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 Blackrock Realty Advisors 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 Blackrock Realty Advisors Inc..
Reported ownership and control details
Form ADV · Filing date 2026-07-24 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | BLACKROCK FINANCIAL MANAGEMENT, INCSTOCKHOLDERDomestic entity | BLACKROCK REALTY ADVISORS INC | 75% or moreCode E | Yes | STOCKHOLDER07/2011 | Schedule APDF page 286 |
| 2 | MARC DAVID COMERCHEROTREASURERIndividual | BLACKROCK REALTY ADVISORS INC | Less than 5%Code NA | Yes | TREASURER03/2018 | Schedule APDF page 286 |
| 3 | CHARLES CHOON SIK PARKCHIEF COMPLIANCE OFFICERIndividual | BLACKROCK REALTY ADVISORS INC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER03/2019 | Schedule APDF page 286 |
| 4 | BLACKROCK FINANCE, INC.SOLE SHAREHOLDERDomestic entity | BLACKROCK HOLDCO 2, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER09/2006 | Schedule BPDF page 287 |
| 5 | BLACKROCK HOLDCO 2, INC.SOLE SHAREHOLDERDomestic entity | BLACKROCK FINANCIAL MANAGEMENT, INC | 75% or moreCode E | Yes | SOLE SHAREHOLDER09/2006 | Schedule BPDF page 287 |
| 6 | BLACKROCK, INC.MEMBERDomestic entity | BLACKROCK SATURN SUBCO, LLC | 75% or moreCode E | Yes | MEMBER07/2025 | Schedule BPDF page 287 |
| 7 | BLACKROCK SATURN SUBCO, LLCSOLE SHAREHOLDERDomestic entity | BLACKROCK FINANCE, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER07/2025 | Schedule BPDF page 287 |
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 7/24/2026 2:28:26 PM
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 actions3 Yes2 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?Yes
- 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?Yes
- 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?Yes
DOther regulatory actions2 Yes3 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?Yes
- 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?Yes
- 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 Yes
- 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?Yes
HCivil judicial actions and proceedings2 Yes2 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?Yes
(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)?Yes
Additional DRP filings 15 source blocks
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 1BLACKROCK, INC.PDF pages 287–289
- Advisory affiliate name — filed text
- BLACKROCK, INC.
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 340,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON JANUARY 17, 2017, BLACKROCK INC. REACHED AN AGREEMENT WITH THE SEC TO RESOLVE ALLEGATIONS THAT A HISTORIC VERSION OF BLACKROCK'S FORM EMPLOYEE SEPARATION AND RELEASE AGREEMENT ("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE SETTLEMENT WITH THE SEC INCLUDED A $340,000 PAYMENT, WHICH WAS PAID ON JANUARY 25, 2017. BLACKROCK ALSO AGREED TO NOTIFY FORMER EMPLOYEES WHO SIGNED AN AGREEMENT TO ADVISE THEM THAT BLACKROCK DOES NOT PREVENT FORMER EMPLOYEES FROM COLLECTING A MONETARY AWARD FOR REPORTING INFORMATION TO THE SEC UNDER ITS WHISTLEBLOWER PROGRAM.
Other filed details
Description of allegations — filed text
THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") FOUND THAT A HISTORIC VERSION OF BLACKROCK INC.'S ("BLACKROCK") FORM EMPLOYEE SEPARATION AND RELEASE AGREEMENT ("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE AGREEMENT, WHICH WAS IN USE BETWEEN OCTOBER 2011 AND MARCH 2016, DID NOT PROHIBIT FORMER EMPLOYEES FROM REPORTING ALLEGED WRONGDOING TO THE SEC. HOWEVER, EMPLOYEES WHO ACCEPTED A VOLUNTARY SEPARATION PAYMENT FROM BLACKROCK WAIVED THEIR RIGHT TO RECOVER A MONETARY REWARD FROM THE SEC IN CONNECTION WITH ITS WHISTLEBLOWING PROGRAM. BLACKROCK STOPPED USING THE AGREEMENT AT ISSUE BEFORE BEING CONTACTED BY THE SEC AND THE SEC WAS UNAWARE OF ANY INSTANCES IN WHICH FORMER BLACKROCK EMPLOYEES WERE PREVENTED FROM COMMUNICATING WITH THE SEC.
Sanction detail — filed text
BLACKROCK PAID THE $340,000 CIVIL MONETARY PENALTY ON JANUARY 25, 2017.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CEASE AND DESIST UNDERTAKING
3.
Date Initiated (MM/DD/YYYY):
01/17/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17786
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:
yp
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") FOUND THAT A HISTORIC VERSION OF BLACKROCK INC.'S ("BLACKROCK") FORM EMPLOYEE SEPARATION AND RELEASE AGREEMENT
("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE AGREEMENT, WHICH WAS IN USE
BETWEEN OCTOBER 2011 AND MARCH 2016, DID NOT PROHIBIT FORMER EMPLOYEES FROM REPORTING ALLEGED WRONGDOING TO THE SEC. HOWEVER, EMPLOYEES WHO ACCEPTED A
VOLUNTARY SEPARATION PAYMENT FROM BLACKROCK WAIVED THEIR RIGHT TO RECOVER A MONETARY REWARD FROM THE SEC IN CONNECTION WITH ITS WHISTLEBLOWING PROGRAM.
BLACKROCK STOPPED USING THE AGREEMENT AT ISSUE BEFORE BEING CONTACTED BY THE SEC AND THE SEC WAS UNAWARE OF ANY INSTANCES IN WHICH FORMER BLACKROCK EMPLOYEES
WERE PREVENTED FROM COMMUNICATING WITH THE SEC.
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):
01/25/2017
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: $ 340,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
BLACKROCK AGREED TO NOTIFY FORMER EMPLOYEES WHO SIGNED AN AGREEMENT TO ADVISE THEM THAT BLACKROCK DOES NOT PREVENT FORMER EMPLOYEES FROM COLLECTING A
MONETARY AWARD FOR REPORTING INFORMATION TO THE SEC UNDER ITS WHISTLEBLOWER PROGRAM.
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:
BLACKROCK PAID THE $340,000 CIVIL MONETARY PENALTY ON JANUARY 25, 2017.
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 JANUARY 17, 2017, BLACKROCK INC. REACHED AN AGREEMENT WITH THE SEC TO RESOLVE ALLEGATIONS THAT A HISTORIC VERSION OF BLACKROCK'S FORM EMPLOYEE SEPARATION AND
RELEASE AGREEMENT ("AGREEMENT") VIOLATED DODD FRANK'S WHISTLEBLOWER PROVISIONS, (RULE 21F-17 UNDER THE SECURITIES AND EXCHANGE ACT OF 1934). THE SETTLEMENT WITH
THE SEC INCLUDED A $340,000 PAYMENT, WHICH WAS PAID ON JANUARY 25, 2017. BLACKROCK ALSO AGREED TO NOTIFY FORMER EMPLOYEES WHO SIGNED AN AGREEMENT TO ADVISE THEM
THAT BLACKROCK DOES NOT PREVENT FORMER EMPLOYEES FROM COLLECTING A MONETARY AWARD FOR REPORTING INFORMATION TO THE SEC UNDER ITS WHISTLEBLOWER PROGRAM.regulatory · block 2BLACKROCK, INC.PDF pages 289–291
- Advisory affiliate name — filed text
- BLACKROCK, INC.
