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 William Blair & Company L.L.C.
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 William Blair & Company L.L.C..
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 | WBC HOLDINGS, L.P.HOLDING COMPANYDomestic entity | WILLIAM BLAIR & COMPANY L.L.C. | 75% or moreCode E | Yes | HOLDING COMPANY11/2008 | Schedule APDF page 118 |
| 2 | BRENT WALKER GLEDHILLPRESIDENT, CEOIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | PRESIDENT, CEO03/2009 | Schedule APDF page 118 |
| 3 | RYAN JACOB DEVOREEXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE11/2017 | Schedule APDF page 118 |
| 4 | WILLSON B RASAVONGXAYCHIEF COMPLIANCE OFFICERIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER12/2019 | Schedule APDF page 118 |
| 5 | CISSIE CITARDIEXECUTIVE COMMITTEE, GENERAL COUNSELIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE, GENERAL COUNSEL01/2021 | Schedule APDF page 118 |
| 6 | MATTHEW MONTGOMERY ZIMMEREXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE01/2022 | Schedule APDF page 118 |
| 7 | BETH A SATTERFIELDEXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE01/2023 | Schedule APDF page 118 |
| 8 | MICHAEL WILLIAM TRIMBERGEREXECUTIVE COMMITTEE, CFOIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE, CFO07/2023 | Schedule APDF page 118 |
| 9 | SCOTT THOMAS MCLAUGHLINEXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE01/2024 | Schedule APDF page 118 |
| 10 | STEVEN ROBERT TOLEEXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE01/2025 | Schedule APDF page 118 |
| 11 | ROBERT DANIEL KENDALLEXECUTIVE COMMITTEEIndividual | WILLIAM BLAIR & COMPANY L.L.C. | Less than 5%Code NA | Yes | EXECUTIVE COMMITTEE01/2026 | Schedule APDF page 118 |
| 12 | WBC GP L.L.C.GENERAL PARTNERDomestic entity | WBC HOLDINGS, L.P. | Percentage not specifiedCode F | Yes | GENERAL PARTNER11/2008 | Schedule BPDF page 118 |
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 4:29:00 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions1 Yes4 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?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 18 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 119–121
- Regulator name — filed text
- NASD
- Monetary/Fine Amount — filed text
- $ 15,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FINE OF $15,000.00 WAS PAID ON JUNE 3, 2005.
Other filed details
Description of allegations — filed text
DURING THE PERIOD JANUARY 1, 2002 THROUGH MARCH 31, 2002, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4 BY FAILING TO IMMEDIATELY DISPLAY THIRTY SEVEN CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION. DURING THE SAME TIME PERIOD, THE FIRM ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) AND NASD CONDUCT RULE 2110 BY TRANSMITTING TO OATS FIFTY EIGHT REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. DURING THE TIME PERIOD JUNE 30, 2003 THROUGH JULY 3, 2003, THE FIRM ALLEGEDLY VIOLATED NASD MEMBERSHIP AND REGISTRATION RULE 1032(F) BY FAILING TO REGISTER ONE PERSON WITH THE NASD AS A LIMITED REPRESENTATIVE - EQUITY TRADER.
Sanction detail — filed text
THE FIRM WAS NOTIFIED ON MAY 2, 2005 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ABJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $15,000 TO SETTLE THE MATTER.
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)
NASD
2.
Principal Sanction:
Censure
Other Sanctions:
FINE OF $15,000
3.
Date Initiated (MM/DD/YYYY):
12/29/2002
Exact
Explanation
If not exact, provide explanation:
EXAM NO. MRD200235951 WAS INITIATED ON DECEMBER 29,2002 AND EXAM NO. MRD200340757 WAS INITIATED ON JUNE 29,2003. THE FINDINGS OF
THE TWO EXAMS WERE COMBINED BY THE NASD INTO ONE COMPLAINT.
4.
Docket/Case Number:
CLG050050AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE PERIOD JANUARY 1, 2002 THROUGH MARCH 31, 2002, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4
BY FAILING TO IMMEDIATELY DISPLAY THIRTY SEVEN CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION. DURING THE SAME
TIME PERIOD, THE FIRM ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) AND NASD CONDUCT RULE 2110 BY TRANSMITTING TO OATS FIFTY
EIGHT REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. DURING THE TIME PERIOD JUNE 30, 2003 THROUGH
JULY 3, 2003, THE FIRM ALLEGEDLY VIOLATED NASD MEMBERSHIP AND REGISTRATION RULE 1032(F) BY FAILING TO REGISTER ONE PERSON WITH THE
NASD AS A LIMITED REPRESENTATIVE - EQUITY TRADER.
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):
05/02/2005
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: $ 15,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM WAS NOTIFIED ON MAY 2, 2005 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ABJUDICATORY COUNCIL HAD
ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS
CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $15,000 TO SETTLE THE MATTER.
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 FINE OF $15,000.00 WAS PAID ON JUNE 3, 2005.regulatory · block 2PDF pages 121–122
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 38,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS.
Other filed details
Description of allegations — filed text
THE FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS.
