Gunn & Company Investment Management, Inc..

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
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. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
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:
1210021
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GUNN, MARSHALL, DEAN
(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.
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.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
FORMAL CHARGES WERE BROUGHT IN THE STATE OF FLORIDA, DEPARTMENT OF BUSINESS AND PROFESSIONAL REGULATION, TALLAHASSEE, FLORIDA,
CASE 2021-058604.
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
06/15/2023
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
ON 6/29/20 THE SEC ENTERED A FINAL JUDGMENT AGAINST MR. GUNN RESTRAINING AND ENJOINING HIM FROM VIOLATING SECTION 10(B) AND
15(A) OF THE EXCHANGE ACT AND RULE 10B-5, SECTION 17(A) AND SECTION 5 OF THE SECURITIES ACT AND FOUND THAT HE MADE FALSE AND
MISLEADING STATEMENTS REGARDING A FALSE CMO TRADING PROGRAM. COUNT I - BASED ON THE FOREGOING, MR. GUNN ALLEGEDLY VIOLATED
SECTION 473.323(1)(G), FLORIDA STATUTES (2022), BY COMMITTING AN ACT OF FRAUD, DECEIT, NEGLIGENCE, INCOMPETENCY, OR MISCONDUCT
BY MAKING FALSE AND MISLEADING STATEMENTS REGARDING A NON-EXISTENT CMO TRADING PROGRAM. THIS IS A MISDEMEANOR. COUNT II -
BASED ON THE FOREGOING, MR. GUNN ALLEGEDLY VIOLATED SECTION 473.323(1)(A), FLORIDA STATUTES, THROUGH A VIOLATION OF SECTION
455.227(1)(F) FOR HAVING HIS RIGHT TO PRACTICE BEFORE THE SEC RETAINED AND ENJOINED AS WELL AS BEING ORDERED TO PAY
DISGORGEMENT. THIS IS A MISDEMEANOR. MR. GUNN DISPUTED THE ALLEGATIONS OF MATERIAL FACT AND ATTENDED AN INFORMAL HEARING ON
2/9/24.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
03/05/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
MR. GUNN DISPUTED THE ALLEGATIONS OF MATERIAL FACT AND WAS ISSUED AN INFORMAL HEARING ON 2/9/24. ON THAT DATE THE CHARGES IN
COUNT I WERE DISMISSED. ALSO ON THAT DATE THE CHARGES IN COUNT II WERE APPROVED AND MR. GUNN'S CPA LICENSE WAS REPRIMANDED, MR.
GUNN WAS ORDERED TO PAY $25,000 IN AN ADMINISTRATIVE FINE AS WELL AS $205.21 IN INVESTIGATIVE COSTS. THE MONIES ARE TO BE PAID
WITHIN 30 DAYS OF 3/5/24.

5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
IN DECEMBER 2013, ONE OF GCIM'S SHAREHOLDERS, MARSHALL D. GUNN, JR., WAS PERSONALLY NAMED IN A COMPLAINT BY THE SEC. IN JUNE 2020,
THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO ENTERED A FINAL CONSENT JUDGMENT AGAINST MARSHALL D. GUNN, JR., IN CONNECTION
WITH HIS ROLE IN A PRIME BANK SCHEME ORCHESTRATED BY DANIEL DIRK CODDINGTON. THE SEC'S COMPLAINT ALLEGES THAT CODDINGTON
DEFRAUDED INVESTORS BY SOLICITING INVESTMENTS IN COLLATERALIZED MORTGAGE OBLIGATIONS ("CMO"S). ACCORDING TO THE SEC'S
COMPLAINT, GUNN ALLEGEDLY MADE FALSE AND MISLEADING STATEMENTS ABOUT THE TRADING PROGRAM TO SOLICIT INVESTORS. GUNN CONSENTED
TO ENTRY OF A FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, AND AGREED TO BE PERMANENTLY
ENJOINED FROM FUTURE VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933 (THE "SECURITIES ACT"),
AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 (THE "EXCHANGE ACT") AND RULE 10B-5 THEREUNDER AND THE SECURITIES
REGISTRATION PROVISIONS OF SECTIONS 5(A) AND (C) OF THE SECURITIES ACT AND THE BROKER-DEALER REGISTRATION PROVISION OF SECTION
15(A) OF THE EXCHANGE ACT. GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF
$50,000. AN ADMINISTRATIVE COMPLAINT FROM THE STATE OF FLORIDA NAMING THE ABOVE-MENTIONED VIOLATIONS OF FLORIDA STATUTES
FOLLOWED ON 6/15/23. MR. GUNN ATTENDED AN INFORMAL HEARING ON 2/9/24 DURING WHICH TIME COUNT I OF THE ALLEGATIONS WAS DISMISSED
AND COUNT II RESULTED IN MR. GUNN'S CPA LICESE BEING REPRIMANDED, MR. GUNN BEING ORDERED TO PAY $25,000 IN ADMINISTRATIVE FINE AS
WELL AS $205.21 IN INVESTIGATIVE COSTS.