- Regulator name — filed text
- CHICAGO BOARD OF TRADE
- Monetary/Fine Amount — filed text
- $ 119,605.60
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH BLACKROCK INC. NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, ON JULY 26, 2021, A PANEL OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON NOVEMBER 12, 2019, AND NOVEMBER 13, 2019, BLACKROCK-MANAGED ACCOUNTS HELD AN ALL MONTHS COMBINED CBOT SOYBEAN MEAL POSITION THAT EXCEEDED THE ALL MONTHS POSITION LIMIT ON AN END OF DAY AND INTRADAY BASIS. SPECIFICALLY, BLACKROCK- MANAGED ACCOUNTS HELD AN AGGREGATE POSITION OF 6,919 CONTRACTS LONG ON NOVEMBER 12, AND 6,920 CONTRACTS LONG ON NOVEMBER 13, 2019. THIS EXCEEDED THE ALL MONTHS COMBINED POSITION LIMIT FOR SOYBEAN MEAL BY 419 CONTRACTS, OR 6.45%, ON NOVEMBER 12, AND BY 420 CONTRACTS, OR 6.46%, ON NOVEMBER 13. BLACKROCK RECOGNIZED THE OVERAGE ON NOVEMBER 13, AND ATTEMPTED TO REDUCE ITS POSITION VIA AN EXCHANGE FOR RISK ("EFR") TRANSACTION, BUT WAS UNABLE TO EXECUTE THE TRADE ON THAT DAY. HOWEVER, ON THE MORNING OF NOVEMBER 14, 2019, BLACKROCK EXECUTED THE EFR AND BROUGHT THE ACCOUNTS' POSITIONS INTO COMPLIANCE, WHICH RESULTED IN A TOTAL MONETARY BENEFIT OF $99,605.60 TO THE ACCOUNTS. THE PANEL CONCLUDED THAT BLACKROCK THEREBY VIOLATED CBOT RULE 562. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF $99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021.
Other filed details
Description of allegations — filed text
THE CME CONCLUDED THAT BLACKROCK VIOLATED CHICAGO BOARD OF TRADE (CBOT) RULE 562, WHICH PROHIBITS FIRMS FROM HOLDING POSITIONS ON THE CME LARGER THAN THE LIMITS PROSCRIBED BY CME RULES.
Sanction detail — filed text
IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF $99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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)
CHICAGO BOARD OF TRADE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY):
01/22/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CBOT 19-1230-BC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Futures - Commodity
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CME CONCLUDED THAT BLACKROCK VIOLATED CHICAGO BOARD OF TRADE (CBOT) RULE 562, WHICH PROHIBITS FIRMS FROM HOLDING POSITIONS ON THE CME LARGER THAN THE LIMITS
PROSCRIBED BY CME RULES.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
07/28/2021
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: $ 119,605.60
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 ACCORDANCE WITH THE SETTLEMENT OFFER, THE PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF
$99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021.
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).
PURSUANT TO AN OFFER OF SETTLEMENT IN WHICH BLACKROCK INC. NEITHER ADMITTED NOR DENIED THE RULE VIOLATION UPON WHICH THE PENALTY IS BASED, ON JULY 26, 2021, A PANEL
OF THE CHICAGO BOARD OF TRADE ("CBOT") BUSINESS CONDUCT COMMITTEE ("PANEL") FOUND THAT ON NOVEMBER 12, 2019, AND NOVEMBER 13, 2019, BLACKROCK-MANAGED ACCOUNTS
HELD AN ALL MONTHS COMBINED CBOT SOYBEAN MEAL POSITION THAT EXCEEDED THE ALL MONTHS POSITION LIMIT ON AN END OF DAY AND INTRADAY BASIS. SPECIFICALLY, BLACKROCK-
MANAGED ACCOUNTS HELD AN AGGREGATE POSITION OF 6,919 CONTRACTS LONG ON NOVEMBER 12, AND 6,920 CONTRACTS LONG ON NOVEMBER 13, 2019. THIS EXCEEDED THE ALL MONTHS
COMBINED POSITION LIMIT FOR SOYBEAN MEAL BY 419 CONTRACTS, OR 6.45%, ON NOVEMBER 12, AND BY 420 CONTRACTS, OR 6.46%, ON NOVEMBER 13. BLACKROCK RECOGNIZED THE
OVERAGE ON NOVEMBER 13, AND ATTEMPTED TO REDUCE ITS POSITION VIA AN EXCHANGE FOR RISK ("EFR") TRANSACTION, BUT WAS UNABLE TO EXECUTE THE TRADE ON THAT DAY.
HOWEVER, ON THE MORNING OF NOVEMBER 14, 2019, BLACKROCK EXECUTED THE EFR AND BROUGHT THE ACCOUNTS' POSITIONS INTO COMPLIANCE, WHICH RESULTED IN A TOTAL
MONETARY BENEFIT OF $99,605.60 TO THE ACCOUNTS. THE PANEL CONCLUDED THAT BLACKROCK THEREBY VIOLATED CBOT RULE 562. IN ACCORDANCE WITH THE SETTLEMENT OFFER, THE
PANEL ORDERED BLACKROCK TO PAY A FINE IN THE AMOUNT OF $20,000 AND ORDERED DISGORGEMENT IN THE AMOUNT OF $99,605.60 WHICH BLACKROCK PAID ON JULY 29TH, 2021.regulatory · block 3BLACKROCK, INCPDF pages 291–293
- Advisory affiliate name — filed text
- BLACKROCK, INC
- Regulator name — filed text
- FINANSINSPEKTIONEN - SWEDISH FINANCIAL SERVICES AUTHORITY ("SFSA")
- Monetary/Fine Amount — filed text
- $ 2,020.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
BIM UK PAID THE SPECIAL FEE TO THE SFSA ON SEPTEMBER 20, 2018.
Other filed details
Description of allegations — filed text
BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED ("BIM UK") IS REQUIRED TO REPORT TO THE SWEDISH FINANCIAL SERVICES AUTHORITY ("SFSA"), WITHIN A SPECIFIED TIME PERIOD, ITS HOLDINGS IN LISTED ISSUERS WHERE THOSE HOLDINGS CROSS A CERTAIN THRESHOLD ("NOTIFICATIONS"). ON MAY 5, 2017, AN EXTERNAL VENDOR WAS UNABLE TO PROVIDE ACCURATE DATA RESULTING IN APPROXIMATELY A 5 MINUTE DELAY IN BIM UK'S SUBMISSION OF CERTAIN SHORT SELLING NOTIFICATIONS TO THE SFSA. THE SFSA WAS INFORMED IN ADVANCE OF THE FILING DEADLINE OF THE LIKELIHOOD OF A DELAY TO THE SUBMISSION OF CERTAIN SHORT SELLING NOTIFICATIONS. IN SEPTEMBER 2017, BIM UK RESPONDED TO AN INQUIRY FROM THE SFSA REGARDING THE LATE SUBMISSION ON MAY 5, 2017 OF SHORT SELLING NOTIFICATIONS FOR THREE LISTED ISSUERS (I.E., BYGGMAX GROUP AB, JM AB AND MYCRONIC AB). THAT RESPONSE EXPLAINED THE CIRCUMSTANCES AND NOTED THAT THE ISSUE AROSE AS A RESULT OF INACCURATE DATA RECEIVED FROM AN EXTERNAL DATA VENDOR. THE SWEDISH FSA TOOK A STRICT APPROACH TO THE INTERPRETATION OF THE REQUIREMENT TO SUBMIT THE NOTIFICATIONS ON TIME AND IMPOSED A SPECIAL FEE ON BIM UK FOR EACH OF THE THREE LATE NOTIFICATIONS.
