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 Principal Securities, 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 Principal Securities, Inc...
Reported ownership and control details
Form ADV · Filing date 2026-03-30 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | PRINCIPAL FINANCIAL SERVICES, INC.OWNERDomestic entity | PRINCIPAL SECURITIES, INC. | 75% or moreCode E | Yes | OWNER10/2001 | Schedule APDF page 55 |
| 2 | MICHAEL FRANCIS MURRAYPRESIDENT/CHIEF EXECUTIVE OFFICER/CHAIRIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | PRESIDENT/CHIEF EXECUTIVE OFFICER/CHAIR07/2018 | Schedule APDF page 55 |
| 3 | AMY CHRISTINE FRIEDRICHDIRECTORIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | DIRECTOR05/2019 | Schedule APDF page 55 |
| 4 | DOUGLAS JOHN RANTSCHIEF INFORMATION SECURITY OFFICERIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF INFORMATION SECURITY OFFICER12/2019 | Schedule APDF page 55 |
| 5 | CRAIG ALAN SPADAFORASENIOR VICE PRESIDENT / HEAD OF ADVISORY AND PLATFORMIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | SENIOR VICE PRESIDENT / HEAD OF ADVISORY AND PLATFORM12/2019 | Schedule APDF page 55 |
| 6 | CHAD THOMAS CLAIRECHIEF INFORMATION OFFICERIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF INFORMATION OFFICER12/2019 | Schedule APDF page 56 |
| 7 | DANIEL SIMON VANWINKLEPSI AML OFFICERIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | PSI AML OFFICER03/2021 | Schedule APDF page 56 |
| 8 | KENNETH ALLEN MCCULLUMDIRECTORIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | DIRECTOR05/2021 | Schedule APDF page 56 |
| 9 | THOMAS JOHN DROGANCHIEF COMPLIANCE OFFICERIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER05/2024 | Schedule APDF page 56 |
| 10 | CODY ANTHONY LAWLERHEAD OF SUPERVISION, HEAD OF OPERATIONSIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | HEAD OF SUPERVISION, HEAD OF OPERATIONS05/2024 | Schedule APDF page 56 |
| 11 | NATHAN PAUL SCHELHAASDIRECTORIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | DIRECTOR12/2024 | Schedule APDF page 56 |
| 12 | DAWN MARIE ROBERTSCHIEF FINANCIAL OFFICERIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER12/2024 | Schedule APDF page 56 |
| 13 | VIVEK AGRAWALDIRECTORIndividual | PRINCIPAL SECURITIES, INC. | Less than 5%Code NA | Yes | DIRECTOR03/2025 | Schedule APDF page 56 |
| 14 | PRINCIPAL FINANCIAL GROUP INC.OWNERDomestic entity | PRINCIPAL FINANCIAL SERVICES, INC. | 75% or moreCode E | Yes | OWNER10/2001 | Schedule BPDF page 56 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 3/30/2026 1:29:47 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 actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- 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 actions4 Yes1 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?Yes
- 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?Yes
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 8 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 1EPPS, WENDELL, DALEPDF pages 57–58
- Advisory affiliate name — filed text
- EPPS, WENDELL, DALE
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: 3060214 This advisory affiliate is a Firm an Individual Registered: Yes No Name: EPPS, WENDELL, DALE (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).
regulatory · block 2NOEY, JOHN, WILLIAMPDF pages 58–60
- Advisory affiliate name — filed text
- NOEY, JOHN, WILLIAM
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: 4676895 This advisory affiliate is a Firm an Individual Registered: Yes No Name: NOEY, JOHN, WILLIAM (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).