Sanction detail — filed text
THE FIRM PAID THE FINE OF $38,000 ON 2/26/2010.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Censure Other Sanctions: A FINE OF $38,000 (IN 20060063857: $5,000 FOR SEC RULE 604 AND $5,000 FOR NASD RULE 6955; IN 2070089900: $5,000 FOR NASD RULE 6130, $3,000 FOR SEC RULE 10B-10, AND $5,000 FOR NASD RULES 2110 AND 3010; IN 20080133281: $10,000 FOR SEC RULE 605 AND $5,000 FOR SEC RULE 10B-10). 3. Date Initiated (MM/DD/YYYY): 02/12/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20060063857-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS. 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): 02/12/2010 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: $ 38,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM PAID THE FINE OF $38,000 ON 2/26/2010. 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 FINDINGS OF THREE EXAMINATIONS FROM 2006 (2006006387), 2007 (20070089900), AND 2008 (20080133281) WERE COMBINED AND THE ALLEGATIONS WERE THAT THE FIRM FAILED TO: DISPLAY IMMEDIATELY 27 CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES AND TRANSMITTED TO OATS 60 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA; SUBMIT THE CORRECT BUY, SELL, SELL SHORT OR CROSS SYMBOL FOR 56 TRANSACTIONS; ON 69 OCCASIONS DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE; PROVIDE FOR ONE OR MORE MINIMUM REQUIREMENTS FOR ADEQUATE SUPERVISORY PROCEDURES; ON FOUR OCCASIONS DISCLOSE ITS CORRECT CAPACITY, ON SIX OCCASIONS DISCLOSE THE CORRECT COMPENSATION TYPE, AND ON ONE OCCASION DISCLOSE THAT THE TRANSACTION WAS EXECUTED AT AN AVERAGE PRICE AND DATA USED FOR RULE 605 REPORTING INCLUDED INCORRECT INFORMATION. THE TRANSACTIONS INVOLVED REPRESENTED LESS THAN .01% OF TRANSACTIONS CONDUCTED DURING THE TIME PERIODS.
regulatory · block 3PDF pages 123–124
- Regulator name — filed text
- FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA")
- Monetary/Fine Amount — filed text
- $ 9,315.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
A PENAL DECREE DATED MAY 14, 2013 ("DECREE") BY THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS SECURITIES REGULATIONS DUE TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES. SWISS REGULATIONS REQUIRE THAT A PERSON WHO ACQUIRES OR SELLS SHARES OF A COMPANY INCORPORATED IN SWITZERLAND WHOSE EQUITY SECURITIES ARE LISTED IN WHOLE OR IN PART IN SWITZERLAND AND THEREBY ATTAINS, FALLS BELOW OR EXCEEDS THE THRESHOLD PERCENTAGES OF VOTING RIGHTS SEND NOTIFICATIONS TO FINMA AND THE COMPANY. SUCH NOTIFICATIONS MUST BE RECEIVED BY FINMA AND THE COMPANY WITHIN FOUR TRADING DAYS. IN THIS CASE, WILLIAM BLAIR EXCEEDED THE 3% THRESHOLD (THE LOWEST THRESHOLD FOR REPORTING PURPOSES) IN TWO SEPARATE INSTANCES AND REPORTED SUCH TRANSACTIONS THREE CALENDAR DAYS AFTER THE DEADLINE. FINMA DEEMED THESE MATTERS TO BE SIMPLE NEGLIGENCE. HOWEVER, WILLIAM BLAIR WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM BLAIR WAS ALSO ASSESSED PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE COSTS WERE ASSESSED.
Other filed details
Description of allegations — filed text
THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS SECURITIES REGULATIONS DUE TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES.
Sanction detail — filed text
WILLIAM BLAIR WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM BLAIR WAS ALSO ASSESSED PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE COSTS WERE ASSESSED.
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)
FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
FINMA ASSESSED A FINE IN THE AMOUNT OF CHF 9,000 AND PROCEDURAL COSTS OF CHF 1,570.
3.
Date Initiated (MM/DD/YYYY):
05/07/2012
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE FILE FDF 442.2-052
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS
SECURITIES REGULATIONS DUE TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES.
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
11. Resolution Date (MM/DD/YYYY):
05/14/2013
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: $ 9,315.00
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:
WILLIAM BLAIR WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES
CURRENT AT THE TIME THE FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM
BLAIR WAS ALSO ASSESSED PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT
THE TIME THE COSTS WERE ASSESSED.
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).
A PENAL DECREE DATED MAY 14, 2013 ("DECREE") BY THE FEDERAL DEPARTMENT OF FINANCE ("FDF") OF THE SWISS FINANCIAL MARKET
SUPERVISORY AUTHORITY ("FINMA") FOUND WILLIAM BLAIR TO HAVE NEGLIGENTLY FAILED TO COMPLY WITH SWISS SECURITIES REGULATIONS DUE
TO WILLIAM BLAIR'S LATE FILING OF SHAREHOLDING REPORTS IN TWO INSTANCES. SWISS REGULATIONS REQUIRE THAT A PERSON WHO ACQUIRES
OR SELLS SHARES OF A COMPANY INCORPORATED IN SWITZERLAND WHOSE EQUITY SECURITIES ARE LISTED IN WHOLE OR IN PART IN SWITZERLAND
AND THEREBY ATTAINS, FALLS BELOW OR EXCEEDS THE THRESHOLD PERCENTAGES OF VOTING RIGHTS SEND NOTIFICATIONS TO FINMA AND THE
COMPANY. SUCH NOTIFICATIONS MUST BE RECEIVED BY FINMA AND THE COMPANY WITHIN FOUR TRADING DAYS. IN THIS CASE, WILLIAM BLAIR
EXCEEDED THE 3% THRESHOLD (THE LOWEST THRESHOLD FOR REPORTING PURPOSES) IN TWO SEPARATE INSTANCES AND REPORTED SUCH
TRANSACTIONS THREE CALENDAR DAYS AFTER THE DEADLINE. FINMA DEEMED THESE MATTERS TO BE SIMPLE NEGLIGENCE. HOWEVER, WILLIAM BLAIR
WAS ASSESSED A FINE IN THE AMOUNT OF CHF 9,000, WHICH WAS APPROXIMATELY $9,315 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE
FINE WAS ASSESSED. THIS AMOUNT CORRESPONDS TO 0.9% OF THE MAXIMUM FINE OF CHF 1,000,000. WILLIAM BLAIR WAS ALSO ASSESSED
PROCEDURAL COSTS OF CHF 1,570, WHICH WAS APPROXIMATELY $1,625 (USD) AT EXCHANGE RATES CURRENT AT THE TIME THE COSTS WERE
ASSESSED.regulatory · block 4PDF pages 124–126
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 4,500,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
AN ORDER BY THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DATED MAY 1, 2017 FOUND THAT FROM 2010 UNTIL 2014, AS A RESULT OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD- APPROVED LIMITS. THESE PAYMENTS TOTALED APPROXIMATELY $1.25 MILLION AND RENDERED CERTAIN OF WILLIAM BLAIR FUNDS' ("FUNDS") DISCLOSURES CONCERNING PAYMENTS FOR DISTRIBUTION AND SUB-TA SERVICES INACCURATE. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR VIOLATED SECTION 206(2) OF THE ADVISERS ACT AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT, AND CAUSED THE FUNDS TO VIOLATE SECTION 12(B) OF THE INVESTMENT COMPANY ACT AND RULE 12B-1 THEREUNDER. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY DISCLOSE TO THE FUNDS' BOARD OF TRUSTEES ("BOARD") THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE FOR PROVIDING SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN CERTAIN OF THE FUNDS AND WILLIAM BLAIR. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR VIOLATED SECTION 206(2) OF THE ADVISERS ACT. WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, WILLIAM BLAIR CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940, MAKING FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. WILLIAM BLAIR ALSO WAS ASSESSED BY THE COMMISSION A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000.
