Firm profile

Planmember Securities Corporation

CARPINTERIA, CACRD 11869Registration Status: ApprovedEffective since June 27, 1991SEC # 801-39177Latest ADV September 17, 2026

Planmember Securities Corporation is an SEC registered investment adviser organized as a corporation with a primary office location in Carpinteria, CA. Its latest Form ADV filing, dated September 17, 2026, reports $10.1B in regulatory assets under management, 429 employees, 351 offices, and 69,645 accounts.

Assets Under Management
$10.1B
Employees
429
Offices
351 offices
Total Clients
69,645

Associated firm names

3 names listed
  • INVESTORS RETIREMENT & MANAGEMENT CORPORATION
  • PLANMEMBER SECURITIES CORPORATION
  • IRM DISTRIBUTORS, INC.

Leadership

3 roles identified
CCOSean Patrick Haley
CFOSteven R Hanson
COOTerrall Joseph Janeway

Advisory services offered

7 types reported
Educational seminars/workshops
Financial Planning Services
Other advisory services

Fee models offered

4 types reported
Asset based fees
Commissions
Fixed fees

Offices & Contact

Primary office

CARPINTERIA, California, 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.

California

CARPINTERIAPrimary office · CAMPBELL · SAN DIEGO · RIVERSIDE · LOS ANGELES · SANTA BARBARA

Alabama

BIRMINGHAM

Alaska

ANCHORAGE

Florida

WINTER SPRINGS · WESTON

Hawaii

MILILANI

Illinois

NAPERVILLE

Maryland

ELKRIDGE

Michigan

GRANDVILLE

Nevada

RENO · HENDERSON

New York

IRVINGTON · FARMINGVILLE

Texas

CORPUS CHRISTI · HOUSTON · RICHARDSON

Utah

KAYSVILLE

Virginia

WINCHESTER

Washington

SPANAWAY · PUYALLUP · EAST WENATCHEE

26 office records listed · 351 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$10.1Bas of September 17, 2026
Discretionary100.0%
$10.1B
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 98.4% of total clients.
Top client categories% of clientsClients
1
Individuals
98.4%
68,543
2
HNWI
1.3%
898
3
Pension Plans
0.2%
126
4
Corporations
0.1%
56
Additional categories (<0.1%)
Charitable22 clients

Assets under management Growth by Quarter

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

Total AUM$10.1B
Total Accounts69,645
10Y AUM Change+$7.0B (+221.3%)

Private Funds

Private funds reported by Planmember Securities Corporation

Loading private fund disclosures…

Employee Growth by Quarter

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

Total Employees429
Clients per Employee162:1
10Y Employee Change-206 (-32.4%)

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%
PLANMEMBER FINANCIAL CORPORATIONDirect owner · Schedule AInterest in PLANMEMBER SECURITIES CORPORATION
75%+
JON MICHAEL ZIEHLIndirect owner · Schedule BInterest in PLANMEMBER FINANCIAL CORPORATION
75%+
EQUITABLE HOLDINGS INC.Indirect owner · Schedule BInterest in EQUITABLE FINANCIAL SERVICES, LLC
75%+
EQUITABLE FINANCIAL SERVICES, LLCIndirect owner · Schedule BInterest in EQUITABLE DISTRIBUTION HOLDING CORPORATION
75%+
EQUITABLE DISTRIBUTION HOLDING CORPORATIONIndirect owner · Schedule BInterest in PLANMEMBER FINANCIAL CORPORATION
25% to < 50%

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 Planmember Securities Corporation.