regulatory · block 3PDF pages 60–62
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
PRINCIPAL SECURITIES SELF-REPORTED TO THE SECURITIES AND EXCHANGE COMMISSION (SEC) AS PART OF THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE (SCSD) POSSIBLE VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) RELATING TO THE FIRM'S FAILURE TO MAKE NECESSARY DISCLOSURES CONCERNING MUTUAL FUND SHARE CLASS SELECTION. WITHOUT THE FIRM ADMITTING OR DENYING THE FINDINGS, ON MARCH 11, 2019, THE SEC ENTERED AN ORDER AGAINST THE FIRM ALLEGING BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES IN CONNECTION WITH THE FIRM'S MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND FEES IT RECEIVED PURSUANT TO RULE 12B- 1 UNDER THE INVESTMENT COMPANY ACT OF 1940. AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO DECEMBER 31, 2018, THE FIRM PURCHASED, RECOMMENDED OR HELD ADVISORY CLIENTS' MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. THE FIRM RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. THE FIRM FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND/OR ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. THE FIRM WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 207 OR THE ADVISERS ACT. THE FIRM WAS ALSO REQUIRED TO PAY DISGORGEMENT AND PREJUDGMENT INTEREST TO AFFECTED INVESTORS TOTALING $1,764,624.26, AS WELL AS TO TAKE OTHER REMEDIAL ACTIONS. THE FIRM IS IN THE PROCESS OF ARRANGING FOR AND EXECUTING THE PAYMENTS OF DISGORGEMENT AND INTEREST TO IMPACTED CUSTOMERS.
Other filed details
Description of allegations — filed text
SEC ADMIN RELEASE IA 5154, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST PRINCIPAL SECURITIES, INC. ("RESPONDENT"). ON THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
Sanction detail — filed text
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. CENSURED, PAY DISGORGEMENT OF $1,552,412.38 AND PREJUDGMENT INTEREST OF $212,211.88, AND COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Other Sanctions:
N/A
3.
Date Initiated (MM/DD/YYYY):
03/11/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19057
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):
SEC ADMIN RELEASE IA 5154, MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST
THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST PRINCIPAL SECURITIES, INC. ("RESPONDENT"). ON
THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY
DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE
FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL
FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE
ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR
OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES
THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH
MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 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:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
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:
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE
ADVISERS ACT. CENSURED, PAY DISGORGEMENT OF $1,552,412.38 AND PREJUDGMENT INTEREST OF $212,211.88, AND COMPLY WITH THE
UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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).
PRINCIPAL SECURITIES SELF-REPORTED TO THE SECURITIES AND EXCHANGE COMMISSION (SEC) AS PART OF THE SEC'S SHARE CLASS SELECTION
DISCLOSURE INITIATIVE (SCSD) POSSIBLE VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) RELATING TO THE FIRM'S
FAILURE TO MAKE NECESSARY DISCLOSURES CONCERNING MUTUAL FUND SHARE CLASS SELECTION. WITHOUT THE FIRM ADMITTING OR DENYING THE
FINDINGS, ON MARCH 11, 2019, THE SEC ENTERED AN ORDER AGAINST THE FIRM ALLEGING BREACHES OF FIDUCIARY DUTY AND INADEQUATE
DISCLOSURES IN CONNECTION WITH THE FIRM'S MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND FEES IT RECEIVED PURSUANT TO RULE 12B-
1 UNDER THE INVESTMENT COMPANY ACT OF 1940. AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO DECEMBER 31, 2018, THE FIRM PURCHASED,
RECOMMENDED OR HELD ADVISORY CLIENTS' MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES
OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. THE FIRM RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. THE
FIRM FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTEREST RELATED TO ITS RECEIPT OF 12B-1 FEES AND/OR ITS
SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. THE FIRM WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) AND 207 OR THE ADVISERS ACT. THE FIRM WAS ALSO
REQUIRED TO PAY DISGORGEMENT AND PREJUDGMENT INTEREST TO AFFECTED INVESTORS TOTALING $1,764,624.26, AS WELL AS TO TAKE OTHER
REMEDIAL ACTIONS. THE FIRM IS IN THE PROCESS OF ARRANGING FOR AND EXECUTING THE PAYMENTS OF DISGORGEMENT AND INTEREST TO
IMPACTED CUSTOMERS.regulatory · block 4Bartlett, Dale, DuanePDF pages 62–64
- Advisory affiliate name — filed text
- Bartlett, Dale, Duane
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: 2625302 This advisory affiliate is a Firm an Individual Registered: Yes No Name: Bartlett, Dale, Duane (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).