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT FROM 2010 UNTIL 2014, AS A RESULT OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD-APPROVED LIMITS. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY DISCLOSE TO THE FUNDS' BOARD OF TRUSTEES THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE FOR PROVIDING SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN CERTAIN OF THE FUNDS AND WILLIAM BLAIR.
Sanction detail — filed text
WILLIAM BLAIR WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000 THAT IT PAID ON MAY 8, 2017. CEASE AND DESIST PROCEEDINGS WERE INSTITUTED PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940.
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)
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
WILLIAM BLAIR WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000
3.
Date Initiated (MM/DD/YYYY):
05/01/2017
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-17960
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT FROM 2010 UNTIL 2014, AS A RESULT OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS
TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER
AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD-APPROVED LIMITS. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY DISCLOSE TO
THE FUNDS' BOARD OF TRUSTEES THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE FOR PROVIDING
SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN CERTAIN OF
THE FUNDS AND WILLIAM BLAIR.
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):
05/01/2017
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 4,500,000.00
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:
WILLIAM BLAIR WAS ASSESSED A CIVIL MONEY PENALTY IN THE AMOUNT OF $4,500,000 THAT IT PAID ON MAY 8, 2017. CEASE AND DESIST
PROCEEDINGS WERE INSTITUTED PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE
INVESTMENT COMPANY ACT OF 1940.
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).
AN ORDER BY THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DATED MAY 1, 2017 FOUND THAT FROM 2010 UNTIL 2014, AS A RESULT
OF ERRONEOUS PAYMENTS, WILLIAM BLAIR NEGLIGENTLY USED MUTUAL FUND ASSETS TO PAY FOR (I) DISTRIBUTION AND MARKETING OF FUND
SHARES OUTSIDE OF A WRITTEN, BOARD-APPROVED RULE 12B-1 PLAN AND (II) SUB-TRANSFER AGENT ("SUB-TA") SERVICES IN EXCESS OF BOARD-
APPROVED LIMITS. THESE PAYMENTS TOTALED APPROXIMATELY $1.25 MILLION AND RENDERED CERTAIN OF WILLIAM BLAIR FUNDS' ("FUNDS")
DISCLOSURES CONCERNING PAYMENTS FOR DISTRIBUTION AND SUB-TA SERVICES INACCURATE. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR
VIOLATED SECTION 206(2) OF THE ADVISERS ACT AND SECTION 34(B) OF THE INVESTMENT COMPANY ACT, AND CAUSED THE FUNDS TO VIOLATE
SECTION 12(B) OF THE INVESTMENT COMPANY ACT AND RULE 12B-1 THEREUNDER. THE SEC ALLEGED THAT WILLIAM BLAIR ALSO FAILED TO FULLY
DISCLOSE TO THE FUNDS' BOARD OF TRUSTEES ("BOARD") THAT WILLIAM BLAIR (AND NOT A THIRD-PARTY SERVICE PROVIDER) WOULD RETAIN A FEE
FOR PROVIDING SHAREHOLDER ADMINISTRATION SERVICES TO THE FUNDS UNDER A SHAREHOLDER ADMINISTRATION SERVICES AGREEMENT BETWEEN
CERTAIN OF THE FUNDS AND WILLIAM BLAIR. AS A RESULT OF THIS CONDUCT, WILLIAM BLAIR VIOLATED SECTION 206(2) OF THE ADVISERS ACT.
WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE
PROCEEDINGS, WHICH ARE ADMITTED, WILLIAM BLAIR CONSENTED TO THE ENTRY OF AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS,
PURSUANT TO SECTION 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTION 9(F) OF THE INVESTMENT COMPANY ACT OF 1940, MAKING
FINDINGS, AND IMPOSING A CEASE-AND-DESIST ORDER. WILLIAM BLAIR ALSO WAS ASSESSED BY THE COMMISSION A CIVIL MONEY PENALTY IN THE
AMOUNT OF $4,500,000.regulatory · block 5PDF pages 126–128
- Regulator name — filed text
- NASD REGULATION, INC.
- Monetary/Fine Amount — filed text
- $ 3,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
NASDR ALLEDGED THAT WILLIAM BLAIR & COMPANY FAILED TO FILE COPIES OF FINAL OFFICIAL STATEMENTS AND COMPLETED FORMS G-36(OS) WITH THE MSRB ON A TIMELY BASIS; FAILED TO ACCURATELY RECORD CERTAIN DATES OF FINAL AGREEMENTS TO PURCHASE, OFFER OR SELL SECURITIES AS AN UNDERWRITER; FAILED TO MAINTAIN RECORDS OF THE DATES FORMS WERE MAILED.
Sanction detail — filed text
THE FIRM WAS NOTIFIED ON MAY 29, 1998 THAT THE NASDR HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $3000 TO SETTLE THE MATTER.
