROCEDURES, SUMMARY OF TEST RESULTS, SIGNIFICANT IDENTIFIED EXCEPTIONS, AND ANY ADDITIONAL OR AMENDED PROCEDURES; IDENTIFYING PRODUCING MANAGERS AND ASSIGNING QUALIFIED PRINCIPALS TO SUPERVISE SUCH MANAGERS; USING THE "LIMITED SIZE AND RESOURCES" EXCEPTION FOR PRODUCING MANAGERS' SUPERVISION, INCLUDING DOCUMENTING THE FACTORS RELIED ON IN DETERMINING THAT THE EXCEPTION IS NECESSARY; ELECTRONICALLY NOTIFYING FINRA OF ITS RELIANCE ON THE "LIMITED SIZE AND RESOURCES" EXCEPTION; REVIEWING AND MONITORING ALL TRANSMITTALS OF CUSTOMER FUNDS AND SECURITIES; REVIEWING, MONITORING AND VALIDATING CUSTOMER CHANGES OF ADDRESS AND CUSTOMER CHANGES OF INVESTMENT OBJECTIVES; AND PROVIDING HEIGHTENED SUPERVISION OVER THE ACTIVITIES OF EACH PRODUCING MANAGER. IN ADDITION, THE FIRM, ACTING THROUGH DOCHINEZ, FAILED TO CONDUCT INDEPENDENT TESTS OF THE FIRM'S ANTI-MONEY LAUNDERING COMPLIANCE PROGRAM (AMLCP) IN 2007 AND 2008, AS REQUIRED BY NASD RULE 3011.
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