Sanction detail — filed text
ON MAY 31, 2018, BIM UK LIMITED RECEIVED THREE LETTERS IMPOSING A SPECIAL FEE FOR EACH OF THE LATE SHORT SELLING NOTIFICATIONS. INVOICE(S) TOTALING 17,300 SEK (APPROXIMATELY $2020 USD) WERE RECEIVED ON AUGUST 21, 2018 FOR THE SPECIAL FEE(S).
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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)
FINANSINSPEKTIONEN - SWEDISH FINANCIAL SERVICES AUTHORITY ("SFSA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
05/31/2018
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):
6.
Principal Product Type:
Other
Other Product Types:
INVESTMENT IN SWEDISH EQUITY
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED ("BIM UK") IS REQUIRED TO REPORT TO THE SWEDISH FINANCIAL SERVICES AUTHORITY ("SFSA"), WITHIN A SPECIFIED TIME PERIOD, ITS
HOLDINGS IN LISTED ISSUERS WHERE THOSE HOLDINGS CROSS A CERTAIN THRESHOLD ("NOTIFICATIONS"). ON MAY 5, 2017, AN EXTERNAL VENDOR WAS UNABLE TO PROVIDE ACCURATE
DATA RESULTING IN APPROXIMATELY A 5 MINUTE DELAY IN BIM UK'S SUBMISSION OF CERTAIN SHORT SELLING NOTIFICATIONS TO THE SFSA. THE SFSA WAS INFORMED IN ADVANCE OF THE
FILING DEADLINE OF THE LIKELIHOOD OF A DELAY TO THE SUBMISSION OF CERTAIN SHORT SELLING NOTIFICATIONS. IN SEPTEMBER 2017, BIM UK RESPONDED TO AN INQUIRY FROM THE
SFSA REGARDING THE LATE SUBMISSION ON MAY 5, 2017 OF SHORT SELLING NOTIFICATIONS FOR THREE LISTED ISSUERS (I.E., BYGGMAX GROUP AB, JM AB AND MYCRONIC AB). THAT
RESPONSE EXPLAINED THE CIRCUMSTANCES AND NOTED THAT THE ISSUE AROSE AS A RESULT OF INACCURATE DATA RECEIVED FROM AN EXTERNAL DATA VENDOR. THE SWEDISH FSA TOOK A
STRICT APPROACH TO THE INTERPRETATION OF THE REQUIREMENT TO SUBMIT THE NOTIFICATIONS ON TIME AND IMPOSED A SPECIAL FEE ON BIM UK FOR EACH OF THE THREE LATE
NOTIFICATIONS.
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):
09/20/2018
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: $ 2,020.00
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:
ON MAY 31, 2018, BIM UK LIMITED RECEIVED THREE LETTERS IMPOSING A SPECIAL FEE FOR EACH OF THE LATE SHORT SELLING NOTIFICATIONS. INVOICE(S) TOTALING 17,300 SEK
(APPROXIMATELY $2020 USD) WERE RECEIVED ON AUGUST 21, 2018 FOR THE SPECIAL FEE(S).
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).
BIM UK PAID THE SPECIAL FEE TO THE SFSA ON SEPTEMBER 20, 2018.regulatory · block 4BLACKROCK, INCPDF pages 293–294
- Advisory affiliate name — filed text
- BLACKROCK, INC
- Regulator name — filed text
- FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
- Monetary/Fine Amount — filed text
- $ 801,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
ON APRIL 20, 2020 BAFIN (THE GERMAN FINANCIAL REGULATOR) REACHED A DECISION TO IMPOSE A SANCTION OF 744.000 EURO ($801,000 USD) AGAINST BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED FOR APPROXIMATELY 180 INCORRECT THRESHOLDS FILINGS BETWEEN AUGUST 2018 AND OCTOBER 2018 FOLLOWING BREXIT RESTRUCTURING. THRESHOLD INFORMATION EPORTED AT THE AGGREGATE BLACKROCK, INC. LEVEL WAS CORRECT, AND THE MARKET WAS NOT MISLED. THE SANCTION WAS PAID ON MAY 11, 2020.
Other filed details
Description of allegations — filed text
BAFIN (THE GERMAN FINANCIAL REGULATOR) REACHED A DECISION AGAINST BIM UK FOR APPROXIMATELY 180 INCORRECT THRESHOLDS FILINGS BETWEEN AUGUST 2018 AND OCTOBER 2018 FOLLOWING BREXIT RESTRUCTURING.
Sanction detail — filed text
DECISION TO IMPOSE A 744.000 EURO ($801,000 USD) SANCTION AGAINST BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED WHICH WAS PAID ON MAY 11, 2020.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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)
FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
04/20/2020
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):
6.
Principal Product Type:
Other
Other Product Types:
THE MATTER RELATED TO OWNERSHIP FILINGS WITH THE GERMAN REGULATOR IN RELATION TO GERMAN LISTED ENTITIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
BAFIN (THE GERMAN FINANCIAL REGULATOR) REACHED A DECISION AGAINST BIM UK FOR APPROXIMATELY 180 INCORRECT THRESHOLDS FILINGS BETWEEN AUGUST 2018 AND OCTOBER 2018
FOLLOWING BREXIT RESTRUCTURING.
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):
05/11/2020
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: $ 801,000.00
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:
DECISION TO IMPOSE A 744.000 EURO ($801,000 USD) SANCTION AGAINST BLACKROCK INVESTMENT MANAGEMENT (UK) LIMITED WHICH WAS PAID ON MAY 11, 2020.
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 APRIL 20, 2020 BAFIN (THE GERMAN FINANCIAL REGULATOR) REACHED A DECISION TO IMPOSE A SANCTION OF 744.000 EURO ($801,000 USD) AGAINST BLACKROCK INVESTMENT
MANAGEMENT (UK) LIMITED FOR APPROXIMATELY 180 INCORRECT THRESHOLDS FILINGS BETWEEN AUGUST 2018 AND OCTOBER 2018 FOLLOWING BREXIT RESTRUCTURING. THRESHOLD
INFORMATION EPORTED AT THE AGGREGATE BLACKROCK, INC. LEVEL WAS CORRECT, AND THE MARKET WAS NOT MISLED. THE SANCTION WAS PAID ON MAY 11, 2020.regulatory · block 5BLACKROCK, INCPDF pages 295–296
- Advisory affiliate name — filed text
- BLACKROCK, INC
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION ("SEC")
- Monetary/Fine Amount — filed text
- $ 1,500,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
"ON APRIL 25, 2017, BFA REACHED AN AGREEMENT WITH THE SEC RESOLVING THE MATTER REGARDING THE RUSSIA FUND ETF. BFA, WHICH DID NOT ADMIT OR DENY ANY OF THE SEC'S FINDINGS, AGREED TO RESOLVE THE MATTER FOR A CIVIL MONETARY PENALTY OF $1,500,000."
Other filed details
Description of allegations — filed text
"THE ORDER SPECIFICALLY CONCERNS THE ISHARES MSCI RUSSIA CAPPED ETF (""RUSSIA FUND ETF""), MANAGED BY BLACKROCK FUND ADVISORS (""BFA"") AND WHETHER IT WAS COVERED BY EXISTING EXEMPTIVE RELIEF GRANTED BY SECURITIES AND EXCHANGE COMMISSION (""SEC""). IN 2010, THE RUSSIA FUND ETF BEGAN SELLING ITS SHARES AS THE ONLY SERIES OF SHARES OF ISHARES MSCI RUSSIA CAPPED ETF, INC. (""RUSSIA FUND COMPANY""). THE RUSSIA FUND COMPANY DID NOT HAVE THE REQUIRED EXEMPTIVE RELIEF UNTIL JANUARY 2015. ACCORDINGLY, BY OPERATING THE RUSSIA FUND ETF FROM DECEMBER 2010 TO JANUARY 2015, BFA CAUSED THE RUSSIA FUND COMPANY TO VIOLATE THE INVESTMENT COMPANY ACT."
