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 Comprehensive Wealth Management
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 Comprehensive Wealth Management.
Reported ownership and control details
Form ADV · Filing date 2026-03-31 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | BRIAN JOSEPH LOCKETTVICE PRESIDENTIndividual | COMPREHENSIVE WEALTH MANAGEMENT | Less than 5%Code NA | Yes | VICE PRESIDENT06/2013 | Schedule APDF page 18 |
| 2 | SHILO MICHELLE LOCKETTPRESIDENTIndividual | COMPREHENSIVE WEALTH MANAGEMENT | Less than 5%Code NA | Yes | PRESIDENT07/2014 | Schedule APDF page 18 |
| 3 | MORGAN LEWIS ARFORDCHIEF INVESTMENT OFFICERIndividual | COMPREHENSIVE WEALTH MANAGEMENT | Less than 5%Code NA | Yes | CHIEF INVESTMENT OFFICER06/2013 | Schedule APDF page 18 |
| 4 | FUPA, INC.MEMBERDomestic entity | COMPREHENSIVE WEALTH MANAGEMENT | 50% to less than 75%Code D | Yes | MEMBER03/2009 | Schedule APDF page 19 |
| 5 | B&S LOCKETT, INC.MEMBERDomestic entity | COMPREHENSIVE WEALTH MANAGEMENT | 50% to less than 75%Code D | Yes | MEMBER03/2009 | Schedule APDF page 19 |
| 6 | CHRISTINA A YBARRACHIEF COMPLIANCE OFFICERIndividual | COMPREHENSIVE WEALTH MANAGEMENT | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER09/2012 | Schedule APDF page 19 |
| 7 | BRIAN JOSEPH LOCKETTPRESIDENTIndividual | B&S LOCKETT, INC. | 50% to less than 75%Code D | Yes | PRESIDENT11/2006 | Schedule BPDF page 19 |
| 8 | SHILO MICHELLE LOCKETTVICE PRESIDENTIndividual | B&S LOCKETT, INC. | 50% to less than 75%Code D | Yes | VICE PRESIDENT11/2006 | Schedule BPDF page 19 |
| 9 | MORGAN LEWIS ARFORDPRESIDENTIndividual | FUPA, INC. | 75% or moreCode E | Yes | PRESIDENT01/2009 | Schedule BPDF page 19 |
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 3/31/2026 6:31:59 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 actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions3 Yes2 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions2 Yes2 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?Yes
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 3 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 1LOCKETT, BRIAN, JOSEPHPDF pages 19–21
- Advisory affiliate name — filed text
- LOCKETT, BRIAN, JOSEPH
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
SIX AND A HALF YEARS AGO, I MENTIONED TO A LONGTIME FAMILY FRIEND THAT I WAS MAKING AN INVESTMENT IN A TECHNOLOGY-RELATED COMPANY. I WAS EXCITED ABOUT THE COMPANY, AND MY FRIEND ASKED ME IF HE COULD PARTICIPATE AS WELL. I SAID YES AND HELPED HIM FILE THE PAPERWORK. I DID NOT RECEIVE ANY COMPENSATION, NOR DID I THINK I WAS ACTING AS A REPRESENTATIVE OF CWM OR THE BROKER-DEALER.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, LOCKETT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED IN A PRIVATE SECURITIES TRANSACTION WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. THE FINDINGS STATED THAT ONE OF LOCKETT'S CUSTOMERS INVESTED A TOTAL OF $50,000 IN A PRIVATE PLACEMENT OFFERING. LOCKETT PARTICIPATED IN THE TRANSACTION BY INTRODUCING THE TRANSACTION TO THE CUSTOMER, SUMMARIZING THE REASONS HE LIKED THE INVESTMENT, MEETING WITH THE CUSTOMER TO REVIEW AND SIGN THE PAPERWORK AND CAUSING THE PAPERWORK TO BE SUBMITTED. LOCKETT DID NOT RECEIVE COMPENSATION FOR HIS PARTICIPATION IN THE TRANSACTION. LOCKETT ATTEMPTED TO CONCEAL HIS ROLE IN THE TRANSACTION BY SUGGESTING TO THE CUSTOMER THAT THE CUSTOMER COMMUNICATE ABOUT THE TRANSACTION WITH LOCKETT IN THE FUTURE VIA LOCKETT'S PERSONAL EMAIL ADDRESS. AFTER THE CUSTOMER COMPLAINED TO THE FIRM, IT ENTERED INTO A SETTLEMENT TO RESOLVE THE COMPLAINT.
Sanction detail — filed text
45 DAY SUSPENSION BEGINS ON 12/2/2019 ENDS 1/15/2020. DURING THE SUSPENSION PERIOD LOCKETT MAY NOT BE ASSOCIATED WITH ANY FINRA MEMBER IN ANY CAPACITY. A FINE OF $5,000 WAS LEVIED AGAINST LOCKETT, LOCKETT AWAITS CONTACT FROM FINRA'S FINANCE DEPARTMENT REGARDING PAYMENT. NO PORTION OF THE PENALTY WAS WAIVED.