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:
1210021
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GUNN, MARSHALL, DEAN
(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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Disgorgement
Other Sanctions: 
GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.
3.
Date Initiated (MM/DD/YYYY): 
12/12/2013
 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
Other Product Types: 
COLLATERALIZED MORTGAGE OBLIGATIONS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DECEMBER 13, 2013: THE SECURITIES AND EXCHANGE COMMISSION FILED A CIVIL LAWSUIT INJUNCTION ON DECEMBER 12, 2013, IN THE UNITED
STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO AGAINST A COLORADO RESIDENT, HIS COMPANY, AND OTHERS WHO CARRIED OUT A PRIME
BANK FRAUD THAT RAISED MORE THAN $31 MILLION FROM 2010 THROUGH 2012. THE SEC'S COMPLIANT ALLEGED THAT MARSHALL D. GUNN, AND THE
OTHER INDIVIDUAL AND ENTITY DEFENDANTS CLAIMED TO HAVE ACCESS TO SPECIAL PROGRAMS THAT WOULD PROVIDE ANNUAL RETURNS OF MORE
THAN 250 PERCENT BY OBTAINING LOANS AGAINST A FINANCIAL INSTRUMENT KNOWN AS A COLLATERALIZED MORTGAGE OBLIGATION, OR CMO, AND
THEN INVESTING THE LOAN PROCEEDS IN A PURPORTED CMO TRADING PROGRAM. THE COMPLAINT ALLEGED THAT THE INDIVIDUALS AND ENTITIES
NEVER OBTAINED THE LOANS AGAINST CMOS OR PLACED INVESTOR FUNDS IN A CMO TRADING PROGRAM, BUT INSTEAD MISAPPROPRIATED INVESTOR
FUNDS FOR THEIR OWN USE. THE COMPLAINT ALSO ALLEGED THAT SEVERAL OF THE DEFENDANTS AIDED AND ABETTED THE FRAUD BY SELLING CMOS
HELD FOR THE BENEFIT OF INVESTORS AND FUNNELING THOSE PROCEEDS BACK TO THE COLORADO RESIDENT. THE SEC'S COMPLAINT ALLEGED THAT
GUNN, AND OTHER DEFENDANTS VIOLATED THE ANTI-FRAUD PROVISIONS OF THE SECURITIES LAWS IN SECTION 17(A) OF THE SECURITIES ACT OF
1933, SECTION 10(B) OF THE EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER; AND THAT OTHER DEFENDANTS ALSO AIDED AND ABETTED
THESE VIOLATIONS. THE COMPLAINT ALSO ALLEGED THAT GUNN, AND OTHER DEFENDANTS VIOLATED THE SECURITY REGISTRATION PROVISIONS OF
THE SECURITIES LAWS IN SECTION 5(A) AND (C) OF THE SECURITIES ACT. ALSO, THE COMPLAINT ALLEGES THAT GUNN, AND OTHER DEFENDANTS
VIOLATED SECTION 15(A) OF THE EXCHANGE ACT BY ACTING AS UNREGISTERED BROKER-DEALERS.
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):
06/29/2020
 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: $ 50,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution

 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.