regulatory · block 5PDF pages 64–66
- Regulator name — filed text
- FINRA
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
AFTER AN INTERNAL REVIEW, IN DECEMBER 2015 PRINCIPAL SECURITIES SELF-REPORTED THAT CERTAIN ELIGIBLE RETIREMENT AND CHARITABLE ORGANIZATION ACCOUNT CUSTOMERS WITH MUTUAL FUNDS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS BETWEEN JULY 1, 2009 AND THAT POINT IN TIME. PRINCIPAL SECURITIES BEGAN MAKING REFUNDS TO IMPACTED ELIGIBLE CUSTOMERS AFTER IT SELF-REPORTED. FINRA ALLEGED PRINCIPAL SECURITIES HAD VIOLATED NASD CONDUCT RULE 3010 AND FINRA RULES 3110 AND 2010 BY FAILING TO IDENTIFY AND APPLY ALL AVAILABLE MUTUAL FUND SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS AND FAILING TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS. WITHOUT ADMITTING OR DENYING THE FINDINGS, PRINCIPAL SECURITIES ACCEPTED AND CONSENTED TO CENSURE AND RESTITUTION TO THE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT HAD NOT RECEIVED, THE APPLICABLE SALES CHARGE WAIVERS.
Other filed details
Description of allegations — filed text
FINRA ALLEGED PRINCIPAL SECURITIES FAILED TO IDENTIFY AND APPLY AVAILABLE MUTUAL FUND SALES CHARGE WAIVERS TO CERTAIN ELIGIBLE RETIREMENT AND CHARITABLE ORGANIZATION ACCOUNTS AND FAILED TO REASONABLY SUPERVISE THE APPLICATION OF THESE SALES CHARGE WAIVERS. FINRA ALLEGED THAT THIS VIOLATED NASD CONDUCT RULE 3010 AND FINRA RULES 3110 AND 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, PRINCIPAL SECURITIES ACCEPTED AND CONSENTED TO CENSURE AND RESTITUTION TO THE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE SALES CHARGE WAIVERS SINCE JULY 1, 2009.
Sanction detail — filed text
THE FIRM WAS CENSURED AND REQUIRED TO PROVIDE FINRA WITH A REMEDIATION PLAN TO REMEDIATE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES-CHARGE WAIVER. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TO PAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH IS ESTIMATED TO TOTAL $1,035,000 (THE AMOUNT ELIGIBLE CUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST).
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) FINRA 2. Principal Sanction: Other Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/15/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015048330401 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): FINRA ALLEGED PRINCIPAL SECURITIES FAILED TO IDENTIFY AND APPLY AVAILABLE MUTUAL FUND SALES CHARGE WAIVERS TO CERTAIN ELIGIBLE RETIREMENT AND CHARITABLE ORGANIZATION ACCOUNTS AND FAILED TO REASONABLY SUPERVISE THE APPLICATION OF THESE SALES CHARGE WAIVERS. FINRA ALLEGED THAT THIS VIOLATED NASD CONDUCT RULE 3010 AND FINRA RULES 3110 AND 2010. WITHOUT ADMITTING OR DENYING THE FINDINGS, PRINCIPAL SECURITIES ACCEPTED AND CONSENTED TO CENSURE AND RESTITUTION TO THE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE SALES CHARGE WAIVERS SINCE JULY 1, 2009. 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): 11/15/2016 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: INTEREST Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND REQUIRED TO PROVIDE FINRA WITH A REMEDIATION PLAN TO REMEDIATE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, THE APPLICABLE MUTUAL FUND SALES-CHARGE WAIVER. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TO PAY RESTITUTION TO ELIGIBLE CUSTOMERS, WHICH IS ESTIMATED TO TOTAL $1,035,000 (THE AMOUNT ELIGIBLE CUSTOMERS WERE OVERCHARGED, INCLUSIVE OF INTEREST). 