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) NASD REGULATION, INC. 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 03/26/1998 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: C8A980036 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if 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): NASDR ALLEDGED THAT WILLIAM BLAIR & COMPANY FAILED TO FILE COPIES OF FINAL OFFICIAL STATEMENTS AND COMPLETED FORMS G-36(OS) WITH THE MSRB ON A TIMELY BASIS; FAILED TO ACCURATELY RECORD CERTAIN DATES OF FINAL AGREEMENTS TO PURCHASE, OFFER OR SELL SECURITIES AS AN UNDERWRITER; FAILED TO MAINTAIN RECORDS OF THE DATES FORMS WERE MAILED. 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): 05/29/1998 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: $ 3,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS NOTIFIED ON MAY 29, 1998 THAT THE NASDR HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $3000 TO SETTLE THE MATTER. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 6PDF pages 128–130
- Regulator name — filed text
- NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
DURING A ROUTINE EXAMINATION CONDUCTED IN SEPTEMBER 1994, DISTRICT STAFF REVIEWED THE SOES TRADING. THE NASD ALLEGED THAT FOUR SERIES OF TRANSACTIONS EXECUTED DURING THAT PERIOD WERE BASED ON A SINGLE INVESTMENT DECISION. THE FIRM EXECUTED APPROXIMATELY 2000 SOES TRANSACTIONS DURING THE PERIOD IN QUESTION.
Other filed details
Description of allegations — filed text
THE COMPLAINT ALLEGED THAT WILLIAM BLAIR & COMPANY VIOLATED SECTION C3C OF THE RULES OF FAIR PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE BY EFFECTING 11 TRANSACTIONS VIA SOES BETWEEN FEBRUARY AND JUNE 1994, WHEN TRADES WERE NOT ELIGIBLE FOR SUCH EXECUTION.
Sanction detail — filed text
THE FIRM WAS NOTIFIED ON MARCH 15, 1996 THAT THE NASD HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER. THE FINE WAS PAID APRIL 25, 1996
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) NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 10/25/1995 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CMS950174AWC 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE COMPLAINT ALLEGED THAT WILLIAM BLAIR & COMPANY VIOLATED SECTION C3C OF THE RULES OF FAIR PRACTICE AND PROCEDURE FOR SOES AND ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE BY EFFECTING 11 TRANSACTIONS VIA SOES BETWEEN FEBRUARY AND JUNE 1994, WHEN TRADES WERE NOT ELIGIBLE FOR SUCH EXECUTION. 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): 04/25/1996 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: $ 1,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS NOTIFIED ON MARCH 15, 1996 THAT THE NASD HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER. THE FINE WAS PAID APRIL 25, 1996 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 A ROUTINE EXAMINATION CONDUCTED IN SEPTEMBER 1994, DISTRICT STAFF REVIEWED THE SOES TRADING. THE NASD ALLEGED THAT FOUR SERIES OF TRANSACTIONS EXECUTED DURING THAT PERIOD WERE BASED ON A SINGLE INVESTMENT DECISION. THE FIRM EXECUTED APPROXIMATELY 2000 SOES TRANSACTIONS DURING THE PERIOD IN QUESTION.
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regulatory · block 7PDF pages 130–132
- Regulator name — filed text
- NASD REGULATION, INC.
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Decision
Other filed details
Description of allegations — filed text
IN THREE INSTANCES WILLIAM BLAIR & COMPANY FAILED TO CONTEMPORANEOUSLY EXECUTE OR PARTIALLY EXECUTE A CUSTOMER LIMIT ORDER AFTER TRADING IN THE SAME SECURITY FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED A CUSTOMER LIMIT ORDER. OVER 150 TRANSACTIONS WERE INCLUDED IN THE REVIEW.
Sanction detail — filed text
THE FINE OF $1000.00 WAS PAID ON MAY 6, 1999.
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) NASD REGULATION, INC. 2. Principal Sanction: Other Other Sanctions: FINE 3. Date Initiated (MM/DD/YYYY): 03/03/1999 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CMS990032AWC 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): IN THREE INSTANCES WILLIAM BLAIR & COMPANY FAILED TO CONTEMPORANEOUSLY EXECUTE OR PARTIALLY EXECUTE A CUSTOMER LIMIT ORDER AFTER TRADING IN THE SAME SECURITY FOR ITS OWN ACCOUNT AT PRICES THAT WOULD HAVE SATISFIED A CUSTOMER LIMIT ORDER. OVER 150 TRANSACTIONS WERE INCLUDED IN THE REVIEW. 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 11. Resolution Date (MM/DD/YYYY): 03/30/1999 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: $ 1,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FINE OF $1000.00 WAS PAID ON MAY 6, 1999. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 8PDF pages 132–133
- Regulator name — filed text
- NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 15,000.00
- How was matter resolved — filed text
- Decision
Other filed details
Description of allegations — filed text
FROM OCTOBER 2, 2001 TO DECEMBER 31, 2001, WILLIAM BLAIR & COMPANY, L.L.C., A MARKET MAKER, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING DURING THE PERIOD BETWEEN 9:20 AND 9:29:59 A.M. EASTERN TIME AND RECEIVED, IN 105 INSTANCES, A TRADE-OR-MOVE MESSAGE THROUGH SELECTNET. WILLIAM BLAIR, WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OR OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET, IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C).
Sanction detail — filed text
THE FINE OF $15,000 WAS PAID ON MARCH 26, 2003.