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: 
GUNN CONSENTED TO ENTRY OF A FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, AND AGREED TO
BE PERMANENTLY ENJOINED FROM FUTURE VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933,
AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER AND THE SECURITIES REGISTRATION
PROVISIONS OF SECTIONS 5(A) AND (C) OF THE SECURITIES ACT AND THE BROKER-DEALER REGISTRATION PROVISION OF SECTION 15(A) OF
THE EXCHANGE ACT.
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).
GUNN CONSENTED TO ENTRY OF A FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, AND AGREED TO BE
PERMANENTLY ENJOINED FROM FUTURE VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933, AND
SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER AND THE SECURITIES REGISTRATION PROVISIONS OF
SECTIONS 5(A) AND (C) OF THE SECURITIES ACT AND THE BROKER-DEALER REGISTRATION PROVISION OF SECTION 15(A) OF THE EXCHANGE ACT.
GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.

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:
1210021
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GUNN, MARSHALL, DEAN
(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) 
CERTIFIED FINANCIAL PLANNER BOARD OF STANDARDS, INC.
2.
Principal Sanction:
Bar
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/01/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020-58231
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
GUNN & COMPANY INVESTMENT MANAGEMENT, INC,
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CERTIFIED FINANCIAL PLANNER BOARD OF STANDARDS, INC. (THE "CFP BOARD") ISSED AN ADMINISTRATIVE ORDER OF PERMANENT BAR TO
MARSHALL D. GUNN, JR. ON OCTOBER 1, 2021. ON AUGUST 19, 2021 THE CFP BOARD MAILED A COMPLIANT TO MR. GUNN FOR VIOLATIONS OF ITS
RULES OF CONDUCT. MR. GUNN FAILED TO FILE A RESPONSE TO THE COMPLAINT AND WAS THEREFORE DEEMED TO BE IN DEFAULT BY THE CFP BOARD.
THE CFP BOARD ULTIMATELY ISSUED A PERMANENT BAR IN RESPONSE TO THE FOLLOWING DISCIPLINARY ACTION, AND MR. GUNN'S SUBSEQUENT
FAILURE TO COOPERATE WITH THE CFP BOARD'S INVESTIGATION: DECEMBER 13, 2013: THE SECURITIES AND EXCHANGE COMMISSION FILED A CIVIL
LAWSUIT INJUNCTION ON DECEMBER 12, 2013, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO AGAINST A COLORADO
RESIDENT, HIS COMPANY, AND OTHERS WHO CARRIED OUT A PRIME BANK FRAUD THAT RAISED MORE THAN $31 MILLION FROM 2010 THROUGH 2012.
THE SEC'S COMPLIANT ALLEGED THAT MARSHALL D. GUNN, AND THE OTHER INDIVIDUAL AND ENTITY DEFENDANTS CLAIMED TO HAVE ACCESS TO
SPECIAL PROGRAMS THAT WOULD PROVIDE ANNUAL RETURNS OF MORE THAN 250 PERCENT BY OBTAINING LOANS AGAINST A FINANCIAL INSTRUMENT
KNOWN AS A COLLATERALIZED MORTGAGE OBLIGATION, OR CMO, AND THEN INVESTING THE LOAN PROCEEDS IN A PURPORTED CMO TRADING
PROGRAM. THE COMPLAINT ALLEGED THAT THE INDIVIDUALS AND ENTITIES NEVER OBTAINED THE LOANS AGAINST CMOS OR PLACED INVESTOR FUNDS
IN A CMO TRADING PROGRAM, BUT INSTEAD MISAPPROPRIATED INVESTOR FUNDS FOR THEIR OWN USE. THE COMPLAINT ALSO ALLEGED THAT SEVERAL
OF THE DEFENDANTS AIDED AND ABETTED THE FRAUD BY SELLING CMOS HELD FOR THE BENEFIT OF INVESTORS AND FUNNELING THOSE PROCEEDS
BACK TO THE COLORADO RESIDENT. THE SEC'S COMPLAINT ALLEGED THAT GUNN, AND OTHER DEFENDANTS VIOLATED THE ANTI-FRAUD PROVISIONS
OF THE SECURITIES LAWS IN SECTION 17(A) OF THE SECURITIES ACT OF 1933, SECTION 10(B) OF THE EXCHANGE ACT OF 1934 AND RULE 10B-5
THEREUNDER; AND THAT OTHER DEFENDANTS ALSO AIDED AND ABETTED THESE VIOLATIONS. THE COMPLAINT ALSO ALLEGED THAT GUNN, AND OTHER
DEFENDANTS VIOLATED THE SECURITY REGISTRATION PROVISIONS OF THE SECURITIES LAWS IN SECTION 5(A) AND (C) OF THE SECURITIES ACT.