Reported ownership and control details

Form ADV · Filing date 2026-09-17 · Schedules A and B

10 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1JON MICHAEL ZIEHLPRESIDENTIndividualPLANMEMBER SECURITIES CORPORATIONLess than 5%Code NAYesPRESIDENT09/1984Schedule APDF page 34
2PLANMEMBER FINANCIAL CORPORATIONOWNERDomestic entityPLANMEMBER SECURITIES CORPORATION75% or moreCode ENoOWNER12/1991Schedule APDF page 34
3TERRALL JOSEPH JANEWAYEVP/CHIEF OPERATING OFFICERIndividualPLANMEMBER SECURITIES CORPORATIONLess than 5%Code NAYesEVP/CHIEF OPERATING OFFICER06/2022Schedule APDF page 34
4BYRON FRANCIS BOWMANCHIEF LEGAL OFFICER & SECRETARYIndividualPLANMEMBER SECURITIES CORPORATIONLess than 5%Code NANoCHIEF LEGAL OFFICER & SECRETARY02/2014Schedule APDF page 34
5SEAN PATRICK HALEYCHIEF COMPLIANCE OFFICERIndividualPLANMEMBER SECURITIES CORPORATIONLess than 5%Code NANoCHIEF COMPLIANCE OFFICER03/2019Schedule APDF page 34
6STEVEN R HANSONCHIEF FINANCIAL OFFICER / FINOPSIndividualPLANMEMBER SECURITIES CORPORATIONLess than 5%Code NAYesCHIEF FINANCIAL OFFICER / FINOPS01/2024Schedule APDF page 34
7EQUITABLE DISTRIBUTION HOLDING CORPORATIONSHAREHOLDER SERIES E PREFERREDDomestic entityPLANMEMBER FINANCIAL CORPORATION25% to less than 50%Code CYesSHAREHOLDER SERIES E PREFERRED02/2013Schedule BPDF page 35
8JON MICHAEL ZIEHLPRESIDENTIndividualPLANMEMBER FINANCIAL CORPORATION75% or moreCode EYesPRESIDENT09/1984Schedule BPDF page 35
9EQUITABLE HOLDINGS INC.MEMBERDomestic entityEQUITABLE FINANCIAL SERVICES, LLC75% or moreCode EYesMEMBER10/2018Schedule BPDF page 35
10EQUITABLE FINANCIAL SERVICES, LLCSHAREHOLDERDomestic entityEQUITABLE DISTRIBUTION HOLDING CORPORATION75% or moreCode EYesSHAREHOLDER06/2002Schedule BPDF page 35

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 9/17/2026 11:24:12 AM

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 actions3 Yes2 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 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?No
  • 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?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 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 1PDF pages 35–37
Regulator name — filed text
FINANCIAL INDUSTRY REGULATORY AUTHORITY
Monetary/Fine Amount — filed text
$ 90,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

DURING THE PERIOD JULY 2012 TO JUNE 2016, APPLICANT IS ALLEGED TO HAVE FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO FOUR ASPECTS OF ITS BUSINESS: THE REVIEW OF VARIABLE ANNUITY EXCHANGES; THE REVIEW, APPROVAL, AND RETENTION OF CONSOLIDATED REPORTS; THE REVIEW OR E-MAIL AND CUSTOMER CORRESPONDENCE; AND THE REVIEW OR ITS REGISTERED REPRESENTATIVES' BUSINESS-RELATED WEBSITES AND SOCIAL MEDIA IN VIOLATION OF FINRA RULES 3010, 3110, 2330(D)(1), 2210, AND 2010. ON JULY 3, 2019, THE APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FINRA, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") TO SETTLE THE ALLEGED VIOLATIONS. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT CONSENTED TO A CENSURE AND A MONETARY FINE OF $90,000.
Other filed details

Description of allegations — filed text

DURING THE PERIOD JULY 2012 AND JUNE 2016, PLANMEMBER FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS, AND WITH APPLICABLE NASD AND FINRA RULES, WITH RESPECT TO FOUR ASPECTS OF ITS BUSINESS: (1) THE REVIEW OF VARIABLE ANNUITY EXCHANGES; (2) THE REVIEW, APPROVAL, AND RETENTION OF CONSOLIDATED REPORTS; (3) THE REVIEW OF E-MAIL AND CUSTOMER CORRESPONDENCE; AND (4) THE REVIEW OF ITS REGISTERED REPRESENTATIVES' BUSINESS-RELATED WEBSITES AND SOCIAL MEDIA.

