Buckman Advisory Group 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
CRD
Number:
2202467
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BUCKMAN, HARRY, JOHN

(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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Censure
Other Sanctions: 
CIVIL MONEY PENALTY IN THE AMOUNT OF $75,000, SUSPENDED FROM SUPERVISORY CAPACITY FOR 12 MONTHS
3.
Date Initiated (MM/DD/YYYY): 
09/12/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21069
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
BUCKMAN ADVISORY GROUP, LLC
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 SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934
("EXCHANGE ACT") AND SECTIONS 203(E), 203(F) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST BUCKMAN
ADVISORY GROUP, LLC ("BAG" OR "FIRM") AND HARRY J. BUCKMAN, JR. ("BUCKMAN") (TOGETHER, "RESPONDENTS"). THE COMMISSION FINDS THAT
FROM JANUARY 2012 UNTIL JUNE 2017 (THE "RELEVANT PERIOD"), BRANDER ENGAGED IN A FRAUDULENT "CHERRYPICKING" SCHEME,
DISPROPORTIONATELY ALLOCATING PROFITABLE TRADES TO HIMSELF AND UNPROFITABLE TRADES TO THE ACCOUNTS OF CERTAIN CLIENTS (THE
"DISFAVORED ACCOUNTS" AND "DISFAVORED CLIENTS"). BRANDER ALSO OFTEN USED SHARES OF HIGHLY-LEVERAGED AND RISKY EXCHANGE TRADED
FUNDS ("ETFS") IN HIS CHERRY-PICKING SCHEME, WITHOUT PERFORMING ANY ANALYSIS TO DETERMINE WHETHER THESE ETFS WERE SUITABLE FOR
THE AFFECTED CLIENTS, ALL OF WHOM WERE SEEKING MORE CONSERVATIVE INVESTMENTS. BAG FAILED TO IMPLEMENT POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND ITS RULES, AND IT FAILED REASONABLY TO SUPERVISE BRANDER. IN
PARTICULAR, IT FAILED TO CONDUCT EFFECTIVE REVIEWS OF BRANDER'S ACTIVITIES, EVEN WHEN THOSE REVIEWS WERE MANDATED BY ITS OWN
WRITTEN COMPLIANCE MANUAL, AND IT FAILED TO ENFORCE AS TO BRANDER ITS OWN REQUIREMENT THAT TRADE ALLOCATIONS BE SUBMITTED AT
THE SAME TIME TRADE ORDERS WERE PLACED. IN ADDITION, BAG'S FORM ADV INCLUDED STATEMENTS ABOUT ITS PRACTICES AND PROCEDURES THAT
WERE FALSE OR MISLEADING IN LIGHT OF THE FIRM'S COMPLIANCE AND SUPERVISION FAILURES. UNTIL DECEMBER 2015, UNDER BAG'S POLICIES AND
PROCEDURES, BUCKMAN, IN HIS CIO ROLE, WAS RESPONSIBLE FOR MONITORING BAG'S COMPLIANCE WITH CLIENTS' INVESTMENT PARAMETERS AND
FOR REVIEWING TRADES AND LIMITED INVESTMENT OPPORTUNITY ALLOCATIONS, TO ENSURE THAT NO CLIENT ACCOUNT WAS SYSTEMATICALLY
DISADVANTAGED. IN ADDITION, FROM 2013 TO 2017, IN BAG'S FORMS DV PART 2A, THE FIRM DISCLOSED THAT BUCKMAN, OR A COMPLIANCE OFFICER
WHO REPORTED DIRECTLY TO BUCKMAN, WAS RESPONSIBLE FOR REVIEWING CLIENT ACCOUNTS FOR COMPLIANCE WITH CLIENTS' INVESTMENT
GOALS AND RISK TOLERANCE LEVELS. BUCKMAN FAILED TO EFFECTIVELY CARRY OUT THESE RESPONSIBILITIES. BUCKMAN ALLOWED BRANDER TO
CREATE PORTFOLIOS FOR HIS CLIENTS THAT DIFFERED FROM THE PRE-APPROVED PORTFOLIOS THAT OTHER BAG INVESTMENT ADVISER
REPRESENTATIVES WERE REQUIRED TO USE AND WAS ON NOTICE THAT BRANDER DID NOT ALWAYS ALLOCATE TRADES AT THE TIME ORDERS WERE