ALSO, THE COMPLAINT ALLEGES THAT GUNN, AND OTHER DEFENDANTS VIOLATED SECTION 15(A) OF THE EXCHANGE ACT BY ACTING AS UNREGISTERED
BROKER-DEALERS.
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):
11/01/2021
 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: 
MARSHALL D. GUNN, JR. WAS ISSED AN ADMINISTRATIVE ORDER OF PERMANENT BAR ON OCTOBER 1, 2021. MR. GUNN IS PERMANENTLY BARRED
FROM HOLDING OR OBTAINING THE CFP BOARD CERTIFICATION OR USING THE CFP OR CERTIFIED FINANCIAL PLANNER MARKS.
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).
MARSHALL D. GUNN, JR. WAS ISSED AN ADMINISTRATIVE ORDER OF PERMANENT BAR ON OCTOBER 1, 2021. MR. GUNN IS PERMANENTLY BARRED FROM
HOLDING OR OBTAINING THE CFP BOARD CERTIFICATION OR USING THE CFP OR CERTIFIED FINANCIAL PLANNER MARKS.

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:
1210021
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GUNN, MARSHALL, DEAN
(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) 
ASSOCIATION OF INTERNATIONAL CERTIFIED PROFESSIONAL ACCOUNTANTS ("AICPA")
2.
Principal Sanction:
Expulsion
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/16/2023
 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):
GUNN & COMPANY INVESTMENT MANAGEMENT, INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
AT A MEETING OF THE HEARING PANEL OF THE JOINT TRIAL BOARD OF THE AICPA THE PANEL FOUND MR. GUNN GUILTY OF VIOLATING THE GENERAL
STANDARDS OF RULE .01A. PROFESSIONAL COMPETENCE (2.300.001); GENERAL STANDARDS FULE .01B. DUE PROFESSIONAL CARE (2.300.001); AND
ACT DISCREDIBLE RULE (2.400.001) OF THE AICPA CODE OF PROFESSIONAL CONDUCT. THIS WAS IN CONNECTION WITH THE FOLLOWING
DISCIPLINARY EVENT: DECEMBER 13, 2013: THE SECURITIES AND EXCHANGE COMMISSION FILED A CIVIL LAWSUIT INJUNCTION ON DECEMBER 12,
2013, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO AGAINST A COLORADO RESIDENT, HIS COMPANY, AND OTHERS WHO
CARRIED OUT A PRIME BANK FRAUD THAT RAISED MORE THAN $31 MILLION FROM 2010 THROUGH 2012. THE SEC'S COMPLIANT ALLEGED THAT
MARSHALL D. GUNN, AND THE OTHER INDIVIDUAL AND ENTITY DEFENDANTS CLAIMED TO HAVE ACCESS TO SPECIAL PROGRAMS THAT WOULD PROVIDE
ANNUAL RETURNS OF MORE THAN 250 PERCENT BY OBTAINING LOANS AGAINST A FINANCIAL INSTRUMENT KNOWN AS A COLLATERALIZED MORTGAGE
OBLIGATION, OR CMO, AND THEN INVESTING THE LOAN PROCEEDS IN A PURPORTED CMO TRADING PROGRAM. THE COMPLAINT ALLEGED THAT THE
INDIVIDUALS AND ENTITIES NEVER OBTAINED THE LOANS AGAINST CMOS OR PLACED INVESTOR FUNDS IN A CMO TRADING PROGRAM, BUT INSTEAD
MISAPPROPRIATED INVESTOR FUNDS FOR THEIR OWN USE. THE COMPLAINT ALSO ALLEGED THAT SEVERAL OF THE DEFENDANTS AIDED AND ABETTED
THE FRAUD BY SELLING CMOS HELD FOR THE BENEFIT OF INVESTORS AND FUNNELING THOSE PROCEEDS BACK TO THE COLORADO RESIDENT. THE
SEC'S COMPLAINT ALLEGED THAT GUNN, AND OTHER DEFENDANTS VIOLATED THE ANTI-FRAUD PROVISIONS OF THE SECURITIES LAWS IN SECTION