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) NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Censure Other Sanctions: FINE 3. Date Initiated (MM/DD/YYYY): 02/24/2003 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CMS030032AWC 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM OCTOBER 2, 2001 TO DECEMBER 31, 2001, WILLIAM BLAIR & COMPANY, L.L.C., A MARKET MAKER, WAS A PARTY TO A LOCKED OR CROSSED MARKET CONDITION PRIOR TO THE MARKET OPENING DURING THE PERIOD BETWEEN 9:20 AND 9:29:59 A.M. EASTERN TIME AND RECEIVED, IN 105 INSTANCES, A TRADE-OR-MOVE MESSAGE THROUGH SELECTNET. WILLIAM BLAIR, WITHIN 30 SECONDS OF RECEIVING SUCH MESSAGES, FAILED TO FILL THE INCOMING TRADE-OR-MOVE MESSAGE FOR THE FULL SIZE OF THE MESSAGE OR MOVE ITS BID DOWN (OR OFFER UP) BY A QUOTATION INCREMENT THAT WOULD HAVE UNLOCKED/UNCROSSED THE MARKET, IN VIOLATION OF NASD MARKETPLACE RULE 4613(E)(1)(C). 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 11. Resolution Date (MM/DD/YYYY): 03/24/2003 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: $ 15,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FINE OF $15,000 WAS PAID ON MARCH 26, 2003. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 9ELKINS, STEPHEN EDWARDPDF pages 133–135
- Advisory affiliate name — filed text
- ELKINS, STEPHEN EDWARD
- Regulator name — filed text
- NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC.
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
BETWEEN APPROXIMATELY JULY 1999 AND SEPTEMBER 2000, WILLIAM BLAIR & COMPANY,L.L.C. FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE NASD'S FREE-RIDING AND WITHHOLDING INTERPRETATION IN THAT ITS EXISTING WRITTEN PROCEDURES FAILED TO REQUIRE A PERIODIC REVIEW OF ACCOUNTS THAT PURCHASED HOT ISSUES TO CONFIRM THAT REGISTERED REPRESENTATIVES HAD PERFORMED REASONABLE DUE DILIGENCE TO DETERMINE THAT THE ACCOUNT WAS NOT RESTRICTED. DURING THE SAME PERIOD, STEPHEN ELKINS, A PRINCIPAL OF WILLIAM BLAIR & COMPANY, L.L.C., SOLD HOT ISSUE SECURITIES TO AN INDIVIDUAL WHO WAS REGISTERED WITH ANOTHER MEMBER OF THE NASD, IN HIS PERSONAL ACCOUNT AND IN AN ACCOUNT IN WHICH THE INDIVIDUAL HAD A BENEFICIAL INTEREST.
Sanction detail — filed text
AS TO WILLIAM BLAIR & COMPANY, L.L.C. - A FINE OF $2,500; AS TO STEPHEN ELKINS - A FINE OF $4,233.46, WHICH INCLUDES DISGORGEMENT OF COMMISSIONS OF $1,733.46
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: 77040 This advisory affiliate is a Firm an Individual Registered: Yes No Name: ELKINS, STEPHEN EDWARD (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) NATIONAL ASSOCIATION OF SECURITIES DEALERS, INC. 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/29/2003 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: AWC C8A030063 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity - OTC Other Product Types: NONE 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): BETWEEN APPROXIMATELY JULY 1999 AND SEPTEMBER 2000, WILLIAM BLAIR & COMPANY,L.L.C. FAILED TO ESTABLISH WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE NASD'S FREE-RIDING AND WITHHOLDING INTERPRETATION IN THAT ITS EXISTING WRITTEN PROCEDURES FAILED TO REQUIRE A PERIODIC REVIEW OF ACCOUNTS THAT PURCHASED HOT ISSUES TO CONFIRM THAT REGISTERED REPRESENTATIVES HAD PERFORMED REASONABLE DUE DILIGENCE TO DETERMINE THAT THE ACCOUNT WAS NOT RESTRICTED. DURING THE SAME PERIOD, STEPHEN ELKINS, A PRINCIPAL OF WILLIAM BLAIR & COMPANY, L.L.C., SOLD HOT ISSUE SECURITIES TO AN INDIVIDUAL WHO WAS REGISTERED WITH ANOTHER MEMBER OF THE NASD, IN HIS PERSONAL ACCOUNT AND IN AN ACCOUNT IN WHICH THE INDIVIDUAL HAD A BENEFICIAL INTEREST. 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): 08/08/2003 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 2,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: NONE 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: AS TO WILLIAM BLAIR & COMPANY, L.L.C. - A FINE OF $2,500; AS TO STEPHEN ELKINS - A FINE OF $4,233.46, WHICH INCLUDES DISGORGEMENT OF COMMISSIONS OF $1,733.46 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 10PDF pages 135–137
- Regulator name — filed text
- COMMONWEALTH OF VIRGINIA, DIVISION OF SECURITIES
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
WILLIAM BLAIR SENT FINANCIALS TO THE DIVISION ON MARCH 14, 1990 AND AGAIN ON JULY 24, 1990. ON AUGUST 27, 1990 BLAIR SENT A THRID COPY TO THE DIVISION AT ITS REQUEST. ON SEPTEMBER 14, 1990, THE DIVISION NOTIFIED BLAIR OF THE RECEIPT AND ALLEGED THAT BLAIR HAD VIOLATED SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT. BLAIR CONSENTED AFTER THE ESTIMATED EXPENSE EXCEEDED THE AMOUNT OF THE PROPSED FINE. REGULATORY ACTION IS OVER 10 YEARS OLD.
Other filed details
Description of allegations — filed text
FIRM ALLEGEDLY FAILED TO SUBMIT AUDITED FINANCIAL STATEMENTS WITHIN TEN DAYS OF PUBLICATION AS REQUIRED BY SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT.
Sanction detail — filed text
FIRM CONSENTED TO A COMPROMISE AND SETTLEMENT ORDER PROPOSED BY THE DIVISION AND WAS FINED $1000.00.