Sanction detail — filed text
A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000 WAS PAID ON APRIL 28, 2017
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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)
SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
PURSUANT TO THE SECURITIES AND EXCHANGE COMMISSION'S ORDER DATED APRIL 25, 2017 (THE "ORDER"), BLACKROCK FUND ADVISORS ("BFA") IS TO CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 22(D), AND (E) OF THE INVESTMENT COMPANY ACT AND RULE 22C- 1 THEREUNDER.
3.
Date Initiated (MM/DD/YYYY):
04/25/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17942
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
EXCHANGE TRADED FUND (ETF)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
"THE ORDER SPECIFICALLY CONCERNS THE ISHARES MSCI RUSSIA CAPPED ETF (""RUSSIA FUND ETF""), MANAGED BY BLACKROCK FUND ADVISORS (""BFA"") AND WHETHER IT WAS COVERED
BY EXISTING EXEMPTIVE RELIEF GRANTED BY SECURITIES AND EXCHANGE COMMISSION (""SEC""). IN 2010, THE RUSSIA FUND ETF BEGAN SELLING ITS SHARES AS THE ONLY SERIES OF
SHARES OF ISHARES MSCI RUSSIA CAPPED ETF, INC. (""RUSSIA FUND COMPANY""). THE RUSSIA FUND COMPANY DID NOT HAVE THE REQUIRED EXEMPTIVE RELIEF UNTIL JANUARY 2015.
ACCORDINGLY, BY OPERATING THE RUSSIA FUND ETF FROM DECEMBER 2010 TO JANUARY 2015, BFA CAUSED THE RUSSIA FUND COMPANY TO VIOLATE THE INVESTMENT COMPANY ACT."
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):
04/28/2017
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: $ 1,500,000.00
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:
A CIVIL MONETARY PENALTY IN THE AMOUNT OF $1,500,000 WAS PAID ON APRIL 28, 2017
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 APRIL 25, 2017, BFA REACHED AN AGREEMENT WITH THE SEC RESOLVING THE MATTER REGARDING THE RUSSIA FUND ETF. BFA, WHICH DID NOT ADMIT OR DENY ANY OF THE SEC'S
FINDINGS, AGREED TO RESOLVE THE MATTER FOR A CIVIL MONETARY PENALTY OF $1,500,000."regulatory · block 6BLACKROCK, INCPDF pages 296–298
- Advisory affiliate name — filed text
- BLACKROCK, INC
- Regulator name — filed text
- THE SWISS FEDERAL DEPARTMENT OF FINANCE ("SWISS FDF")
- Monetary/Fine Amount — filed text
- $ 50,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
BLACKROCK, INC. PAID SETTLEMENT SUM OF CHF 50,000 ON APRIL 22, 2022.
Other filed details
Description of allegations — filed text
ON DATES IN 2017 AND IN 2018, BLACKROCK, INC. WAS LATE IN MAKING CERTAIN THRESHOLD FILINGS WITH THE SWISS REGULATOR. THESE LATE FILINGS WERE CAUSED BY TWO SEPARATE ISSUES: (1) INCORRECT SHARE ISSUE INFORMATION PROVIDED TO BLACKROCK BY ITS THIRD PARTY VENDOR; AND, (2) BLACKROCK'S OUTGOING EMAIL QUARANTINE SYSTEM INCORRECTLY QUARANTINING THRESHOLD INFORMATION EMAILS FROM BLACKROCK TO THE SWISS REGULATOR.
Sanction detail — filed text
THE SWISS FEDERAL DEPARTMENT OF FINANCE IMPOSED A SETTLEMENT SUM OF CHF 50,000. BLACKROCK, INC. PAID THE FEE ON APRIL 22, 2022.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK, 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)
THE SWISS FEDERAL DEPARTMENT OF FINANCE ("SWISS FDF")
2.
Principal Sanction:
Other
Other Sanctions:
SETTLEMENT SUM
3.
Date Initiated (MM/DD/YYYY):
07/19/2021
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):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
SWISS LISTED EQUITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DATES IN 2017 AND IN 2018, BLACKROCK, INC. WAS LATE IN MAKING CERTAIN THRESHOLD FILINGS WITH THE SWISS REGULATOR. THESE LATE FILINGS WERE CAUSED BY TWO SEPARATE
ISSUES: (1) INCORRECT SHARE ISSUE INFORMATION PROVIDED TO BLACKROCK BY ITS THIRD PARTY VENDOR; AND, (2) BLACKROCK'S OUTGOING EMAIL QUARANTINE SYSTEM INCORRECTLY
QUARANTINING THRESHOLD INFORMATION EMAILS FROM BLACKROCK TO THE SWISS REGULATOR.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
04/22/2022
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: $ 50,000.00
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 SWISS FEDERAL DEPARTMENT OF FINANCE IMPOSED A SETTLEMENT SUM OF CHF 50,000. BLACKROCK, INC. PAID THE FEE ON APRIL 22, 2022.
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).
BLACKROCK, INC. PAID SETTLEMENT SUM OF CHF 50,000 ON APRIL 22, 2022.Show 9 more source blocks
regulatory · block 7BLACKROCK ADVISORS, LLCPDF pages 298–300
- Advisory affiliate name — filed text
- BLACKROCK ADVISORS, LLC
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 2,500,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(8) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT EXPECT THE RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS.
Other filed details
Description of allegations — filed text
ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940
Sanction detail — filed text
ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI- ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT EXPECT THE RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS.
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:
106614
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK ADVISORS, 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)
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other
Other Sanctions:
BLACKROCK ADVISORS, LLC ("BAL") IS TO: A) PAY A $2.5 MILLION CIVIL MONEY PENALTY; B) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-8 PROMULGATED THEREUNDER, AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT; C) BE CENSURED.
3.
Date Initiated (MM/DD/YYYY):
03/02/2020
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21786
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
BLACKROCK ADVISORS LLC
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL
REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND
INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL
AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8
THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940
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:
Settled
11. Resolution Date (MM/DD/YYYY):
10/24/2023
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: $ 2,500,000.00
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:
ON OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-
ANNUAL REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST
RATE AND INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S
FINDINGS, BAL AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND
RULE 206(4)-8 THEREUNDER AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT
EXPECT THE RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS.
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 OCTOBER 24, 2023, THE SEC ANNOUNCED AN AGREEMENT WITH BLACKROCK ADVISORS, LLC ("BAL") TO SETTLE FINDINGS RELATING TO MISSTATEMENTS IN ANNUAL AND SEMI-ANNUAL
REPORTS OF A MUTUAL FUND FOR WHICH BAL SERVES AS THE REGISTERED INVESTMENT ADVISER. THE SEC FOUND THAT THE REPORTS INACCURATELY DESCRIBED THE INTEREST RATE AND
INDUSTRY CLASSIFICATION OF A LENDING FACILITY WITH A PRIVATELY HELD ENTITY IN WHICH THE MUTUAL FUND INVESTED. WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, BAL
AGREED TO THE ENTRY OF AN ADMINISTRATIVE ORDER CONTAINING FINDINGS THAT BAL VIOLATED SECTION 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8
THEREUNDER AND SECTION 34(8) OF THE INVESTMENT COMPANY ACT OF 1940. BAL PAID THE $2.5 MILLION CIVIL MONEY PENALTY ON OCTOBER 30, 2023. BAL DOES NOT EXPECT THE
RESOLUTION OF THIS MATTER TO HAVE A MATERIAL ADVERSE EFFECT ON ITS FINANCIAL RESULTS OR OPERATIONS.regulatory · block 8PDF pages 300–302
- Regulator name — filed text
- SECRETARY OF STATE OF THE STATE OF MISSISSIPPI
- How was matter resolved — filed text
- Vacated
Action status / disposition — filed text
ON APRIL 29, 2026, THE MISSISSIPPI SECRETARY OF STATE VACATED THE ADMINISTRATIVE ORDER THAT WAS ISSUED IN MARCH 2024.