17(A) OF THE SECURITIES ACT OF 1933, SECTION 10(B) OF THE EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER; AND THAT OTHER
DEFENDANTS ALSO AIDED AND ABETTED THESE VIOLATIONS. THE COMPLAINT ALSO ALLEGED THAT GUNN, AND OTHER DEFENDANTS VIOLATED THE
SECURITY REGISTRATION PROVISIONS OF THE SECURITIES LAWS IN SECTION 5(A) AND (C) OF THE SECURITIES ACT. ALSO, THE COMPLAINT ALLEGES
THAT GUNN, AND OTHER DEFENDANTS VIOLATED SECTION 15(A) OF THE EXCHANGE ACT BY ACTING AS UNREGISTERED BROKER-DEALERS.
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:
Other

11. Resolution Date (MM/DD/YYYY):
12/16/2023
 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: $
 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 HEARING PANEL VOTED TO TO EXPEL MR. GUNN FROM MEMBERSHIP IN THE AICPA. MR. GUNN WAS GIVEN THE OPTION TO REQUEST A
REVIEW OF THE HEARING PANEL'S DECISION BY DECEMBER 16, 2023. SINCE MR. GUNN DID NOT REQUEST SUCH A REVIEW, THE IS NO OTHER
PROVISION IN THE RULES FOR REQUESTING A REVIEW AND THE FINDING IS FINAL AS OF THAT DATE.
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).
THE HEARING PANEL VOTED TO TO EXPEL MR. GUNN FROM MEMBERSHIP IN THE AICPA. MR. GUNN WAS GIVEN THE OPTION TO REQUEST A REVIEW OF
THE HEARING PANEL'S DECISION BY DECEMBER 16, 2023. SINCE MR. GUNN DID NOT REQUEST SUCH A REVIEW, THE IS NO OTHER PROVISION IN THE
RULES FOR REQUESTING A REVIEW AND THE FINDING IS FINAL AS OF THAT DATE.

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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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:
1210021
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GUNN, MARSHALL, DEAN

(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.H.
(1)(a), 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.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Disgorgement
Other Relief Sought: 
GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.
3.
Filing Date of Court Action (MM/DD/YYYY):
06/29/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
COLLATERALIZED MORTGAGE OBLIGATIONS
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
DECEMBER 13, 2013: THE SECURITIES AND EXCHANGE COMMISSION FILED A CIVIL LAWSUIT INJUNCTION ON DECEMBER 12, 2013, IN THE UNITED
STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO AGAINST A COLORADO RESIDENT, HIS COMPANY, AND OTHERS WHO CARRIED OUT A PRIME
BANK FRAUD THAT RAISED MORE THAN $31 MILLION FROM 2010 THROUGH 2012. THE SEC'S COMPLIANT ALLEGED THAT MARSHALL D. GUNN, AND THE
OTHER INDIVIDUAL AND ENTITY DEFENDANTS CLAIMED TO HAVE ACCESS TO SPECIAL PROGRAMS THAT WOULD PROVIDE ANNUAL RETURNS OF MORE
THAN 250 PERCENT BY OBTAINING LOANS AGAINST A FINANCIAL INSTRUMENT KNOWN AS A COLLATERALIZED MORTGAGE OBLIGATION, OR CMO, AND
THEN INVESTING THE LOAN PROCEEDS IN A PURPORTED CMO TRADING PROGRAM. THE COMPLAINT ALLEGED THAT THE INDIVIDUALS AND ENTITIES