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) COMMONWEALTH OF VIRGINIA, DIVISION OF SECURITIES 2. Principal Sanction: Other Other Sanctions: COMPROMISE AND SETTLEMENT ORDER 3. Date Initiated (MM/DD/YYYY): 09/26/1990 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: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FIRM ALLEGEDLY FAILED TO SUBMIT AUDITED FINANCIAL STATEMENTS WITHIN TEN DAYS OF PUBLICATION AS REQUIRED BY SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Other 11. Resolution Date (MM/DD/YYYY): 09/26/1990 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: $ 1,000.00 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: FIRM CONSENTED TO A COMPROMISE AND SETTLEMENT ORDER PROPOSED BY THE DIVISION AND WAS FINED $1000.00. 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). WILLIAM BLAIR SENT FINANCIALS TO THE DIVISION ON MARCH 14, 1990 AND AGAIN ON JULY 24, 1990. ON AUGUST 27, 1990 BLAIR SENT A THRID COPY TO THE DIVISION AT ITS REQUEST. ON SEPTEMBER 14, 1990, THE DIVISION NOTIFIED BLAIR OF THE RECEIPT AND ALLEGED THAT BLAIR HAD VIOLATED SECTION 13.1-518.1 OF THE VIRGINIA SECURITIES ACT. BLAIR CONSENTED AFTER THE ESTIMATED EXPENSE EXCEEDED THE AMOUNT OF THE PROPSED FINE. REGULATORY ACTION IS OVER 10 YEARS OLD.
regulatory · block 11PDF pages 137–139
- Regulator name — filed text
- CHICAGO BOARD OF OPTIONS EXCHANGE
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Other
Other filed details
Description of allegations — filed text
DURING THE PERIOD FROM SEPTEMBER 6, 1983 THROUGH JUNE 28, 1984, WILLIAM BLAIR & COMPANY ALLEGEDLY PERMITTED TEN PUBLIC CUSTOMERS TO ENGAGE IN LISTED OPTION TRANSACTIONS PRIOR TO THEIR ACCOUNTS BEING APPROVED BY A REGISTERED OPTIONS PRINCIPAL
Sanction detail — filed text
FINE WAS PAID ON MAY 29, 1985 IN THE AMOUNT OF $1000.00.
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) CHICAGO BOARD OF OPTIONS EXCHANGE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/22/1985 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CBOE FILE NUMBER 85-0011 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): DURING THE PERIOD FROM SEPTEMBER 6, 1983 THROUGH JUNE 28, 1984, WILLIAM BLAIR & COMPANY ALLEGEDLY PERMITTED TEN PUBLIC CUSTOMERS TO ENGAGE IN LISTED OPTION TRANSACTIONS PRIOR TO THEIR ACCOUNTS BEING APPROVED BY A REGISTERED OPTIONS PRINCIPAL 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): 05/29/1985 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: $ 1,000.00 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: FINE WAS PAID ON MAY 29, 1985 IN THE AMOUNT OF $1000.00. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 12PDF pages 139–140
- Regulator name — filed text
- NATIONAL ASSOCIATION OF SECURITIES DEALERS
- Monetary/Fine Amount — filed text
- $ 7,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE DBCC NOTED THAT THE VIOLATIONS WERE NOT INTENTIONAL AND THAT THE FIRM DID NOT REALIZE THAT THE CUSTOMERS INVOLVED WOULD BE CONSIDERED RESTRICTED UNDER THE INTERPRETATION.
Other filed details
Description of allegations — filed text
THE COMPLAINT ALLEGED THAT THE FIRM SOLD SHARES OF HOT ISSUE SECURITIES TO PERSONS ASSOCIATED WITH A BROKER DEALER IN CONTRAVENTION OF THE NASD INTERPRETATION ON FREE-RIDING AND WITHHOLDING. THE SALES ALLEGEDLY VIOLATED ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE. THE COMPLAINT DID NOT IDENTIFY ANY ACTUAL OR ALLEGED DAMAGES.
Sanction detail — filed text
AN OFFER OF SETTLEMENT WAS SUBMITTED TO THE DISTRICT BUSINESS CONDUCT COMMITTEE. THE OFFER WAS ACCEPTED AND THE FIRM WAS CENSURED AND FINED $7,000. THE FINE WAS PAID ON JUNE 8, 1993
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) NATIONAL ASSOCIATION OF SECURITIES DEALERS 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/04/1993 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: C8A930009 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): WILLIAM BLAIR & COMPANY 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE COMPLAINT ALLEGED THAT THE FIRM SOLD SHARES OF HOT ISSUE SECURITIES TO PERSONS ASSOCIATED WITH A BROKER DEALER IN CONTRAVENTION OF THE NASD INTERPRETATION ON FREE-RIDING AND WITHHOLDING. THE SALES ALLEGEDLY VIOLATED ARTICLE III, SECTION 1 OF THE NASD RULES OF FAIR PRACTICE. THE COMPLAINT DID NOT IDENTIFY ANY ACTUAL OR ALLEGED DAMAGES. 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): 06/08/1993 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: $ 7,000.00 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: AN OFFER OF SETTLEMENT WAS SUBMITTED TO THE DISTRICT BUSINESS CONDUCT COMMITTEE. THE OFFER WAS ACCEPTED AND THE FIRM WAS CENSURED AND FINED $7,000. THE FINE WAS PAID ON JUNE 8, 1993 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 DBCC NOTED THAT THE VIOLATIONS WERE NOT INTENTIONAL AND THAT THE FIRM DID NOT REALIZE THAT THE CUSTOMERS INVOLVED WOULD BE CONSIDERED RESTRICTED UNDER THE INTERPRETATION.
regulatory · block 13WILLIAM BLAIR MUTUAL FUNDS, INC.PDF pages 141–142
- Advisory affiliate name — filed text
- WILLIAM BLAIR MUTUAL FUNDS, INC.
- Regulator name — filed text
- TENNESSEE SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 20,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
WILLIAM BLAIR & COMPANY VIGOROUSLY OPPOSED THE DIVISIONS ALLEGATIONS THAT UNREGISTERED SHARES HAD BEEN SOLD IN TENNESSEE. AN APPLICATION WAS FILED DURING THE ROUTINE RENEWAL PROCESS IN ADVANCE OF THE FUNDS EXPIRATION. EIGHT MONTHS AFTER THE RENEWAL WAS SUBMITTED, THE DIVISION DEEMED IT INCOMPLETE FOR INSUFFICIENT FILING FEES.
