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 Essex Financial Services, Inc..
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 Essex Financial Services, Inc...
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-08-25 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ESSEX BANKSHAREHOLDERDomestic entity | ESSEX FINANCIAL SERVICES, INC. | 75% or moreCode E | Yes | SHAREHOLDER04/2003 | Schedule APDF page 22 |
| 2 | DOUGLAS WILLIAMS PAULCHAIRMANIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | CHAIRMAN08/2013 | Schedule APDF page 22 |
| 3 | BRUCE MICHAEL GLOWACDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR10/2013 | Schedule APDF page 22 |
| 4 | Ronald Clark NelsonDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR10/2025 | Schedule APDF page 22 |
| 5 | Charles Robert CumelloPRESIDENT & CHIEF EXECUTIVE OFFICER, DIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | PRESIDENT & CHIEF EXECUTIVE OFFICER, DIRECTOR12/2013 | Schedule APDF page 22 |
| 6 | MARY EMELIA BOONEDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR11/2013 | Schedule APDF page 22 |
| 7 | GEOFFREY LEE JACOBSONDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR09/2018 | Schedule APDF page 22 |
| 8 | JOHN BAUERDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR09/2018 | Schedule APDF page 22 |
| 9 | STEPHEN DEANE GRESHAMDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR03/2020 | Schedule APDF page 22 |
| 10 | Nancy StillmanCHIEF COMPLIANCE OFFICERIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER06/2025 | Schedule APDF page 22 |
| 11 | SUSAN K ROTHCHIEF OPERATING OFFICER, TREASURER, SECRETARYIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER, TREASURER, SECRETARY10/2025 | Schedule APDF page 23 |
| 12 | LYNN KAREN GIROUXDIRECTORIndividual | ESSEX FINANCIAL SERVICES, INC. | Less than 5%Code NA | Yes | DIRECTOR08/2026 | Schedule APDF page 23 |
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 8/25/2026 8:43:24 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 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?No
- 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 2 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 23–25
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
THE ALLEGED VIOLATIONS OCCURRED FROM EARLY 2011 TO AT LEAST APRIL 2013, WHEN THE FIRM'S FORMER PRESIDENT AND CEO, ALONG WITH A CONNECTICUT ATTORNEY, FRAUDULENTLY SCHEMED TO CIRCUMVENT THE RULE REGARDING PAYMENTS FOR CLIENT SOLICITATIONS. THE FIRM SELF- REPORTED THE ALLEGED VIOLATIONS TO THE COMMISSION AND ON NOVEMBER 23, 2015, THE FIRM TERMINATED THE EMPLOYMENT OF ITS FORMER PRESIDENT AND CEO. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. IN THE OFFER, THE FIRM AGREED TO PROVIDE DISGORGEMENT OF $170,000 (PLUS INTEREST), WHICH REPRESENTED REVENUE THE FIRM RECEIVED FROM THE IMPROPER REFERRAL FEE ARRANGEMENT. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY THE FIRM AND COOPERATION AFFORDED THE COMMISSION STAFF.
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION ALLEGED THAT THE FIRM VIOLATED THE CASH SOLICITATION PORTIONS OF THE INVESTMENT ADVISERS ACT WHICH PROHIBIT THE PAYMENT OF REFERRAL FEES TO A SOLICITOR UNLESS DISCLOSURE AND OTHER REQUIREMENTS ARE MET.
Sanction detail — filed text
DISGORGEMENT OF $170,000 AND INTEREST OF $13181.31 PAID ON JANUARY 19, 2017.
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) SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: DISGORGEMENT OF $170,000 AND PREJUDGEMENT INTEREST OF $13,181.31. 3. Date Initiated (MM/DD/YYYY): 01/09/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-17762 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE SECURITIES AND EXCHANGE COMMISSION ALLEGED THAT THE FIRM VIOLATED THE CASH SOLICITATION PORTIONS OF THE INVESTMENT ADVISERS ACT WHICH PROHIBIT THE PAYMENT OF REFERRAL FEES TO A SOLICITOR UNLESS DISCLOSURE AND OTHER REQUIREMENTS ARE MET. 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): 01/09/2017 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: DISGORGEMENT OF $170,000 AND PREJUDGEMENT INTEREST OF $13,181.31. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: DISGORGEMENT OF $170,000 AND INTEREST OF $13181.31 PAID ON JANUARY 19, 2017. 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 ALLEGED VIOLATIONS OCCURRED FROM EARLY 2011 TO AT LEAST APRIL 2013, WHEN THE FIRM'S FORMER PRESIDENT AND CEO, ALONG WITH A CONNECTICUT ATTORNEY, FRAUDULENTLY SCHEMED TO CIRCUMVENT THE RULE REGARDING PAYMENTS FOR CLIENT SOLICITATIONS. THE FIRM SELF- REPORTED THE ALLEGED VIOLATIONS TO THE COMMISSION AND ON NOVEMBER 23, 2015, THE FIRM TERMINATED THE EMPLOYMENT OF ITS FORMER PRESIDENT AND CEO. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION DETERMINED TO ACCEPT. IN THE OFFER, THE FIRM AGREED TO PROVIDE DISGORGEMENT OF $170,000 (PLUS INTEREST), WHICH REPRESENTED REVENUE THE FIRM RECEIVED FROM THE IMPROPER REFERRAL FEE ARRANGEMENT. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY THE FIRM AND COOPERATION AFFORDED THE COMMISSION STAFF.