Other filed details
Description of allegations — filed text
ON MARCH 27, 2024, BLACKROCK, INC., BLACKROCK INVESTMENTS, LLC, BLACKROCK ADVISORS, LLC, BLACKROCK FUND ADVISORS, AND ISHARES TRUST (COLLECTIVELY, "BLACKROCK") WERE SERVED WITH A SUMMARY CEASE AND DESIST ORDER AND NOTICE OF INTENT TO IMPOSE ADMINISTRATIVE PENALTY FROM THE MISSISSIPPI SECRETARY OF STATE. THE SUMMARY ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS IN FUND PROSPECTUSES, MARKETING MATERIAL, PUBLIC STATEMENTS, AND ON ITS WEBSITE REGARDING BLACKROCK'S ESG PRACTICES AND APPROACH TO PROXY VOTING. THE SUMMARY ORDER, WHICH WAS ISSUED TO BLACKROCK WITHOUT ANY PRIOR NOTICE OR OPPORTUNITY TO BE HEARD, FINDS THAT BLACKROCK VIOLATED THE MISSISSIPPI SECURITIES LAWS, AND ORDERS BLACKROCK TO REFRAIN FROM FUTURE VIOLATIONS OF THOSE LAWS. ON APRIL 25, 2024, BLACKROCK EXERCISED ITS RIGHT UNDER MISSISSIPPI TO REQUEST AN ADMINISTRATIVE HEARING TO CONTEST THE ALLEGATIONS.
Sanction detail — filed text
NOT APPLICABLE
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: 106614 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK ADVISORS, LLC (For individuals, Last, First, Middle) CRD Number: 105247 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK FUND ADVISORS (For individuals, Last, First, Middle) CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK, 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) SECRETARY OF STATE OF THE STATE OF MISSISSIPPI 2. Principal Sanction: Cease and Desist Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/27/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: LS-24-6726 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: ETFS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON MARCH 27, 2024, BLACKROCK, INC., BLACKROCK INVESTMENTS, LLC, BLACKROCK ADVISORS, LLC, BLACKROCK FUND ADVISORS, AND ISHARES TRUST (COLLECTIVELY, "BLACKROCK") WERE SERVED WITH A SUMMARY CEASE AND DESIST ORDER AND NOTICE OF INTENT TO IMPOSE ADMINISTRATIVE PENALTY FROM THE MISSISSIPPI SECRETARY OF STATE. THE SUMMARY ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS IN FUND PROSPECTUSES, MARKETING MATERIAL, PUBLIC STATEMENTS, AND ON ITS WEBSITE REGARDING BLACKROCK'S ESG PRACTICES AND APPROACH TO PROXY VOTING. THE SUMMARY ORDER, WHICH WAS ISSUED TO BLACKROCK WITHOUT ANY PRIOR NOTICE OR OPPORTUNITY TO BE HEARD, FINDS THAT BLACKROCK VIOLATED THE MISSISSIPPI SECURITIES LAWS, AND ORDERS BLACKROCK TO REFRAIN FROM FUTURE VIOLATIONS OF THOSE LAWS. ON APRIL 25, 2024, BLACKROCK EXERCISED ITS RIGHT UNDER MISSISSIPPI TO REQUEST AN ADMINISTRATIVE HEARING TO CONTEST THE ALLEGATIONS. 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: Vacated 11. Resolution Date (MM/DD/YYYY): 04/29/2026 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: PLEASE SEE SECTION 13 FOR DETAILS RELATING TO THE ACTION STATUS 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: NOT APPLICABLE 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 APRIL 29, 2026, THE MISSISSIPPI SECRETARY OF STATE VACATED THE ADMINISTRATIVE ORDER THAT WAS ISSUED IN MARCH 2024.
regulatory · block 9BLACKROCK MEXICO OPERADORA, S.A. DE C.V., SOCIEDAD OPERADORA DE FONDOS DE INVERSIÓNPDF pages 302–303
- Advisory affiliate name — filed text
- BLACKROCK MEXICO OPERADORA, S.A. DE C.V., SOCIEDAD OPERADORA DE FONDOS DE INVERSIÓN
- Regulator name — filed text
- COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV")
- Monetary/Fine Amount — filed text
- $ 164,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
ON JULY 12, 2024, THE COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV") IMPOSED A FINE OF APPROXIMATELY $164,000 (MNX $2,957,150) REGARDING THE FIRM'S COMPLIANCE WITH CERTAIN REGULATIONS APPLICABLE TO THE MANAGEMENT OF MUTUAL FUNDS AND THE PROVISION OF INVESTMENT ADVISORY SERVICES IN BLACKROCK'S MEXICO CITY OFFICE. SPECIFICALLY, THE CNBV FOUND THAT THE REGISTRATIONS OF 4 BLACKROCK SALES REPRESENTATIVES WERE ASSOCIATED WITH INCORRECT BLACKROCK ENTITIES AND THAT BLACKROCK MEXICO'S PUBLIC WEBSITE DID NOT GIVE NOTICE TO USERS WHEN USERS WERE REDIRECTED TO THIRD PARTY WEBSITES. PAYMENT OF FINE WAS SUBMITTED TO THE CNBV ON AUGUST 2, 2024
Other filed details
Description of allegations — filed text
FAILURE TO COMPLY WITH CERTAIN REGULATIONS APPLICABLE TO THE MANAGEMENT OF MUTUAL FUNDS AND THE PROVISION OF INVESTMENT ADVISORY SERVICES IN BLACKROCK'S MEXICO CITY OFFICE.
Sanction detail — filed text
PAYMENT OF FINE APPROXIMATELY $164,000 (MNX $2,957,150)
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK MEXICO OPERADORA, S.A. DE
C.V., SOCIEDAD OPERADORA DE FONDOS
DE INVERSIÓN
(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.
p
y
g
p
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)
COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
06/06/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
211-2B/28101798-AGCC/2023
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):
FAILURE TO COMPLY WITH CERTAIN REGULATIONS APPLICABLE TO THE MANAGEMENT OF MUTUAL FUNDS AND THE PROVISION OF INVESTMENT ADVISORY SERVICES IN BLACKROCK'S MEXICO
CITY OFFICE.