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). AFTER AN INTERNAL REVIEW, IN DECEMBER 2015 PRINCIPAL SECURITIES SELF-REPORTED THAT CERTAIN ELIGIBLE RETIREMENT AND CHARITABLE ORGANIZATION ACCOUNT CUSTOMERS WITH MUTUAL FUNDS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS BETWEEN JULY 1, 2009 AND THAT POINT IN TIME. PRINCIPAL SECURITIES BEGAN MAKING REFUNDS TO IMPACTED ELIGIBLE CUSTOMERS AFTER IT SELF-REPORTED. FINRA ALLEGED PRINCIPAL SECURITIES HAD VIOLATED NASD CONDUCT RULE 3010 AND FINRA RULES 3110 AND 2010 BY FAILING TO IDENTIFY AND APPLY ALL AVAILABLE MUTUAL FUND SALES CHARGE WAIVERS TO ELIGIBLE CUSTOMERS AND FAILING TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS. WITHOUT ADMITTING OR DENYING THE FINDINGS, PRINCIPAL SECURITIES ACCEPTED AND CONSENTED TO CENSURE AND RESTITUTION TO THE ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT HAD NOT RECEIVED, THE APPLICABLE SALES CHARGE WAIVERS.
regulatory · block 6PDF pages 66–67
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 125,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT (1) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM RELATED TO THE USE OF CONSOLIDATED REPORTS PROVIDED TO CUSTOMERS BY ITS REGISTERED REPRESENTATIVES, AND (2) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TWO REGISTERED REPRESENTATIVES IN ONE OF THE FIRM'S BRANCH OFFICES WHO FAILED TO RETAIN COPIES OF CONSOLIDATED REPORTS IN ACCORDANCE WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT (1) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM RELATED TO THE USE OF CONSOLIDATED REPORTS PROVIDED TO CUSTOMERS BY ITS REGISTERED REPRESENTATIVES, AND (2) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TWO REGISTERED REPRESENTATIVES IN ONE OF THE FIRM'S BRANCH OFFICES WHO FAILED TO RETAIN COPIES OF CONSOLIDATED REPORTS IN ACCORDANCE WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $125,000.
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) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/21/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015043589501 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT (1) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM RELATED TO THE USE OF CONSOLIDATED REPORTS PROVIDED TO CUSTOMERS BY ITS REGISTERED REPRESENTATIVES, AND (2) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TWO REGISTERED REPRESENTATIVES IN ONE OF THE FIRM'S BRANCH OFFICES WHO FAILED TO RETAIN COPIES OF CONSOLIDATED REPORTS IN ACCORDANCE WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES. 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): 12/21/2016 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: $ 125,000.00 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 FIRM WAS CENSURED AND FINED $125,000. 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). WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT (1) FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM RELATED TO THE USE OF CONSOLIDATED REPORTS PROVIDED TO CUSTOMERS BY ITS REGISTERED REPRESENTATIVES, AND (2) FAILED TO ENFORCE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING TWO REGISTERED REPRESENTATIVES IN ONE OF THE FIRM'S BRANCH OFFICES WHO FAILED TO RETAIN COPIES OF CONSOLIDATED REPORTS IN ACCORDANCE WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.