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: 4573162 This advisory affiliate is a Firm an Individual Registered: Yes No Name: LOCKETT, BRIAN, JOSEPH (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINANCIAL INDUSTRY REGULATORY AUTHORITY 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/12/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016050847301 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): GENEOS WEALTH MANAGEMENT INC 6. Principal Product Type: Other Other Product Types: UNSPECIFIED SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, LOCKETT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED IN A PRIVATE SECURITIES TRANSACTION WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. THE FINDINGS STATED THAT ONE OF LOCKETT'S CUSTOMERS INVESTED A TOTAL OF $50,000 IN A PRIVATE PLACEMENT OFFERING. LOCKETT PARTICIPATED IN THE TRANSACTION BY INTRODUCING THE TRANSACTION TO THE CUSTOMER, SUMMARIZING THE REASONS HE LIKED THE INVESTMENT, MEETING WITH THE CUSTOMER TO REVIEW AND SIGN THE PAPERWORK AND CAUSING THE PAPERWORK TO BE SUBMITTED. LOCKETT DID NOT RECEIVE COMPENSATION FOR HIS PARTICIPATION IN THE TRANSACTION. LOCKETT ATTEMPTED TO CONCEAL HIS ROLE IN THE TRANSACTION BY SUGGESTING TO THE CUSTOMER THAT THE CUSTOMER COMMUNICATE ABOUT THE TRANSACTION WITH LOCKETT IN THE FUTURE VIA LOCKETT'S PERSONAL EMAIL ADDRESS. AFTER THE CUSTOMER COMPLAINED TO THE FIRM, IT ENTERED INTO A SETTLEMENT TO RESOLVE THE COMPLAINT. 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): 11/12/2019 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: $ 5,000.00 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: 45 DAY SUSPENSION BEGINS ON 12/2/2019 ENDS 1/15/2020. DURING THE SUSPENSION PERIOD LOCKETT MAY NOT BE ASSOCIATED WITH ANY FINRA MEMBER IN ANY CAPACITY. A FINE OF $5,000 WAS LEVIED AGAINST LOCKETT, LOCKETT AWAITS CONTACT FROM FINRA'S FINANCE DEPARTMENT REGARDING PAYMENT. NO PORTION OF THE 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). SIX AND A HALF YEARS AGO, I MENTIONED TO A LONGTIME FAMILY FRIEND THAT I WAS MAKING AN INVESTMENT IN A TECHNOLOGY-RELATED COMPANY. I WAS EXCITED ABOUT THE COMPANY, AND MY FRIEND ASKED ME IF HE COULD PARTICIPATE AS WELL. I SAID YES AND HELPED HIM FILE THE PAPERWORK. I DID NOT RECEIVE ANY COMPENSATION, NOR DID I THINK I WAS ACTING AS A REPRESENTATIVE OF CWM OR THE BROKER-DEALER.
regulatory · block 2LOCKETT, BRIAN, JOSEPHPDF pages 21–23
- Advisory affiliate name — filed text
- LOCKETT, BRIAN, JOSEPH
- Regulator name — filed text
- STATE OF CALIFORNIA INSURANCE COMMISSION
- Monetary/Fine Amount — filed text
- $ 850.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
INCORRECTLY ASSUMED THAT UPDATING MY CRD ENTRY WOULD NOTIFY THE INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA (CA) OF A CHANGE IN BACKGROUND INFORMATION, WHICH RESULTED IN A SMALL FINE. THE UNDERLYING MATTER DID NOT INVOLVE AN INSURANCE PRODUCT, AND I HAVE NEVER BEEN FOUND BY A REGULATORY AGENCY, COURT, OR ARBITRATION PANEL TO HAVE VIOLATED ANY INSURANCE REGULATION.
Other filed details
Description of allegations — filed text
FAILURE TO NOTIFY THE CA DEPARTMENT OF INSURANCE REGARDING A FINRA DISCIPLINARY ACTION IN A TIMELY MANNER.
Sanction detail — filed text
$500 PENALTY, $350 REIMBURSEMENT. THE FINE WAS PAID ON JUNE 22, 2020
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 4573162 This advisory affiliate is a Firm an Individual Registered: Yes No Name: LOCKETT, BRIAN, JOSEPH (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF CALIFORNIA INSURANCE COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/08/2020 Exact Explanation If not exact, provide explanation: ORDER NOT FINALIZED UNTIL 5.27.2020 4. Docket/Case Number: OBS 3922-A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): COMPREHENSIVE WEALTH MANAGEMENT, LLC 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FAILURE TO NOTIFY THE CA DEPARTMENT OF INSURANCE REGARDING A FINRA DISCIPLINARY ACTION IN A TIMELY MANNER. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 05/27/2020 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 850.00 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: $500 PENALTY, $350 REIMBURSEMENT. THE FINE WAS PAID ON JUNE 22, 2020 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). INCORRECTLY ASSUMED THAT UPDATING MY CRD ENTRY WOULD NOTIFY THE INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA (CA) OF A CHANGE IN BACKGROUND INFORMATION, WHICH RESULTED IN A SMALL FINE. THE UNDERLYING MATTER DID NOT INVOLVE AN INSURANCE PRODUCT, AND I HAVE NEVER BEEN FOUND BY A REGULATORY AGENCY, COURT, OR ARBITRATION PANEL TO HAVE VIOLATED ANY INSURANCE REGULATION.