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):
07/12/2024
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: $ 164,000.00
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:
PAYMENT OF FINE APPROXIMATELY $164,000 (MNX $2,957,150)
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 JULY 12, 2024, THE COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV") IMPOSED A FINE OF APPROXIMATELY $164,000 (MNX $2,957,150) REGARDING THE FIRM'S COMPLIANCE WITH
CERTAIN REGULATIONS APPLICABLE TO THE MANAGEMENT OF MUTUAL FUNDS AND THE PROVISION OF INVESTMENT ADVISORY SERVICES IN BLACKROCK'S MEXICO CITY OFFICE. SPECIFICALLY,
THE CNBV FOUND THAT THE REGISTRATIONS OF 4 BLACKROCK SALES REPRESENTATIVES WERE ASSOCIATED WITH INCORRECT BLACKROCK ENTITIES AND THAT BLACKROCK MEXICO'S PUBLIC
WEBSITE DID NOT GIVE NOTICE TO USERS WHEN USERS WERE REDIRECTED TO THIRD PARTY WEBSITES. PAYMENT OF FINE WAS SUBMITTED TO THE CNBV ON AUGUST 2, 2024regulatory · block 10PDF pages 304–306
- Regulator name — filed text
- STATE OF INDIANA SECURITIES COMMISSIONER
Action status / disposition — filed text
ON AUGUST 22, 2024, THE INDIANA SECURITIES COMMISSIONER (THE "COMMISSIONER") ISSUED A CEASE AND DESIST ORDER (THE "ORDER") AGAINST BLACKROCK, INC. AND SEVERAL OF ITS ADVISORY AFFILIATES, (COLLECTIVELY, "BLACKROCK"). THE ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS ABOUT HOW WE MANAGE OUR NON-ESG AND ESG FUNDS. WITH RESPECT TO NON-ESG FUNDS, THE ORDER CITES TO OUR PARTICIPATION IN CLIMATE ORGANIZATIONS AND OUR STATEMENTS REGARDING ESG INTEGRATION AND STEWARDSHIP ACTIVITIES, AMONG OTHER THINGS, AS EVIDENCE THAT OUR NON-ESG FUNDS ACTUALLY PURSUE AN ESG STRATEGY. WITH RESPECT TO ESG FUNDS, THE ORDER ASSERTS THAT BLACKROCK FALSELY CLAIMS THAT SUSTAINABLE INVESTING WILL GENERATE BETTER RETURNS. THE ORDER FINDS THAT THIS ACTIVITY VIOLATES INDIANA'S SECURITIES LAW AND DIRECTS BLACKROCK TO CEASE ENGAGING IN THE REFERENCED ACTIVITIES.
Other filed details
Description of allegations — filed text
ON AUGUST 22, 2024, THE INDIANA SECURITIES COMMISSIONER (THE "COMMISSIONER") ISSUED A CEASE AND DESIST ORDER (THE "ORDER") AGAINST BLACKROCK, INC. AND SEVERAL OF ITS ADVISORY AFFILIATES, (COLLECTIVELY, "BLACKROCK"). THE ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS ABOUT HOW WE MANAGE OUR NON-ESG AND ESG FUNDS. WITH RESPECT TO NON-ESG FUNDS, THE ORDER CITES TO OUR PARTICIPATION IN CLIMATE ORGANIZATIONS AND OUR STATEMENTS REGARDING ESG INTEGRATION AND STEWARDSHIP ACTIVITIES, AMONG OTHER THINGS, AS EVIDENCE THAT OUR NON-ESG FUNDS ACTUALLY PURSUE AN ESG STRATEGY. WITH RESPECT TO ESG FUNDS, THE ORDER ASSERTS THAT BLACKROCK FALSELY CLAIMS THAT SUSTAINABLE INVESTING WILL GENERATE BETTER RETURNS. THE ORDER FINDS THAT THIS ACTIVITY VIOLATES INDIANA'S SECURITIES LAW AND DIRECTS BLACKROCK TO CEASE ENGAGING IN THE REFERENCED ACTIVITIES.
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: 108069 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK CAPITAL MANAGEMENT, INC. (For individuals, Last, First, Middle) CRD Number: 106614 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK ADVISORS, LLC (For individuals, Last, First, Middle) CRD Number: 107105 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK FINANCIAL MANAGEMENT, INC (For individuals, Last, First, Middle) CRD Number: 105247 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK FUND ADVISORS (For individuals, Last, First, Middle) CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK INC (For individuals, Last, First, Middle) CRD Number: 108928 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK INVESTMENT MANAGEMENT, LLC (For individuals, Last, First, Middle) CRD Number: 38642 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BLACKROCK INVESTMENTS, 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) STATE OF INDIANA SECURITIES COMMISSIONER 2. Principal Sanction: Cease and Desist Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 08/22/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 24-0013 CD 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: ETFS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON AUGUST 22, 2024, THE INDIANA SECURITIES COMMISSIONER (THE "COMMISSIONER") ISSUED A CEASE AND DESIST ORDER (THE "ORDER") AGAINST BLACKROCK, INC. AND SEVERAL OF ITS ADVISORY AFFILIATES, (COLLECTIVELY, "BLACKROCK"). THE ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS ABOUT HOW WE MANAGE OUR NON-ESG AND ESG FUNDS. WITH RESPECT TO NON-ESG FUNDS, THE ORDER CITES TO OUR PARTICIPATION IN CLIMATE ORGANIZATIONS AND OUR STATEMENTS REGARDING ESG INTEGRATION AND STEWARDSHIP ACTIVITIES, AMONG OTHER THINGS, AS EVIDENCE THAT OUR NON-ESG FUNDS ACTUALLY PURSUE AN ESG STRATEGY. WITH RESPECT TO ESG FUNDS, THE ORDER ASSERTS THAT BLACKROCK FALSELY CLAIMS THAT SUSTAINABLE INVESTING WILL GENERATE BETTER RETURNS. THE ORDER FINDS THAT THIS ACTIVITY VIOLATES INDIANA'S SECURITIES LAW AND DIRECTS BLACKROCK TO CEASE ENGAGING IN THE REFERENCED ACTIVITIES. 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: 11. Resolution Date (MM/DD/YYYY): 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: 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: 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 AUGUST 22, 2024, THE INDIANA SECURITIES COMMISSIONER (THE "COMMISSIONER") ISSUED A CEASE AND DESIST ORDER (THE "ORDER") AGAINST BLACKROCK, INC. AND SEVERAL OF ITS ADVISORY AFFILIATES, (COLLECTIVELY, "BLACKROCK"). THE ORDER ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS ABOUT HOW WE MANAGE OUR NON-ESG AND ESG FUNDS. WITH RESPECT TO NON-ESG FUNDS, THE ORDER CITES TO OUR PARTICIPATION IN CLIMATE ORGANIZATIONS AND OUR STATEMENTS REGARDING ESG INTEGRATION AND STEWARDSHIP ACTIVITIES, AMONG OTHER THINGS, AS EVIDENCE THAT OUR NON-ESG FUNDS ACTUALLY PURSUE AN ESG STRATEGY. WITH RESPECT TO ESG FUNDS, THE ORDER ASSERTS THAT BLACKROCK FALSELY CLAIMS THAT SUSTAINABLE INVESTING WILL GENERATE BETTER RETURNS. THE ORDER FINDS THAT THIS ACTIVITY VIOLATES INDIANA'S SECURITIES LAW AND DIRECTS BLACKROCK TO CEASE ENGAGING IN THE REFERENCED ACTIVITIES.
regulatory · block 11PDF pages 306–307
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 4,500,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
THE SEC ADMINISTRATIVE ORDER IS FINAL. THE CIVIL PENALTY WAS PAID WITHIN 10 DAYS OF THE ENTRY OF THE ORDER.
Other filed details
Description of allegations — filed text
ACCORDING TO THE SEC ORDER, GIM (I) DID NOT OFFSET FROM APPLICABLE MANAGEMENT FEES ELIGIBLE FEES PAID TO IT BY A FUND PORTFOLIO COMPANY, (II) DID NOT OFFSET FROM APPLICABLE MANAGEMENT FEES THE FULL AMOUNT IT OWED A FUND'S LIMITED PARTNERS IN CONNECTION WITH ELIGIBLE FEES IT COLLECTED FROM A FUND PORTFOLIO COMPANY AND (III) INCLUDED INCONSISTENT PROVISIONS CONCERNING THE MANAGEMENT FEE CALCULATION METHODOLOGY IN THE OFFERING AND GOVERNING DOCUMENTS FOR TWO FUNDS. IN ADDITION, THE SEC ORDER FOUND THAT GIM DID NOT ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE ABOVE VIOLATIONS OF THE ADVISERS ACT.