Show 2 more source blocks
regulatory · block 7PDF pages 68–69
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 250,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FINRA FOUND THAT GAPS IN THE FIRM'S SYSTEM FOR SUPERVISING ADDITIONS TO EXISTING VARIABLE ANNUITIES RESULTED IN IMPROPER TRANSACTIONS ESCAPING DETECTION BY THE FIRM, CAUSING HARM TO CONTRACT HOLDERS. AS EXAMPLES FINRA FOUND THE FIRM DID NOT DETECT RECOMMENDED IN-AND-OUT TRADING BETWEEN A CUSTOMER'S VARIABLE ANNUITIES, WHICH RESULTED IN FREQUENT AND UNNECESSARY SURRENDER CHARGES, AND THAT THE FIRM DID NOT DETECT ANOTHER CUSTOMER'S EXCESSIVE CONCENTRATION IN A VARIABLE ANNUITY RESULTING FROM A $300,000 ADDITION TO THAT CONTRACT WHICH MORE THAN DOUBLED THE CUSTOMER'S INITIAL INVESTMENT. (PRINCIPAL SECURITIES HAS REMEDIED THE HARM TO THOSE CUSTOMERS. IN NOVEMBER 2016, FINRA BARRED THE ASSOCIATED PERSON WHO INITIATED THOSE TRANSACTIONS, MATTHEW GEISER, FROM THE BROKERAGE INDUSTRY FOR FAILING TO COOPERATE WITH FINRA'S INVESTIGATION OF THIS MATTER.) WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR AT LEAST THREE YEARS, ITS SYSTEM FOR SUPERVISING ADDITIONS TO EXISTING VARIABLE ANNUITIES WAS NOT REASONABLY DESIGNED TO ENSURE THAT THEY COMPLIED WITH APPLICABLE SECURITIES LAWS AND RULES, INCLUDING THOSE GOVERNING SUITABILITY.
Sanction detail — filed text
PRINCIPAL SECURITIES WAS CENSURED AND FINED $250,000.
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) FINRA 2. Principal Sanction: Other Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/26/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015047322502 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Annuity(ies) - Variable Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT FOR AT LEAST THREE YEARS, ITS SYSTEM FOR SUPERVISING ADDITIONS TO EXISTING VARIABLE ANNUITIES WAS NOT REASONABLY DESIGNED TO ENSURE THAT THEY COMPLIED WITH APPLICABLE SECURITIES LAWS AND RULES, INCLUDING THOSE GOVERNING SUITABILITY. 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): 10/26/2017 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: $ 250,000.00 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: PRINCIPAL SECURITIES WAS CENSURED AND FINED $250,000. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). FINRA FOUND THAT GAPS IN THE FIRM'S SYSTEM FOR SUPERVISING ADDITIONS TO EXISTING VARIABLE ANNUITIES RESULTED IN IMPROPER TRANSACTIONS ESCAPING DETECTION BY THE FIRM, CAUSING HARM TO CONTRACT HOLDERS. AS EXAMPLES FINRA FOUND THE FIRM DID NOT DETECT RECOMMENDED IN-AND-OUT TRADING BETWEEN A CUSTOMER'S VARIABLE ANNUITIES, WHICH RESULTED IN FREQUENT AND UNNECESSARY SURRENDER CHARGES, AND THAT THE FIRM DID NOT DETECT ANOTHER CUSTOMER'S EXCESSIVE CONCENTRATION IN A VARIABLE ANNUITY RESULTING FROM A $300,000 ADDITION TO THAT CONTRACT WHICH MORE THAN DOUBLED THE CUSTOMER'S INITIAL INVESTMENT. (PRINCIPAL SECURITIES HAS REMEDIED THE HARM TO THOSE CUSTOMERS. IN NOVEMBER 2016, FINRA BARRED THE ASSOCIATED PERSON WHO INITIATED THOSE TRANSACTIONS, MATTHEW GEISER, FROM THE BROKERAGE INDUSTRY FOR FAILING TO COOPERATE WITH FINRA'S INVESTIGATION OF THIS MATTER.) WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS.
regulatory · block 8PDF pages 69–71
- Regulator name — filed text
- STATE OF MAINE OFFICE OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
SETTLEMENT BY CONSENT WITHOUT ADMITTING OR DENYING VIOLATION OF THE UNIFORM SECURITIES ACT, PRINCIPAL SECURITIES AGREED TO PAY A FINE AND THAT IT WILL COMPLY WITH LICENSING AND LEGAL REQUIREMENTS OF BROKER-DEALERS IN THE STATE.