regulatory · block 3LOCKETT, BRIAN, JOSEPHPDF pages 23–25
- Advisory affiliate name — filed text
- LOCKETT, BRIAN, JOSEPH
- Regulator name — filed text
- STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
AS PREVIOUSLY SHARED IN A DISCLOSURE SIMILAR TO THIS ONE, IN 2019, I REACHED AN AGREEMENT WITH FINRA RELATING TO AN ISSUE THAT TOOK PLACE MORE THAN 8-YEAS AGO, WHERE I MENTIONED TO A LONG-TIME FAMILY FRIEND THAT I WAS MAKING AN INVESTMENT IN A TECHNOLOGY-RELATED COMPANY. I WAS EXCITED ABOUT THE COMPANY, AND MY FRIEND ASKED IF HE COULD PARTICIPATE AS WELL. I SAID YES AND HELPED HIM FILE THE PAPERWORK. SEEING THE ACTIONS THAT FINRA TOOK, DFI DECIDED TO REVIEW THE MATTER AS WELL AND IMPOSED THEIR OWN SANCTION. I DID NOT RECEIVE ANY COMPENSATION, NOR DID I THINK I WAS ACTING AS A REPRESENTATIVE OF CWM OR THE BROKER-DEALER.
Other filed details
Description of allegations — filed text
PURSUANT TO THE SECURITIES ACT OF WASHINGTON, RCW 21.20, THE SECURITIES DIVISION OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS (SECURITIES DIVISION) AND RESPONDENT BRIAN J, LOCKETT DO HEREBY ENTER INTO THIS CONSENT ORDER IN SETTLEMENT OF THE MATTERS ALLEGED HEREIN.
Sanction detail — filed text
MONETARY PENALTY AND INVESTIGATIVE COSTS WERE PAID ON 11/10/2020. THE 45 DAY SUSPENSION WAS SERVED RETROACTIVE 12/2/2019 - 1/15/2020
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 4573162 This advisory affiliate is a Firm an Individual Registered: Yes No Name: LOCKETT, BRIAN, JOSEPH (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF WASHINGTON DEPARTMENT OF FINANCIAL INSTITUTIONS SECURITIES DIVISION 2. Principal Sanction: Suspension Other Sanctions: CIVIL AND ADMINISTRATIVE PENALT(IES)/FINE(S) 3. Date Initiated (MM/DD/YYYY): 11/10/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: S-202882-20-CO01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): COMPREHENSIVE WEALTH MANAGEMENT 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): PURSUANT TO THE SECURITIES ACT OF WASHINGTON, RCW 21.20, THE SECURITIES DIVISION OF THE DEPARTMENT OF FINANCIAL INSTITUTIONS (SECURITIES DIVISION) AND RESPONDENT BRIAN J, LOCKETT DO HEREBY ENTER INTO THIS CONSENT ORDER IN SETTLEMENT OF THE MATTERS ALLEGED HEREIN. 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): 11/10/2020 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 5,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: INVESTIGATIVE COSTS $2,550.00 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: MONETARY PENALTY AND INVESTIGATIVE COSTS WERE PAID ON 11/10/2020. THE 45 DAY SUSPENSION WAS SERVED RETROACTIVE 12/2/2019 - 1/15/2020 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). AS PREVIOUSLY SHARED IN A DISCLOSURE SIMILAR TO THIS ONE, IN 2019, I REACHED AN AGREEMENT WITH FINRA RELATING TO AN ISSUE THAT TOOK PLACE MORE THAN 8-YEAS AGO, WHERE I MENTIONED TO A LONG-TIME FAMILY FRIEND THAT I WAS MAKING AN INVESTMENT IN A TECHNOLOGY-RELATED COMPANY. I WAS EXCITED ABOUT THE COMPANY, AND MY FRIEND ASKED IF HE COULD PARTICIPATE AS WELL. I SAID YES AND HELPED HIM FILE THE PAPERWORK. SEEING THE ACTIONS THAT FINRA TOOK, DFI DECIDED TO REVIEW THE MATTER AS WELL AND IMPOSED THEIR OWN SANCTION. I DID NOT RECEIVE ANY COMPENSATION, NOR DID I THINK I WAS ACTING AS A REPRESENTATIVE OF CWM OR THE BROKER-DEALER.
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