Channing Capital Management, LLC

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:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE-AND-DESIST; AND CENSURE
3.
Date Initiated (MM/DD/YYYY): 
11/22/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19605
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
MANAGED/SEPARATE ACCOUNT(S)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGED VIOLATION RELATED TO SECTION 206(4) AND RULE 206(4)-7 OF THE INVESTMENT ADVISERS ACT OF 1940.
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):
11/22/2019
 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: $ 50,000.00
 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: 
CHANNING CAPITAL MANAGEMENT LLC ("CHANNING CAPITAL") ENTERED INTO A VOLUNTARY SETTLEMENT RESOLUTION REACHED WITH THE SEC
THAT INCLUDED A LIMITED NEGOTIATED CIVIL MONETARY PENALTY FINE OF $50,000, PAID ON DECEMBER 3, 2019. ALSO THE CHANNING
CAPITAL AGREED TO A CIVIL REGULATORY CEASE-AND-DESIST ORDER AND RELATED CENSURE.
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 NOVEMBER 22, 2019, CHANNING CAPITAL MANAGEMENT LLC ("CHANNING CAPITAL") ENTERED INTO A VOLUNTARY CONSENT SETTLEMENT WITH
THE SEC, WITHOUT ADMITTING OR DENYING ANY SEC FINDINGS, FOR THE PURPOSE OF VOLUNTARILY RESOLVING CLAIMS THAT IT HAD FAILED TO
APPROPRIATELY IMPLEMENT ITS TRADE AGGREGATION AND ALLOCATION COMPLIANCE POLICY/PROCEDURE REGARDING A CERTAIN PORTION OF ITS
BLOCK TRADES IN VIOLATION OF SECTION 206(4) AND SEC RULE 206(4)-7 UNDER THE INVESTMENT ADVISERS ACT OF 1940. SPECIFICALLY FROM
JANUARY 2014 TO JANUARY 2018, CHANNING CAPITAL'S WRITTEN TRADE AGGREGATION AND ALLOCATION POLICIES AND PROCEDURES REQUIRED IT
TO ALLOCATE THE TRANSACTION COSTS ASSOCIATED WITH BLOCK TRADES ON A PRO-RATA BASIS AMONGST ALL CLIENTS PARTICIPATING IN THE SAME
BLOCK TRADE. A SEPARATE WRITTEN COMPLIANCE POLICY/PROCEDURE (AS PER SEC STANDARDS GOVERNING INVESTMENT PORTFOLIO AND TRADING
COMPLIANCE) REQUIRED CHANNING CAPITAL TO FOLLOW THE REQUIREMENTS AND RESTRICTIONS SET FORTH IN EACH CLIENT'S INVESTMENT
MANAGEMENT AGREEMENT, INCLUDING CLIENT TRADING-BROKERAGE GUIDELINES AND RESTRICTIONS OR LIMITATIONS PLACED ON TRADING

COMMISSIONS OR COMMISSION RATES. 2 OF CHANNING CAPITAL'S THEN 35-45 INSTITUTIONAL CLIENTS PLACED RESTRICTION LIMITATIONS OR CAPS
ON THE AMOUNT THEY WERE WILLING TO PAY IN COMMISSION RATES FOR EXECUTION OF THEIR BROKERAGE TRADES. IN ADHERING TO SUCH CLIENTS'
RESTRICTIONS, CHANNING CAPITAL ROUTINELY CONVEYED THOSE 2 CLIENTS' COMMISSION CAP RESTRICTIONS TO EXECUTING BROKERS AND
REQUESTED THAT SUCH BROKERS ALSO OBSERVE LOWER COMMISSION RATES OF A HALF-CENT TO 1 CENT PER SHARE FOR THOSE 2 CLIENTS WHILE
PERMITTING THEM TO PARTICIPATE IN CERTAIN BLOCK TRADES WITH CHANNING CAPITAL'S OTHER INSTITUTIONAL CLIENTS. THIS PRACTICE RESULTED
IN 2 CLIENTS WITH A TOTAL OF 4 CLIENT ACCOUNTS PARTICIPATING IN A CERTAIN PORTION OF THE SAME BLOCK TRADES WHILE PAYING
DIFFERENTIAL COMMISSION RATES OF A HALF-CENT TO 1 CENT PER SHARE. THIS BLOCK TRADING PRACTICE WAS VOLUNTARILY ENDED AND CEASED
AS OF MID-JANUARY 2018 (APPROXIMATELY 2 YEARS AGO), AS CHANNING CAPITAL VOLUNTARILY CHANGED ITS INTERNAL BLOCK TRADING PRACTICES
TO AVOID AND ELIMINATE BLOCK TRADES BEING EXECUTED WITH DIFFERENTIAL COMMISSION RATES. IN REACHING THIS SETTLEMENT RESOLUTION,
THE SEC ALSO TOOK INTO ACCOUNT THIS VOLUNTARY CORRECTIVE ACTION ALONG WITH THE FIRM'S OTHER VOLUNTARY REMEDIAL STEPS PROMPTLY
UNDERTAKEN REGARDING THIS MATTER AND THE VOLUNTARY COOPERATION AFFORDED TO THE SEC STAFF BY THE FIRM. THE KEY TERMS OF THE
VOLUNTARY SETTLEMENT RESOLUTION REQUIRED THE FIRM TO PAY A CIVIL PENALTY FINE OF $50,000 AND TO CEASE FROM COMMITTING OR CAUSING
ANY FUTURE VIOLATIONS. THE FIRM PAID THE AGREED UPON FINE PROMPTLY AFTER THE SETTLEMENT WAS APPROVED AND FINALIZED BY THE SEC
COMMISSION IN WASHINGTON, D.C.