Other filed details
Description of allegations — filed text
THE SECURITIES ADMINISTRATOR, UNDER ORDER 2021-12 ISSUED ON APRIL 26, 2021, PROVIDED CONTINUED LATITUDE FOR FIRMS RELIEF FROM ON- SITE BRANCH OFFICE INSPECTIONS THROUGH THE REMAINDER OF 2021, REQUIRED ON-SITE INSPECTIONS FOR EACH BRANCH OFFICE BY DECEMBER 31, 2022, AND ORDERED FIRMS TO NOTIFY THE SECURITIES ADMINISTRATOR BY JANUARY 31, 2023 OF CERTAIN DETAILS REGARDING LOCATIONS INSPECTED ON-SITE IN 2022. PRINCIPAL SECURITIES CONTINUED TO OPERATE UNDER FINRA PANDEMIC GUIDANCE DURING THE 2022 CALENDAR YEAR, UNINTENTIONALLY IN VIOLATION OF THE MAINE ORDER AND RULE IMPLICATION. PRINCIPAL SECURITIES REPORTED TO THE SECURITIES ADMINISTRATOR THAT BRANCH INSPECTIONS FOR THE 2022 YEAR WERE COMPLETED VIRTUALLY, AND UPON RECOGNITION OF THE STATE'S ORDER, CONDUCTED ON-SITE INSPECTIONS FOR LOCATIONS IN THE STATE IN THE FIRST QUARTER OF 2023. THE SECURITIES ADMINISTRATOR'S POSITION IS THAT, BY FAILING TO CONDUCT ON-SITE INSPECTIONS, THE FIRM WAS IN VIOLATION OF ORDER 2021-12 AND RULE CH. 504(7)(4)(B).
Sanction detail — filed text
FINE PAID AND SUBMITTED WITH SIGNED CONSENT ON 8/3/2023.
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) STATE OF MAINE OFFICE OF SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 08/03/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 23-19286 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE SECURITIES ADMINISTRATOR, UNDER ORDER 2021-12 ISSUED ON APRIL 26, 2021, PROVIDED CONTINUED LATITUDE FOR FIRMS RELIEF FROM ON- SITE BRANCH OFFICE INSPECTIONS THROUGH THE REMAINDER OF 2021, REQUIRED ON-SITE INSPECTIONS FOR EACH BRANCH OFFICE BY DECEMBER 31, 2022, AND ORDERED FIRMS TO NOTIFY THE SECURITIES ADMINISTRATOR BY JANUARY 31, 2023 OF CERTAIN DETAILS REGARDING LOCATIONS INSPECTED ON-SITE IN 2022. PRINCIPAL SECURITIES CONTINUED TO OPERATE UNDER FINRA PANDEMIC GUIDANCE DURING THE 2022 CALENDAR YEAR, UNINTENTIONALLY IN VIOLATION OF THE MAINE ORDER AND RULE IMPLICATION. PRINCIPAL SECURITIES REPORTED TO THE SECURITIES ADMINISTRATOR THAT BRANCH INSPECTIONS FOR THE 2022 YEAR WERE COMPLETED VIRTUALLY, AND UPON RECOGNITION OF THE STATE'S ORDER, CONDUCTED ON-SITE INSPECTIONS FOR LOCATIONS IN THE STATE IN THE FIRST QUARTER OF 2023. THE SECURITIES ADMINISTRATOR'S POSITION IS THAT, BY FAILING TO CONDUCT ON-SITE INSPECTIONS, THE FIRM WAS IN VIOLATION OF ORDER 2021-12 AND RULE CH. 504(7)(4)(B). 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): 08/10/2023 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: $ 2,500.00 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: FINE PAID AND SUBMITTED WITH SIGNED CONSENT ON 8/3/2023. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). SETTLEMENT BY CONSENT WITHOUT ADMITTING OR DENYING VIOLATION OF THE UNIFORM SECURITIES ACT, PRINCIPAL SECURITIES AGREED TO PAY A FINE AND THAT IT WILL COMPLY WITH LICENSING AND LEGAL REQUIREMENTS OF BROKER-DEALERS IN THE STATE.
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