PLACED, AND HE FAILED TO IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT ADVISERS ACT VIOLATIONS ASSOCIATED
WITH BRANDER'S MISCONDUCT. HE ALSO FAILED REASONABLY TO SUPERVISE BRANDER. AS A RESULT OF THE CONDUCT DESCRIBED HEREIN, BUCKMAN
CAUSED BAG'S VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT, WILLFULLY AIDED AND ABETTED AND CAUSED BAG'S VIOLATIONS OF SECTION
206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND FAILED REASONABLY TO SUPERVISE BRANDER WITHIN THE MEANING OF
SECTIONS 203(E)(6) AND 203(F) OF THE ADVISERS ACT WITH A VIEW TO PREVENTING BRANDER'S VIOLATIONS OF SECTION 17(A)(1) OF THE
SECURITIES ACT, SECTION 10(B) OF THE EXCHANGE ACT AND RULES 10B-5(A) AND (C) THEREUNDER, AND SECTIONS 206(1) AND 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:
Consent
11. Resolution Date (MM/DD/YYYY):
09/13/2022
 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: $ 75,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SUSPENDED FROM SUPERVISORY CAPACITY FOR 12 MONTHS
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: 
SUSPENDED FROM SUPERVISORY CAPACITY FOR 12 MONTHS FROM 09/13/2022 TO 09/13/2023
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 SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934
("EXCHANGE ACT") AND SECTIONS 203(E), 203(F) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") AGAINST BUCKMAN
ADVISORY GROUP, LLC ("BAG" OR "FIRM") AND HARRY J. BUCKMAN, JR. ("BUCKMAN") (TOGETHER, "RESPONDENTS"). THE COMMISSION FINDS THAT
FROM JANUARY 2012 UNTIL JUNE 2017 (THE "RELEVANT PERIOD"), BRANDER ENGAGED IN A FRAUDULENT "CHERRYPICKING" SCHEME,
DISPROPORTIONATELY ALLOCATING PROFITABLE TRADES TO HIMSELF AND UNPROFITABLE TRADES TO THE ACCOUNTS OF CERTAIN CLIENTS (THE
"DISFAVORED ACCOUNTS" AND "DISFAVORED CLIENTS"). BRANDER ALSO OFTEN USED SHARES OF HIGHLY-LEVERAGED AND RISKY EXCHANGE TRADED
FUNDS ("ETFS") IN HIS CHERRY-PICKING SCHEME, WITHOUT PERFORMING ANY ANALYSIS TO DETERMINE WHETHER THESE ETFS WERE SUITABLE FOR
THE AFFECTED CLIENTS, ALL OF WHOM WERE SEEKING MORE CONSERVATIVE INVESTMENTS. BAG FAILED TO IMPLEMENT POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND ITS RULES, AND IT FAILED REASONABLY TO SUPERVISE BRANDER. IN
PARTICULAR, IT FAILED TO CONDUCT EFFECTIVE REVIEWS OF BRANDER'S ACTIVITIES, EVEN WHEN THOSE REVIEWS WERE MANDATED BY ITS OWN
WRITTEN COMPLIANCE MANUAL, AND IT FAILED TO ENFORCE AS TO BRANDER ITS OWN REQUIREMENT THAT TRADE ALLOCATIONS BE SUBMITTED AT
THE SAME TIME TRADE ORDERS WERE PLACED. IN ADDITION, BAG'S FORM ADV INCLUDED STATEMENTS ABOUT ITS PRACTICES AND PROCEDURES THAT
WERE FALSE OR MISLEADING IN LIGHT OF THE FIRM'S COMPLIANCE AND SUPERVISION FAILURES. UNTIL DECEMBER 2015, UNDER BAG'S POLICIES AND
PROCEDURES, BUCKMAN, IN HIS CIO ROLE, WAS RESPONSIBLE FOR MONITORING BAG'S COMPLIANCE WITH CLIENTS' INVESTMENT PARAMETERS AND
FOR REVIEWING TRADES AND LIMITED INVESTMENT OPPORTUNITY ALLOCATIONS, TO ENSURE THAT NO CLIENT ACCOUNT WAS SYSTEMATICALLY
DISADVANTAGED. IN ADDITION, FROM 2013 TO 2017, IN BAG'S FORMS DV PART 2A, THE FIRM DISCLOSED THAT BUCKMAN, OR A COMPLIANCE OFFICER
WHO REPORTED DIRECTLY TO BUCKMAN, WAS RESPONSIBLE FOR REVIEWING CLIENT ACCOUNTS FOR COMPLIANCE WITH CLIENTS' INVESTMENT
GOALS AND RISK TOLERANCE LEVELS. BUCKMAN FAILED TO EFFECTIVELY CARRY OUT THESE RESPONSIBILITIES. BUCKMAN ALLOWED BRANDER TO
CREATE PORTFOLIOS FOR HIS CLIENTS THAT DIFFERED FROM THE PRE-APPROVED PORTFOLIOS THAT OTHER BAG INVESTMENT ADVISER
REPRESENTATIVES WERE REQUIRED TO USE AND WAS ON NOTICE THAT BRANDER DID NOT ALWAYS ALLOCATE TRADES AT THE TIME ORDERS WERE
PLACED, AND HE FAILED TO IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT ADVISERS ACT VIOLATIONS ASSOCIATED
WITH BRANDER'S MISCONDUCT. HE ALSO FAILED REASONABLY TO SUPERVISE BRANDER. AS A RESULT OF THE CONDUCT DESCRIBED HEREIN, BUCKMAN
CAUSED BAG'S VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT, WILLFULLY AIDED AND ABETTED AND CAUSED BAG'S VIOLATIONS OF SECTION
206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND FAILED REASONABLY TO SUPERVISE BRANDER WITHIN THE MEANING OF
SECTIONS 203(E)(6) AND 203(F) OF THE ADVISERS ACT WITH A VIEW TO PREVENTING BRANDER'S VIOLATIONS OF SECTION 17(A)(1) OF THE
SECURITIES ACT, SECTION 10(B) OF THE EXCHANGE ACT AND RULES 10B-5(A) AND (C) THEREUNDER, AND SECTIONS 206(1) AND 206(2) OF THE
ADVISERS ACT.

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:
Censure
Other Sanctions: 
CIVIL MONEY PENALTY IN THE AMOUNT OF $400,000,CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7
3.
Date Initiated (MM/DD/YYYY): 
09/12/2022
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
2:22-CV-05506
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):
VIOLATED SECTION 206(2) OF THE ADVISERS ACT,VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7, SECTION 206(2), SECTIONS
203(E)(6) AND 203(F)
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/12/2022
 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: $ 400,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7
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: 
NONE
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).
FROM JANUARY 2012 UNTIL JUNE 2017 FAILED TO REASONABLY IMPLEMENT ITS WRITTEN POLICIES AND PROCEDURES WITH REGARD TO ACCOUNT
AND TRADE REVIEWS, AND IN PARTICULAR WITH REGARD TO REVIEWS AS TO EQUITABLE ALLOCATION OF TRADES AND SUITABILITY.