Eagle Asset Management Inc.

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
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) 
TEXAS STATE SECURITIES BOARD
2.
Principal Sanction:
Reprimand
Other Sanctions: 
$12500 FINE
3.
Date Initiated (MM/DD/YYYY): 
03/01/1995
 Exact
 Explanation
If not exact, provide explanation:
NO RECORD OF EXACT DATE
4.
Docket/Case Number:
CEN-1056
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
DISCRETIONARY INVESTMENT ADVISORY SERVICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
RENDERED INVESTMENT ADVICE THROUGH USE OF UNREGISTERED AGENTS
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:
Consent
11. Resolution Date (MM/DD/YYYY):
09/18/1995
 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: $ 12,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:

EAGLE WAS REPRIMANDED AND PAID A FINE OF $12,500. THE ENTIRE AMOUNT WAS LEVIED AGAINST EAGLE, AND THE AMOUNT WAS PAID ON
09/14/1995
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: 
EAGLE CONSENTED TO ORDER AND PAID FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
EAGLE CONSENTED TO ORDER AND PAID FINE

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:
705
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES &
ASSOCIATES, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
6694
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES FINANCIAL
SERVICES, 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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY (SRO)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/18/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014043592001
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
RAYMOND JAMES & ASSOCIATES, INC.; RAYMOND JAMES FINANCIAL SERVICES, INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, RAYMOND JAMES AND ASSOCIATES (HEREIN, "THE FIRM") CONSENTED TO THE SANCTIONS AND TO
THE ENTRY OF FINDINGS THAT IT FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES TO REASONABLY DETECT AND CAUSE THE
REPORTING OF SUSPICIOUS TRANSACTIONS. THE FINDINGS STATED THAT AS THE FIRM'S AMLCO, THE REPRESENTATIVE WAS RESPONSIBLE FOR
ENSURING THAT THE FIRM'S AML PROGRAM WAS ADEQUATELY TAILORED TO THE FIRM'S BUSINESS AND FOR APPROPRIATELY MONITORING, DETECTING
AND REPORTING SUSPICIOUS ACTIVITY. DESPITE THE SEPARATE AML DEPARTMENTS AND PROGRAMS, THE FIRM AS A CLEARING FIRM, ITS AMLCO, AND
RAYMOND JAMES FINANCIAL SERVICES, INC. FOR WHICH THE FIRM SERVED AS CLEARING FIRM CREATED A SYSTEM UNDER WHICH THIS FIRM HEAVILY
RELIED UPON ITS CLEARING FIRM TO PROVIDE CERTAIN SYSTEMS AND TOOLS AS PART OF THE FIRM'S AML PROGRAM. THE FIRM FAILED TO COMMIT
ADEQUATE RESOURCES TO THE FIRM'S AML PROGRAMS. THE FIRM'S STAFFING OF ITS AML DEPARTMENTS WAS INADEQUATE IN LIGHT OF THE
EXTENSIVE RESPONSIBILITIES ASSIGNED TO THE FEW INDIVIDUALS, INCLUDING THE LABOR-INTENSIVE MANUAL REVIEWS, PARTICULARLY IN LIGHT OF
THE FIRM'S GROWTH. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH REASONABLE WRITTEN PROCEDURES FOR CERTAIN ASPECTS
OF THE FIRM'S AML PROGRAMS. THE FIRM FAILED TO ESTABLISH REASONABLE AML SYSTEMS TAILORED TO ITS BUSINESS. THE AML PROCEDURES THAT
WERE IN PLACE REQUIRED THE FIRM TO REVIEW ACCOUNTS FOR POTENTIAL SUSPICIOUS ACTIVITY. THE FIRM, HOWEVER, FAILED TO DEVELOP AND
IMPLEMENT SURVEILLANCE REPORTS TAILORED TO DETECT DETAIN TYPES OF POTENTIALLY SUSPICIOUS TRANSACTIONS. FOR EXAMPLE, THE FIRM HAD
NO WRITTEN PROCEDURES REQUIRING REVIEW OF, OR SURVEILLANCE REPORTS MONITORING FOR, THE FOLLOWING HIGH-RISK ACTIVITIES:
TRANSFERS OF FUNDS TO UNRELATED ACCOUNTS WITHOUT ANY APPARENT BUSINESS PURPOSE; JOURNALING SECURITIES AND CASH BETWEEN
UNRELATED ACCOUNTS FOR NO APPARENT BUSINESS PURPOSE, PARTICULARLY INTERNAL TRANSFERS OF CASH FROM CUSTOMER ACCOUNTS TO
EMPLOYEE OR EMPLOYEE-RELATED ACCOUNTS; AND MOVEMENT OF FUNDS, BY WIRE TRANSFER OR OTHERWISE, FROM MULTIPLE ACCOUNTS TO THE
SAME THIRD PARTY ACCOUNT. THE FIRM'S SURVEILLANCE REPORTS FAILED TO REASONABLY MONITOR FOR SUSPICIOUS ACTIVITY. THE FINDS ALSO
INCLUDED THAT THE FIRM FAILED TO REASONABLY INVESTIGATE RED FLAGS. AS A RESULT FROM THE FIRM'S AML PROCEDURES, THE FIRM HAD GAPS IN
ITS SURVEILLANCE OF ACTIVITY FOR AML RED FLAGS, THE FIRM FAILED TO REASONABLY INVESTIGATE MANY INSTANCES IN ORDER TO DETERMINE
WHETHER A SAR SHOULD BE FILED. ALSO, ALTHOUGH THE FIRM AML ANALYSTS IDENTIFIED SOME RED FLAGS AND OPENED INVESTIGATIONS, THE
INVESTIGATIONS WERE DEFICIENT. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY ENFORCE ITS DUE DILIGENCE PROCEDURES FOR CERTAIN
CORRESPONDENT ACCOUNTS OF CERTAIN FOREIGN FINANCIAL INSTITUTIONS (FFIS). MOREOVER, THE FIRM ALSO HAD NO RELIABLE PERIODIC REVIEW
PROCESS IN PLACE TO ENSURE THAT THE ACTIVITY IN THE FFIS' ACCOUNTS WAS CONSISTENT WITH REPRESENTATIONS MADE BY FFIS AT THE TIME OF
ACCOUNT OPENING. THIS FAILURE RESULTED IN THE FIRM PERFORMING NO PERIODIC RISK REVIEWS OF A PORTUGUESE FFI ACCOUNT, EVEN THOUGH
THE FFI WAS ASSIGNED A HIGH-RISK RATING BY THE FIRM. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A
SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH SECTION 5 OF THE SECURITIES ACT THROUGH THE INCOMPLETE RISK
REVIEWS, DUE DILIGENCE FAILURES, AND FAILURES TO IMPLEMENT EXISTING PROCEDURES RELEVANT TO LOW PRICED SECURITIES.
8.
Current Status?      
 Pending
 On Appeal
 Final