Sanction detail — filed text

A FINE OF $90,000.00 WAS LEVIED; THIS FINE WAS PAID ON JULY 27, 2019.
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Censure
Other Sanctions: 
A FINE OF $90,000.00
3.
Date Initiated (MM/DD/YYYY): 
07/03/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015047824201
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):
DURING THE PERIOD JULY 2012 AND JUNE 2016, PLANMEMBER FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING
WRITTEN SUPERVISORY PROCEDURES, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS,
AND WITH APPLICABLE NASD AND FINRA RULES, WITH RESPECT TO FOUR ASPECTS OF ITS BUSINESS: (1) THE REVIEW OF VARIABLE ANNUITY
EXCHANGES; (2) THE REVIEW, APPROVAL, AND RETENTION OF CONSOLIDATED REPORTS; (3) THE REVIEW OF E-MAIL AND CUSTOMER
CORRESPONDENCE; AND (4) THE REVIEW OF ITS REGISTERED REPRESENTATIVES' BUSINESS-RELATED WEBSITES AND SOCIAL MEDIA.
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):
07/03/2019
 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: $ 90,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
A FINE OF $90,000.00 WAS LEVIED; THIS FINE WAS PAID ON JULY 27, 2019.
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).
DURING THE PERIOD JULY 2012 TO JUNE 2016, APPLICANT IS ALLEGED TO HAVE FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY
SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH RESPECT TO FOUR ASPECTS OF ITS BUSINESS: THE REVIEW OF VARIABLE ANNUITY
EXCHANGES; THE REVIEW, APPROVAL, AND RETENTION OF CONSOLIDATED REPORTS; THE REVIEW OR E-MAIL AND CUSTOMER CORRESPONDENCE;
AND THE REVIEW OR ITS REGISTERED REPRESENTATIVES' BUSINESS-RELATED WEBSITES AND SOCIAL MEDIA IN VIOLATION OF FINRA RULES 3010,
3110, 2330(D)(1), 2210, AND 2010. ON JULY 3, 2019, THE APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FINRA, ENTERED INTO A
LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") TO SETTLE THE ALLEGED VIOLATIONS. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT
CONSENTED TO A CENSURE AND A MONETARY FINE OF $90,000.
regulatory · block 2PDF pages 37–39
Regulator name — filed text
FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.
Monetary/Fine Amount — filed text
$ 18,500.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

DURING THE PERIOD OCTOBER 1, 2015, THROUGH DECEMBER 31, 2015, APPLICANT IS ALLEGED TO HAVE COMMITTED MUNICIPAL SECURITIES FAIR PRICING AND RELATED SUPERVISION VIOLATIONS WITH RESPECT TO 8 TRANSACTIONS IN 3 ACCOUNTS, IN VIOLATION OF MSRB RULES G-17, G-27, AND G-30. ON JANUARY 18, 2018, THE APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FINRA, ENTERED INTO A LETTER OF ACCEPTANCE, WAIVER, AND CONSENT ("AWC") TO SETTLE THE ALLEGED VIOLATIONS. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT CONSENTED TO THE SANCTIONS DESCRIBED IN ITEM 12., ABOVE.
Other filed details

Description of allegations — filed text

DURING THE PERIOD OCTOBER 2, 2015, THROUGH DECEMBER 31, 2015, APPLICANT IS ALLEGED TO HAVE COMMITTED MUNICIPAL SECURITIES FAIR PRICING AND RELATED SUPERVISION VIOLATIONS WITH RESPECT TO 8 TRANSACTION IN 3 ACCOUNTS, IN VIOLATION OF MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB") RULES G-17, G-27, AND G-30.

Sanction detail — filed text

A FINE OF $18,500 ($12,500 FOR THE FAIR PRICING VIOLATIONS AND $6,000 FOR THE SUPERVISION VIOLATIONS) AND RESTITUTION IN THE AMOUNT OF $5,808.25, PLUS INTEREST, WAS LEVIED AGAINST THE APPLICANT. THE TOTAL AMOUNT WAS PAID ON JANUARY 18, 2018.
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE RESTITUTION UNDERTAKING
3.
Date Initiated (MM/DD/YYYY): 
01/18/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20160491831-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NOT APPLICABLE.
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD OCTOBER 2, 2015, THROUGH DECEMBER 31, 2015, APPLICANT IS ALLEGED TO HAVE COMMITTED MUNICIPAL SECURITIES FAIR
PRICING AND RELATED SUPERVISION VIOLATIONS WITH RESPECT TO 8 TRANSACTION IN 3 ACCOUNTS, IN VIOLATION OF MUNICIPAL SECURITIES
RULEMAKING BOARD ("MSRB") RULES G-17, G-27, AND G-30.
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):
01/18/2018
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 18,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction

 Bar
 Suspension
B.
Other Sanctions Ordered:
AN UNDERTAKING TO REVISE THE APPLICANT'S WRITTEN SUPERVISORY PROCEDURES TO ACHIEVE COMPLIANCE WITH RESPECT TO THE
APPLICABLE SECURITIES LAWS AND REGULATIONS, AND THE RULES OF THE MSRB, CONCERNING MUNICIPAL SECURITIES FAIR PRICING.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
A FINE OF $18,500 ($12,500 FOR THE FAIR PRICING VIOLATIONS AND $6,000 FOR THE SUPERVISION VIOLATIONS) AND RESTITUTION IN THE
AMOUNT OF $5,808.25, PLUS INTEREST, WAS LEVIED AGAINST THE APPLICANT. THE TOTAL AMOUNT WAS PAID ON JANUARY 18, 2018.
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).
DURING THE PERIOD OCTOBER 1, 2015, THROUGH DECEMBER 31, 2015, APPLICANT IS ALLEGED TO HAVE COMMITTED MUNICIPAL SECURITIES FAIR
PRICING AND RELATED SUPERVISION VIOLATIONS WITH RESPECT TO 8 TRANSACTIONS IN 3 ACCOUNTS, IN VIOLATION OF MSRB RULES G-17, G-27,
AND G-30. ON JANUARY 18, 2018, THE APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF FINRA, ENTERED INTO A LETTER OF
ACCEPTANCE, WAIVER, AND CONSENT ("AWC") TO SETTLE THE ALLEGED VIOLATIONS. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT
CONSENTED TO THE SANCTIONS DESCRIBED IN ITEM 12., ABOVE.
regulatory · block 3PDF pages 39–41
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
How was matter resolved — filed text
Decision & Order of Offer of Settlement

Action status / disposition — filed text

AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO JUNE 30, 2018 (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 AND ITS ASSOCIATED PERSONS 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 AND ITS ASSOCIATED PERSONS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. THE APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF THE SEC, SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED. THE APPLICANT CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ON MARCH 22, 2019. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT CONSENTED TO THE SANCTIONS DESCRIBED IN ITEM 12, ABOVE.
Other filed details

Description of allegations — filed text

AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO JUNE 30, 2018 (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 AND ITS ASSOCIATED PERSONS 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 AND ITS ASSOCIATED PERSONS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES.

Sanction detail — filed text

DISGORGEMENT OF $3,168,810.93 AND PREJUDGMENT INTEREST OF $381,849.55 (TOTAL: $3,550,660.48) TO BE PAID TO CLIENTS THROUGH A DISTRIBUTION FUND ESTABLISHED PURSUANT TO THE TERMS OF THE ORDER. THE TOTAL AMOUNT WAS DEPOSITED WITH AN ESCROW AGENT FOR THE DISTRIBUTION FUND ON MARCH 15, 2019. NO CIVIL PENALTY WAS IMPOSED BASED UPON THE APPLICANT'S SELF-REPORT IN THE SCSD INITIATIVE.
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:
Disgorgement
Other Sanctions: 
CEASE AND DESIST; CENSURE; UNDERTAKINGS.
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING NO. 3-19080
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: 
INVESTMENT ADVISORY SERVICES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO JUNE 30, 2018 (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 AND ITS ASSOCIATED PERSONS 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 AND
ITS ASSOCIATED PERSONS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision & Order of Offer of Settlement
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 TO (A) REVIEW AND CORRECT ALL RELEVANT DISCLOSURE DOCUMENTS; (B) MOVE EXISTING CLIENTS TO A LOWER-COST FUND
CLASS AS NECESSARY; (C) UPDATE APPLICANT'S POLICIES AND PROCEDURES TO PREVENT VIOLATIONS OF THE ADVISERS ACT; (D) NOTIFY
AFFECTED CLIENTS OF THE SETTLEMENT TERMS OF THE ORDER; AND (E) COMPLY WITH ADDITIONAL UNDERTAKINGS AS TO DISGORGEMENT.
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: 
DISGORGEMENT OF $3,168,810.93 AND PREJUDGMENT INTEREST OF $381,849.55 (TOTAL: $3,550,660.48) TO BE PAID TO CLIENTS THROUGH A
DISTRIBUTION FUND ESTABLISHED PURSUANT TO THE TERMS OF THE ORDER. THE TOTAL AMOUNT WAS DEPOSITED WITH AN ESCROW AGENT
FOR THE DISTRIBUTION FUND ON MARCH 15, 2019. NO CIVIL PENALTY WAS IMPOSED BASED UPON THE APPLICANT'S SELF-REPORT IN THE SCSD
INITIATIVE.
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).
AT TIMES DURING THE PERIOD JANUARY 1, 2014 TO JUNE 30, 2018 (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 AND ITS ASSOCIATED PERSONS 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 AND
ITS ASSOCIATED PERSONS RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH MUTUAL FUND SHARE CLASSES. THE
APPLICANT, WITHOUT ADMITTING OR DENYING THE FINDINGS OF THE SEC, SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED. THE
APPLICANT CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS. PURSUANT TO SECTIONS
203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST
ORDER ON MARCH 22, 2019. AS CONDITIONS OF ITS SETTLEMENT, THE APPLICANT CONSENTED TO THE SANCTIONS DESCRIBED IN ITEM 12, ABOVE.

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