Sanction detail — filed text
THE PENALTY AMOUNT OF $4,500,000 WAS PAID ON DECEMBER 20, 2021.
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 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) U.S. SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: CENSURE AND CIVIL PENALTY 3. Date Initiated (MM/DD/YYYY): 12/20/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-20683 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: PRIVATE EQUITY FUNDS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ACCORDING TO THE SEC ORDER, GIM (I) DID NOT OFFSET FROM APPLICABLE MANAGEMENT FEES ELIGIBLE FEES PAID TO IT BY A FUND PORTFOLIO COMPANY, (II) DID NOT OFFSET FROM APPLICABLE MANAGEMENT FEES THE FULL AMOUNT IT OWED A FUND'S LIMITED PARTNERS IN CONNECTION WITH ELIGIBLE FEES IT COLLECTED FROM A FUND PORTFOLIO COMPANY AND (III) INCLUDED INCONSISTENT PROVISIONS CONCERNING THE MANAGEMENT FEE CALCULATION METHODOLOGY IN THE OFFERING AND GOVERNING DOCUMENTS FOR TWO FUNDS. IN ADDITION, THE SEC ORDER FOUND THAT GIM DID NOT ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE ABOVE VIOLATIONS OF THE ADVISERS ACT. 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: Settled 11. Resolution Date (MM/DD/YYYY): 12/20/2021 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: $ 4,500,000.00 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 PENALTY AMOUNT OF $4,500,000 WAS PAID ON DECEMBER 20, 2021. 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 SEC ADMINISTRATIVE ORDER IS FINAL. THE CIVIL PENALTY WAS PAID WITHIN 10 DAYS OF THE ENTRY OF THE ORDER.
regulatory · block 12BLACKROCK MEXICO OPERADORA, S.A. DE C.V., SOCIEDAD OPERADORA DE FONDOS DE INVERSIÓNPDF pages 308–309
- Advisory affiliate name — filed text
- BLACKROCK MEXICO OPERADORA, S.A. DE C.V., SOCIEDAD OPERADORA DE FONDOS DE INVERSIÓN
- Regulator name — filed text
- COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV")
- Monetary/Fine Amount — filed text
- $ 123,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
SEE SUMMARY PROVIDED IN SECTION 7. THE FINDINGS OBSERVED BY THE CNBV HAVE ALREADY BEEN CORRECTED, AND THESE ACTIONS HAVE BEEN COMMUNICATED TO THE CNBV. THE FINE IMPOSED BY THE CNBV IS THE MINIMUM FINE PERMISSIBLE UNDER THE APPLICABLE LAW FOR EACH FINDING.
Other filed details
Description of allegations — filed text
ON JANUARY 9, 2025, THE COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV") IMPOSED A FINE OF APPROXIMATELY $123,000 USD (MNX $2,501,720) REGARDING THE ANTIMONEY LAUNDERING AND COUNTER-TERRORIST FINANCING PROGRAM AT BLACKROCK'S MEXICO CITY OFFICE. SPECIFICALLY, THE CNBV FOUND THAT BLACKROCK MEXICO DID NOT HAVE SUFFICIENT PROCEDURES TO ASSESS WHETHER POTENTIAL TRANSACTIONS INVOLVING POLITICALLY EXPOSED PERSONS WERE APPROPRIATE AND TO COLLECT CERTAIN INFORMATION ABOUT HIGHER RISK CLIENTS. FURTHER, THE CNBV IDENTIFIED INSTANCES WHERE BLACKROCK MEXICO DID NOT MAINTAIN COMPLETE CLIENT FILES.
Sanction detail — filed text
NOT APPLICABLE
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
BLACKROCK MEXICO OPERADORA, S.A. DE
C.V., SOCIEDAD OPERADORA DE FONDOS
DE INVERSIÓN
(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)
COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
01/10/2025
Exact
Explanation
If not exact, provide explanation:
THE 01/09/2025 DATE REFERS TO THE DATE BLACKROCK MEXICO RECEIVED THE OFFICIAL NOTIFICATION LETTER FROM THE CNBV RELATED TO THE CNBV EXAMINATION ON MUTUAL FUNDS
AND AML INITIATED IN JULY 2022.
4.
Docket/Case Number:
CNBV.2S.2.211(4433)"2023"/1025/5 PTS
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:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JANUARY 9, 2025, THE COMISIÓN NACIONAL BANCARIA Y DE VALORES ("CNBV") IMPOSED A FINE OF APPROXIMATELY $123,000 USD (MNX $2,501,720) REGARDING THE ANTIMONEY
LAUNDERING AND COUNTER-TERRORIST FINANCING PROGRAM AT BLACKROCK'S MEXICO CITY OFFICE. SPECIFICALLY, THE CNBV FOUND THAT BLACKROCK MEXICO DID NOT HAVE SUFFICIENT
PROCEDURES TO ASSESS WHETHER POTENTIAL TRANSACTIONS INVOLVING POLITICALLY EXPOSED PERSONS WERE APPROPRIATE AND TO COLLECT CERTAIN INFORMATION ABOUT HIGHER
RISK CLIENTS. FURTHER, THE CNBV IDENTIFIED INSTANCES WHERE BLACKROCK MEXICO DID NOT MAINTAIN COMPLETE CLIENT FILES.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
01/09/2025
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: $ 123,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
IN ACCORDANCE WITH THE NOTIFICATION LETTER, THE CNBV ORDERED BLACKROCK MEXICO TO PAY A FINE IN THE AMOUNT OF APPROXIMATELY $123,000 (USD), BLACKROCK MEXICO
DID NOT CONTEST AND PAID A FINE IN THE AMOUNT OF $98,000 (USD) ON 01/17/2025, A PORTION OF WHICH WAS DISCOUNTED UNDER THE TERMS OF THE APPLICABLE REGULATION.
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:
NOT APPLICABLE
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).