9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/18/2016
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 17,000,000.00
 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 CENSURE; A FINE IN THE AMOUNT OF $8,000,000 FOR RAYMOND JAMES & ASSOCIATES; A FINE IN THE AMOUNT OF $9,000,000 FOR RAYMOND
JAMES FINANCIAL SERVICES; AND
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).
RJA & RJFS WERE CENSURED, FINED, AND REQUIRED TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF EACH OF ITS AML AND
SUPERVISORY POLICIES, SYSTEMS, PROCEDURES, AND TRAINING. AT THE CONCLUSION OF THE REVIEW, WHICH SHALL BE NO MORE THAN 180 DAYS
AFTER THE DATE OF THE NOTICE OF ACCEPTANCE OF THE AWC, RJA/RJFS SHALL CERTIFY THAT THE PROCEDURES ARE REASONABLY DESIGNED TO
ACHIEVE COMPLIANCE WITH FINRA RULE 3310. THE CERTIFICATION SHALL BE PROVIDED IN A WRITTEN LETTER TO FINRA. THE LETTER SHALL BE
ACCOMPANIED BY A WRITTEN REPORT, AT A MINIMUM STATING (I) THE ADEQUACY OF RJA/RJFS' POLICIES, SYSTEMS, PROCEDURES, AND TRAINING
RELATING TO AML AND SUPERVISION; (II) A DESCRIPTION OF THE REVIEW PERFORMED AND THE CONCLUSIONS REACHED; AND (III)
RECOMMENDATIONS FOR MODIFICATIONS AND ADDITIONS TO THE FIRM'S POLICIES, SYSTEMS, PROCEDURES AND TRAINING.

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:
149018
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
RAYMOND JAMES FINANCIAL
SERVICES ADVISORS, 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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 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 Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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).