NEVER OBTAINED THE LOANS AGAINST CMOS OR PLACED INVESTOR FUNDS IN A CMO TRADING PROGRAM, BUT INSTEAD MISAPPROPRIATED INVESTOR
FUNDS FOR THEIR OWN USE. THE COMPLAINT ALSO ALLEGES THAT SEVERAL OF THE DEFENDANTS AIDED AND ABETTED THE FRAUD BY SELLING CMOS
HELD FOR THE BENEFIT OF INVESTORS AND FUNNELING THOSE PROCEEDS BACK TO THE COLORADO RESIDENT. THE SEC'S COMPLAINT ALLEGES THAT
GUNN, AND OTHER DEFENDANTS VIOLATED THE ANTI-FRAUD PROVISIONS OF THE SECURITIES LAWS IN SECTION 17(A) OF THE SECURITIES ACT OF
1933, SECTION 10(B) OF THE EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER; AND THAT OTHER DEFENDANTS ALSO AIDED AND ABETTED
THESE VIOLATIONS. THE COMPLAINT ALSO ALLEGED THAT GUNN, AND OTHER DEFENDANTS VIOLATED THE SECURITY REGISTRATION PROVISIONS OF
THE SECURITIES LAWS IN SECTION 5(A) AND (C) OF THE SECURITIES ACT. ALSO, THE COMPLAINT ALLEGES THAT GUNN, AND OTHER DEFENDANTS
VIOLATED SECTION 15(A) OF THE EXCHANGE ACT BY ACTING AS UNREGISTERED BROKER-DEALERS.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation

If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
06/29/2020
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.
C.
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:
GUNN CONSENTED TO ENTRY OF A FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT, AND AGREED TO
BE PERMANENTLY ENJOINED FROM FUTURE VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF SECTION 17(A) OF THE SECURITIES ACT OF 1933,
AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER AND THE SECURITIES REGISTRATION
PROVISIONS OF SECTIONS 5(A) AND (C) OF THE SECURITIES ACT AND THE BROKER-DEALER REGISTRATION PROVISION OF SECTION 15(A) OF
THE EXCHANGE ACT.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
IN DECEMBER 2013, ONE OF GCIM'S SHAREHOLDERS, MARSHALL D. GUNN, JR., WAS PERSONALLY NAMED IN A COMPLAINT BY THE U.S. SECURITIES AND
EXCHANGE COMMISSION. IN JUNE 2020, THE U.S. DISTRICT COURT FOR THE DISTRICT OF COLORADO ENTERED A FINAL CONSENT JUDGMENT AGAINST
MARSHALL D. GUNN, JR., IN CONNECTION WITH HIS ROLE IN A PRIME BANK SCHEME ORCHESTRATED BY DANIEL DIRK CODDINGTON. THE SEC'S
COMPLAINT ALLEGES THAT CODDINGTON DEFRAUDED INVESTORS BY SOLICITING INVESTMENTS IN COLLATERALIZED MORTGAGE OBLIGATIONS
(CMOS). ACCORDING TO THE SEC'S COMPLAINT, GUNN ALLEGEDLY MADE FALSE AND MISLEADING STATEMENTS ABOUT THE TRADING PROGRAM TO
SOLICIT INVESTORS. GUNN CONSENTED TO ENTRY OF A FINAL JUDGMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OF THE COMPLAINT,
AND AGREED TO BE PERMANENTLY ENJOINED FROM FUTURE VIOLATIONS OF THE ANTIFRAUD PROVISIONS OF SECTION 17(A) OF THE SECURITIES ACT
OF 1933, AND SECTION 10(B) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 10B-5 THEREUNDER AND THE SECURITIES REGISTRATION
PROVISIONS OF SECTIONS 5(A) AND (C) OF THE SECURITIES ACT AND THE BROKER-DEALER REGISTRATION PROVISION OF SECTION 15(A) OF THE
EXCHANGE ACT. GUNN AGREED TO PAY DISGORGEMENT OF $197,500, PREJUDGMENT INTEREST OF $33,754 AND A CIVIL PENALTY OF $50,000.