SEE SUMMARY PROVIDED IN SECTION 7. THE FINDINGS OBSERVED BY THE CNBV HAVE ALREADY BEEN CORRECTED, AND THESE ACTIONS HAVE BEEN COMMUNICATED TO THE CNBV. THE FINE
IMPOSED BY THE CNBV IS THE MINIMUM FINE PERMISSIBLE UNDER THE APPLICABLE LAW FOR EACH FINDING.civil judicial · block 1PDF pages 309–311
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: BLACKROCK 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.H.(1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) TEXAS ATTORNEY GENERAL AND ATTORNEYS GENERAL FROM 10 OTHER STATES (AL, AR, IN, IOWA, KS, MO, MT, NE, WV, AND WY) 2. Principal Relief Sought: Other Other Relief Sought: CIVIL FINE/PENALTY, MONEY DAMAGES, INJUNCTION AND RETURN OF FEES AND COSTS. 3. Filing Date of Court Action (MM/DD/YYYY): 11/27/2024 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Other Other Product Types: ETFS 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): CASE 6:24-CV-00437, UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ON NOVEMBER 27, 2024, TEXAS ATTORNEY GENERAL KEN PAXTON AND ATTORNEYS GENERAL FROM 10 OTHER STATES (ALABAMA, ARKANSAS, INDIANA, IOWA, KANSAS, MISSOURI, MONTANA, NEBRASKA, WEST VIRGINIA, AND WYOMING) FILED A COMPLAINT AGAINST BLACKROCK, VANGUARD, AND STATE STREET (THE "MANAGERS") ALLEGING THAT THE MANAGERS USED THEIR OWNERSHIP STAKES IN COAL COMPANIES TO ARTIFICIALLY REDUCE COAL OUTPUT IN VIOLATION OF VARIOUS STATE AND FEDERAL ANTITRUST LAWS. TEXAS ALSO CLAIMS BLACKROCK MADE FALSE AND DECEPTIVE STATEMENTS IN CONNECTION WITH THE MARKETING OF ITS NON-ESG ETFS. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 12/03/2024 Exact Explanation If not exact, provide explanation: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: 12. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: C. 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: 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). ON NOVEMBER 27, 2024, TEXAS ATTORNEY GENERAL KEN PAXTON AND ATTORNEYS GENERAL FROM 10 OTHER STATES (ALABAMA, ARKANSAS, INDIANA, IOWA, KANSAS, MISSOURI, MONTANA, NEBRASKA, WEST VIRGINIA, AND WYOMING) FILED A COMPLAINT AGAINST BLACKROCK, VANGUARD, AND STATE STREET (THE "MANAGERS") ALLEGING THAT THE MANAGERS USED THEIR OWNERSHIP STAKES IN COAL COMPANIES TO ARTIFICIALLY REDUCE COAL OUTPUT IN VIOLATION OF VARIOUS STATE AND FEDERAL ANTITRUST LAWS. TEXAS ALSO CLAIMS BLACKROCK MADE FALSE AND DECEPTIVE STATEMENTS IN CONNECTION WITH THE MARKETING OF ITS NON-ESG ETFS.
civil judicial · block 2PDF pages 311–313
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial
actions must be reported on separate DRPs.
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:
BLACKROCK 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.H.(1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
TENNESSEE ATTORNEY GENERAL
2.
Principal Relief Sought:
Other
Other Relief Sought:
INJUNCTION, DISGORGEMENT, CIVIL PENALTY, RETURN OF FEES AND COSTS.
3.
Filing Date of Court Action (MM/DD/YYYY):
12/18/2023
Exact
Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types:
ETFS
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number):
CASE _23CV-618, CIRCUIT COURT OF WILLIAMSON COUNTY, TENNESSEE F'OR THE TWENTY.FIRST JUDICIAL DISTRICT
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
7.
Describe the allegations related to this civil action (your response must fit within the space provided):
ON DECEMBER 18, 2023, THE TENNESSEE ATTORNEY GENERAL ("AG") SUED BLACKROCK, INC. IN TENNESSEE STATE COURT FOR ALLEGED VIOLATIONS OF TENNESSEE'S CONSUMER
PROTECTION STATUTE IN CONNECTION WITH OUR ESG PRACTICES. THE COMPLAINT GENERALLY ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS IN FUND PROSPECTUSES,
FACT SHEETS, VARIOUS PUBLIC STATEMENTS, AND ON ITS WEBSITE REGARDING ITS ESG PRACTICES AND ITS APPROACH TO PROXY VOTING.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact
Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY):
01/17/2025
Exact
Explanation
If not exact, provide explanation:
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
PLEASE SEE SECTION 14 FOR DETAILS RELATING TO THE SETTLEMENT AGREEMENT.
C.
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:
NOT APPLICABLE.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided).
ON DECEMBER 18, 2023, THE TENNESSEE ATTORNEY GENERAL ("AG") SUED BLACKROCK, INC. IN TENNESSEE STATE COURT FOR ALLEGED VIOLATIONS OF TENNESSEE'S CONSUMER
PROTECTION STATUTE IN CONNECTION WITH OUR ESG PRACTICES. THE COMPLAINT GENERALLY ALLEGES THAT BLACKROCK HAS MADE MISLEADING STATEMENTS IN FUND PROSPECTUSES,
FACT SHEETS, VARIOUS PUBLIC STATEMENTS, AND ON ITS WEBSITE REGARDING ITS ESG PRACTICES AND ITS APPROACH TO PROXY VOTING. ON JANUARY 17, 2025, THE PARTIES SETTLED THE
LITIGATION. THE SETTLEMENT DOES NOT INVOLVE THE PAYMENT OF ANY MONEY, NOR DOES IT INCLUDE ANY FINDINGS THAT BLACKROCK VIOLATED ANY LAWS. AMONG OTHER THINGS,
BLACKROCK AGREED TO UPDATE CERTAIN DISCLOSURES ON ITS WEBPAGES AND TO PROVIDE ADDITIONAL TRANSPARENCY AND RECORDKEEPING AROUND ITS STEWARDSHIP PRACTICES.civil judicial · block 3PDF pages 313–315
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) 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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. 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: BLACKROCK TCP CAPITAL CORP (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.H.(1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) PRIVATE PLAINTIFF, CORY BURNELL, WHO PURPORTS TO BRING THE ACTION INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: COMPENSATORY DAMAGES, INTEREST, ATTORNEYS' FEES AND COSTS, AND OTHER RELIEF. 3. Filing Date of Court Action (MM/DD/YYYY): 02/03/2026 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): CASE 2:26-CV-01102 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 7. Describe the allegations related to this civil action (your response must fit within the space provided): ON FEBRUARY 3, 2026, A PUTATIVE SECURITIES CLASS ACTION LAWSUIT WAS FILED IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA. THE COMPLAINT NAMES BLACKROCK TCP CAPITAL CORP AND CERTAIN OF ITS CURRENT AND FORMER EXECUTIVE OFFICERS AS DEFENDANTS. THE COMPLAINT PURPORTS TO BE BROUGHT ON BEHALF OF A CLASS OF PERSONS WHO PURCHASED OR OTHERWISE ACQUIRED BLACKROCK TCP CAPITAL CORP'S SECURITIES BETWEEN NOVEMBER 6, 2024 AND JANUARY 23, 2026, AND ALLEGES VIOLATIONS OF SECTIONS 10(B) AND 20(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 PROMULGATED THEREUNDER, BASED ON ALLEGED MATERIALLY FALSE AND MISLEADING STATEMENTS AND/OR OMISSIONS CONCERNING BLACKROCK TCP CAPITAL CORP'S BUSINESS, OPERATIONS AND FINANCIAL CONDITION. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): 03/10/2026 Exact Explanation If not exact, provide explanation: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: 12. Resolution Date (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: C. 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: 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). ON FEBRUARY 3, 2026, A PUTATIVE SECURITIES CLASS ACTION LAWSUIT WAS FILED IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA. THE COMPLAINT NAMES BLACKROCK TCP CAPITAL CORP AND CERTAIN OF ITS CURRENT AND FORMER EXECUTIVE OFFICERS AS DEFENDANTS. THE COMPLAINT PURPORTS TO BE BROUGHT ON BEHALF OF A CLASS OF PERSONS WHO PURCHASED OR OTHERWISE ACQUIRED BLACKROCK TCP CAPITAL CORP'S SECURITIES BETWEEN NOVEMBER 6, 2024 AND JANUARY 23, 2026, AND ALLEGES VIOLATIONS OF SECTIONS 10(B) AND 20(A) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 PROMULGATED THEREUNDER, BASED ON ALLEGED MATERIALLY FALSE AND MISLEADING STATEMENTS AND/OR OMISSIONS CONCERNING BLACKROCK TCP CAPITAL CORP'S BUSINESS, OPERATIONS AND FINANCIAL CONDITION.
* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.