Firm profile

Principal Securities, Inc..

DES MOINES, IACRD 1137Registration Status: ApprovedEffective since October 10, 1997SEC # 801-54949Latest ADV March 30, 2026

Principal Securities, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Des Moines, IA. Its latest Form ADV filing, dated March 30, 2026, reports $17.0B in regulatory assets under management, 1,464 employees, 359 offices, and 68,981 accounts.

Assets Under Management
$17.0B
Employees
1,464
Offices
359 offices
Total Clients
51,941

Associated firm names

5 names listed
  • BLC EQUITY SERVICES CORPORATION
  • PRINCOR FINANCIAL/ SERVICES CORPORATION
  • PRINCOR FINANCIAL SERVICES CORPORATION
  • PRINCIPAL SECURITIES, INC.

Leadership

3 roles identified
CEOMichael Francis Murray
CCOThomas John Drogan
CFODawn Marie Roberts

Advisory services offered

6 types reported
Educational seminars/workshops
Financial Planning Services
Pension consulting services

Fee models offered

4 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

DES MOINES, Iowa, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Iowa

DES MOINESPrimary office · WEST DES MOINES · HIAWATHA · BETTENDORF

Alabama

BIRMINGHAM

California

ROSEVILLE · SAN DIEGO

Colorado

DENVER

Florida

TAMPA · JACKSONVILLE

Georgia

ATLANTA

Illinois

DOWNERS GROVE

Kansas

OVERLAND PARK

Michigan

GRAND RAPIDS

Minnesota

LAKE ELMO · MINNETONKA

Missouri

CHESTERFIELD

Nebraska

ELKHORN

New York

MELVILLE

North Carolina

CHARLOTTE · RALEIGH

Pennsylvania

WAYNE

South Dakota

SIOUX FALLS

Texas

HOUSTON · ADDISON

Wisconsin

WAUWATOSA

26 office records listed · 359 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$17.0Bas of March 30, 2026
Discretionary83.1%
$14.1B
83% of total RAUM83.1%
Non-discretionary16.9%
$2.9B
17% of total RAUM16.9%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 94.4% of total clients.
Top client categories% of clientsClients
1
Individuals
94.4%
49,012
2
HNWI
5.1%
2,638
3
Corporations
0.4%
221
4
Charitable
0.1%
41
5
Pension Plans
0.1%
29

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$17.0B
Total Accounts68,981
10Y AUM Change+$15.1B (+788.4%)

Private Funds

Private funds reported by Principal Securities, Inc..

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees1,464
Clients per Employee35:1
10Y Employee Change-283 (-16.2%)

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

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
PRINCIPAL FINANCIAL SERVICES, INC.Direct owner · Schedule AInterest in PRINCIPAL SECURITIES, INC.
75%+
PRINCIPAL FINANCIAL GROUP INC.Indirect owner · Schedule BInterest in PRINCIPAL FINANCIAL SERVICES, INC.
75%+

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

14 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1PRINCIPAL FINANCIAL SERVICES, INC.OWNERDomestic entityPRINCIPAL SECURITIES, INC.75% or moreCode EYesOWNER10/2001Schedule APDF page 55
2MICHAEL FRANCIS MURRAYPRESIDENT/CHIEF EXECUTIVE OFFICER/CHAIRIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesPRESIDENT/CHIEF EXECUTIVE OFFICER/CHAIR07/2018Schedule APDF page 55
3AMY CHRISTINE FRIEDRICHDIRECTORIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesDIRECTOR05/2019Schedule APDF page 55
4DOUGLAS JOHN RANTSCHIEF INFORMATION SECURITY OFFICERIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesCHIEF INFORMATION SECURITY OFFICER12/2019Schedule APDF page 55
5CRAIG ALAN SPADAFORASENIOR VICE PRESIDENT / HEAD OF ADVISORY AND PLATFORMIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesSENIOR VICE PRESIDENT / HEAD OF ADVISORY AND PLATFORM12/2019Schedule APDF page 55
6CHAD THOMAS CLAIRECHIEF INFORMATION OFFICERIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesCHIEF INFORMATION OFFICER12/2019Schedule APDF page 56
7DANIEL SIMON VANWINKLEPSI AML OFFICERIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesPSI AML OFFICER03/2021Schedule APDF page 56
8KENNETH ALLEN MCCULLUMDIRECTORIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesDIRECTOR05/2021Schedule APDF page 56
9THOMAS JOHN DROGANCHIEF COMPLIANCE OFFICERIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesCHIEF COMPLIANCE OFFICER05/2024Schedule APDF page 56
10CODY ANTHONY LAWLERHEAD OF SUPERVISION, HEAD OF OPERATIONSIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesHEAD OF SUPERVISION, HEAD OF OPERATIONS05/2024Schedule APDF page 56
11NATHAN PAUL SCHELHAASDIRECTORIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesDIRECTOR12/2024Schedule APDF page 56
12DAWN MARIE ROBERTSCHIEF FINANCIAL OFFICERIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesCHIEF FINANCIAL OFFICER12/2024Schedule APDF page 56
13VIVEK AGRAWALDIRECTORIndividualPRINCIPAL SECURITIES, INC.Less than 5%Code NAYesDIRECTOR03/2025Schedule APDF page 56
14PRINCIPAL FINANCIAL GROUP INC.OWNERDomestic entityPRINCIPAL FINANCIAL SERVICES, INC.75% or moreCode EYesOWNER10/2001Schedule 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.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
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.

* 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.