Other filed details
Description of allegations — filed text
THE DIVISION ALLEGED THAT WILLIAM BLAIR & COMPANY'S AFFILIATE, WILLIAM BLAIR MUTUAL FUNDS, INC. SOLD UNREGISTERED MUTUAL FUND SHARES IN TENNESSEE BETWEEN JULY 1991 AND OCTOBER 1992. THE VALUE OF THE SECURITIES ALLEGEDLY TOTALLED $30,500 IN 20 TRANSACTIONS.
Sanction detail — filed text
AFTER DISPUTING THE DIVISION'S ALLEGATIONS FOR A PERIOD OF 18 MONTHS, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER AND PAID A FINE OF $20,000.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: This advisory affiliate is a Firm an Individual Registered: Yes No Name: WILLIAM BLAIR MUTUAL FUNDS, INC. (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) TENNESSEE SECURITIES DIVISION 2. Principal Sanction: Other Other Sanctions: ADMINISTRATIVE 3. Date Initiated (MM/DD/YYYY): 06/03/1993 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): WILLIAM BLAIR & COMPANY 6. Principal Product Type: Money Market Fund(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE DIVISION ALLEGED THAT WILLIAM BLAIR & COMPANY'S AFFILIATE, WILLIAM BLAIR MUTUAL FUNDS, INC. SOLD UNREGISTERED MUTUAL FUND SHARES IN TENNESSEE BETWEEN JULY 1991 AND OCTOBER 1992. THE VALUE OF THE SECURITIES ALLEGEDLY TOTALLED $30,500 IN 20 TRANSACTIONS. 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: Settled 11. Resolution Date (MM/DD/YYYY): 12/12/1994 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: $ 20,000.00 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: AFTER DISPUTING THE DIVISION'S ALLEGATIONS FOR A PERIOD OF 18 MONTHS, WILLIAM BLAIR & COMPANY AGREED TO SETTLE THE MATTER AND PAID A FINE OF $20,000. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). WILLIAM BLAIR & COMPANY VIGOROUSLY OPPOSED THE DIVISIONS ALLEGATIONS THAT UNREGISTERED SHARES HAD BEEN SOLD IN TENNESSEE. AN APPLICATION WAS FILED DURING THE ROUTINE RENEWAL PROCESS IN ADVANCE OF THE FUNDS EXPIRATION. EIGHT MONTHS AFTER THE RENEWAL WAS SUBMITTED, THE DIVISION DEEMED IT INCOMPLETE FOR INSUFFICIENT FILING FEES.
regulatory · block 14PDF pages 142–144
- Regulator name — filed text
- NASD
- Monetary/Fine Amount — filed text
- $ 25,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
DURING THE FIRST AND FOURTH QUARTERS OF 2004, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY TRANSMITTED TO OATS REPORTS THAT CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA AND FAILED TO SUBMIT REQUIRED INFORMATION TO OATS REGARDING ONE ORDER. ON 18 OCCASIONS DURING THE FOURTH QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO COMPLY WITH THE LIMIT ORDER DISPLAY RULE. FURTHER, IN THE FIRST QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO CONDUCT INDEPENDENT REVIEWS OF LIMIT ORDERS TO ENSURE THAT THE AUTOMATED COMPLIANCE SYSTEM WAS WORKING AS INTENDED.
Sanction detail — filed text
THE FIRM WAS NOTIFIED ON FEBRUARY 15, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $25,000 TO SETTLE THE MATTER. THE FINE WAS PAID ON MARCH 9, 2007.
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)
NASD
2.
Principal Sanction:
Censure
Other Sanctions:
FINE OF $25,000
3.
Date Initiated (MM/DD/YYYY):
02/23/2005
Exact
Explanation
If not exact, provide explanation:
EXAM NO. 2005001403 WAS INITIATED ON FEBRUARY 23, 2005; EXAM NO. 20050002524 WAS INITIATED ON FEBRUARY 9, 2005 AND EXAM NO.
20050009075 WAS INITIATED ON MARCH 14, 2005. THE FINDINGS OF THE THREE EXAMS WERE COMBINED BY THE NASD INTO ONE COMPLAINT.
4.
Docket/Case Number:
20050001403-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE FIRST AND FOURTH QUARTERS OF 2004, WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY TRANSMITTED TO OATS REPORTS THAT
CONTAINED INACCURATE, INCOMPLETE OR IMPROPERLY FORMATTED DATA AND FAILED TO SUBMIT REQUIRED INFORMATION TO OATS REGARDING ONE
ORDER. ON 18 OCCASIONS DURING THE FOURTH QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO COMPLY WITH THE LIMIT ORDER DISPLAY RULE.
FURTHER, IN THE FIRST QUARTER OF 2004 THE FIRM ALLEGEDLY FAILED TO CONDUCT INDEPENDENT REVIEWS OF LIMIT ORDERS TO ENSURE THAT THE
AUTOMATED COMPLIANCE SYSTEM WAS WORKING AS INTENDED.
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):
02/15/2007
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: $ 25,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM WAS NOTIFIED ON FEBRUARY 15, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY
COUNCIL HAD ACCEPTED THE ACCEPTANCE, WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE
ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $25,000 TO SETTLE THE MATTER. THE
FINE WAS PAID ON MARCH 9, 2007.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).regulatory · block 15PDF pages 144–146
- Regulator name — filed text
- NASD
- Monetary/Fine Amount — filed text
- $ 20,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
DURING THE THIRD QUARTER OF 2005 WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4 BY FAILING TO IMMEDIATELY DISPLAY TWENTY-TWO (22)CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES, IN ITS PUBLIC QUOTATION. DURING THE SAME TIME PERIOD, THE FIRM ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) BY TRANSMITTING TO OATS, REPORTS CONCERNING SEVENTY (70) ORDERS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA.
Sanction detail — filed text
THE FIRM WAS NOTIFIED ON DECEMBER 12, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY COUNCIL HAD ACCEPTED THE ACCEPTANCE,WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $20,000 TO SETTLE THE MATTER (CONSISTING OF $10,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS AND $10,000 FOR THE OATS VIOLATIONS).
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)
NASD
2.
Principal Sanction:
Censure
Other Sanctions:
FINE OF $20,000
3.