regulatory · block 2PDF pages 25–27
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
EFS, IN ITS CAPACITY AS A REGISTERED INVESTMENT ADVISER, VOLUNTARILY PARTICIPATED IN THE COMMISSION'S SHARE CLASS SELECTION DISCLOSURE ("SCSD") INITIATIVE. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EFS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION ACCEPTED. IN DETERMINING TO ACCEPT EFS'S OFFER, THE COMMISSION CONSIDERED THAT EFS SELF-REPORTED ITS CONDUCT TO THE COMMISSION PURSUANT TO THE SCSD INITIATIVE. IN ADDITION THE COMMISSION ACKNOWLEDGED THAT EFS HAS CERTIFIED TO THE COMMISSION STAFF THAT IT HAS COMPLETED CERTAIN UNDERTAKINGS SPECIFIED IN THE OFFER.
Other filed details
Description of allegations — filed text
THE SECURITIES AND EXCHANGE COMMISSION (COMMISSION) FOUND THAT DURING THE PERIOD JANUARY 1, 2014 TO MAY 22, 2018 (THE "RELEVANT PERIOD"), ESSEX FINANCIAL SERVICES, INC. (EFS) PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. EFS FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTERESTS RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. AS A RESULT OF THIS CONDUCT, IT WAS DETERMINED THAT EFS WILLFULLY VIOLATED SECTION 206(2) OF THE ADVISERS ACT.
Sanction detail — filed text
EFS SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY THE PAYABLE AMOUNT OF DISGORGMENT AND PREJUDGMENT INTEREST OF $645,000 AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURE, DISGORGEMENT, UNDERTAKING
3.
Date Initiated (MM/DD/YYYY):
09/30/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19559
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 SECURITIES AND EXCHANGE COMMISSION (COMMISSION) FOUND THAT DURING THE PERIOD JANUARY 1, 2014 TO MAY 22, 2018 (THE "RELEVANT
PERIOD"), ESSEX FINANCIAL SERVICES, INC. (EFS) PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES
THAT CHARGED 12B-1 FEES INSTEAD OF LOWER COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. EFS FAILED TO
DISCLOSE IN ITS FORM ADV OR OTHERWISE THE CONFLICTS OF INTERESTS RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION
OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. AS A RESULT OF THIS CONDUCT, IT WAS DETERMINED THAT EFS WILLFULLY VIOLATED
SECTION 206(2) OF THE ADVISERS ACT.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/30/2019
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST WITH THE DISGORGEMENT. IT WAS ORDERED THAT RESPONDENT SHALL PAY $2,755,879
DISGORGEMENT AND $230,710.94 PREJUDGMENT INTEREST TO AFFECTED INVESTORS, TOTALING $2,986,589.94, BUT PAYMENT OF SUCH
AMOUNT EXCEPT FOR $645,000 ("PAYABLE AMOUNT") WAS WAIVED BASED UPON EFS'S SWORN REPRESENTATIONS IN ITS STATEMENT OF
FINANCIAL CONDITION, DATED NOVEMBER 26, 2018, AND OTHER DOCUMENTS SUBMITTED TO THE COMMISSION.
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:
EFS SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) OF THE
ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY THE PAYABLE AMOUNT OF DISGORGMENT AND PREJUDGMENT INTEREST OF $645,000 AND
SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
EFS, IN ITS CAPACITY AS A REGISTERED INVESTMENT ADVISER, VOLUNTARILY PARTICIPATED IN THE COMMISSION'S SHARE CLASS SELECTION
DISCLOSURE ("SCSD") INITIATIVE. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, EFS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE
COMMISSION ACCEPTED. IN DETERMINING TO ACCEPT EFS'S OFFER, THE COMMISSION CONSIDERED THAT EFS SELF-REPORTED ITS CONDUCT TO THE
COMMISSION PURSUANT TO THE SCSD INITIATIVE. IN ADDITION THE COMMISSION ACKNOWLEDGED THAT EFS HAS CERTIFIED TO THE COMMISSION
STAFF THAT IT HAS COMPLETED CERTAIN UNDERTAKINGS SPECIFIED IN THE OFFER.* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.