Date Initiated (MM/DD/YYYY):
11/06/2005
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050032430-01
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE THIRD QUARTER OF 2005 WILLIAM BLAIR & COMPANY ("THE FIRM") ALLEGEDLY VIOLATED SEC RULE 11AC1-4 BY FAILING TO IMMEDIATELY
DISPLAY TWENTY-TWO (22)CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES, IN ITS PUBLIC QUOTATION. DURING THE SAME TIME PERIOD, THE FIRM
ALLEGEDLY VIOLATED NASD MARKETPLACE RULE 6955(A) BY TRANSMITTING TO OATS, REPORTS CONCERNING SEVENTY (70) ORDERS THAT CONTAINED
INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
12/12/2007
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: $ 20,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM WAS NOTIFIED ON DECEMBER 12, 2007 THAT THE NASD'S OFFICE OF DISCIPLINARY AFFAIRS AND THE NATIONAL ADJUDICATORY
COUNCIL HAD ACCEPTED THE ACCEPTANCE,WAIVER AND CONSENT (AWC) TO SETTLE THE COMPLAINT. WITHOUT ADMITTING OR DENYING THE
ALLEGATIONS CONTAINED IN THE COMPLAINT, WILLIAM BLAIR & COMPANY AGREED TO PAY THE FINE OF $20,000 TO SETTLE THE MATTER
(CONSISTING OF $10,000 FOR THE LIMIT ORDER DISPLAY VIOLATIONS AND $10,000 FOR THE OATS VIOLATIONS).
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).regulatory · block 16PDF pages 146–148
- Regulator name — filed text
- NASDAQ
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
THE FIRM ALLEGEDLY ENTERED 11 ORDERS INTO THE NASDAQ MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE.
Sanction detail — filed text
FINE OF $5000.00
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) NASDAQ 2. Principal Sanction: Other Other Sanctions: FINE OF $5000.00 3. Date Initiated (MM/DD/YYYY): 02/12/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 20060063857-02 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: NASDAQ SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FIRM ALLEGEDLY ENTERED 11 ORDERS INTO THE NASDAQ MARKET CENTER THAT FAILED TO CORRECTLY INDICATE WHETHER THE ORDERS WERE A BUY, SHORT SALE OR LONG SALE. 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): 02/12/2010 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: FINE OF $5000.00 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 17PDF pages 148–149
- Regulator name — filed text
- NASDAQ
- Monetary/Fine Amount — filed text
- $ 25,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED, IN 157 INSTANCES, TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NBBO AND FAILED TO MAINTAIN A CONTINUING TWO-SIDED TRADING INTEREST DURING THE ENTIRE TRADING DAY REQUIRED BY NASDAQ RULE 4613(A), FOR THE REVIEW PERIOD OCTOBER 1, 2018 THROUGH MARCH 31, 2019. THE VIOLATIONS OCCURRED BECAUSE OF A SYSTEM ISSUE WITH THE FIRM'S ORDER MANAGEMENT SYSTEM. THE CONDUCT ALSO CONSTITUTES A VIOLATION OF NASDAQ RULES 2010A AND 3010.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $25,000 (COMPRISED OF $12,500 FOR THE VIOLATIONS OF NASDAQ RULE 4613(A) AND $12,500 FOR THE VIOLATIONS OF NASDAQ RULES 2010A AND 3010)
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) NASDAQ 2. Principal Sanction: Other Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 07/02/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2019.06.0052 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED, IN 157 INSTANCES, TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NBBO AND FAILED TO MAINTAIN A CONTINUING TWO-SIDED TRADING INTEREST DURING THE ENTIRE TRADING DAY REQUIRED BY NASDAQ RULE 4613(A), FOR THE REVIEW PERIOD OCTOBER 1, 2018 THROUGH MARCH 31, 2019. THE VIOLATIONS OCCURRED BECAUSE OF A SYSTEM ISSUE WITH THE FIRM'S ORDER MANAGEMENT SYSTEM. THE CONDUCT ALSO CONSTITUTES A VIOLATION OF NASDAQ RULES 2010A AND 3010. 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): 09/01/2020 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: $ 25,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM WAS CENSURED AND FINED $25,000 (COMPRISED OF $12,500 FOR THE VIOLATIONS OF NASDAQ RULE 4613(A) AND $12,500 FOR THE VIOLATIONS OF NASDAQ RULES 2010A AND 3010) 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 18WILLIAM BLAIR INVESTMENT MANAGEMENT, LLCPDF pages 150–151
- Advisory affiliate name — filed text
- WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC
- Regulator name — filed text
- U.S. SECURITIES & EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 10,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS.
Other filed details
Description of allegations — filed text
ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS.
Sanction detail — filed text
THE FIRM IS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL PAY A CIVIL MONEY FINE OF $10,000,000 JOINTLY AND SEVERALLY, AND SHALL COMPLY WITHCERTAIN UNDERTAKINGS.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (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) U.S. SECURITIES & EXCHANGE COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/29/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-21764 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: BROKER-DEALER OFF-CHANNEL COMMUNICATIONS INITIATIVE 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 09/29/2023 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: $ 10,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: UNDERTAKINGS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: THE FIRM IS ORDERED TO CEASE AND DESIST, IS CENSURED, SHALL PAY A CIVIL MONEY FINE OF $10,000,000 JOINTLY AND SEVERALLY, AND SHALL COMPLY WITHCERTAIN UNDERTAKINGS. 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). ON SEPTEMBER 29, 2023, WILLIAM BLAIR & COMPANY, L.L.C. AND WILLIAM BLAIR INVESTMENT MANAGEMENT, LLC (COLLECTIVELY, WILLIAM BLAIR) ENTERED INTO A SETTLEMENT WITH THE U.S. SECURITIES & EXCHANGE COMMISSION (SEC) IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT REQUIRES WILLIAM BLAIR TO PAY A CIVIL MONETARY PENALTY OF $10,000,000 AND RETAIN A COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. WILLIAM BLAIR COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS.
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