Pershing Square Capital Management, L.P.

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:
132982
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PERSHING SQUARE CAPITAL
MANAGEMENT, L.P.
(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 AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/17/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 4608
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):
ON JANUARY 17, 2017, THE SEC INSTITUTED ADMINISTRATIVE PROCEEDINGS AGAINST THE REGISTRANT, PURSUANT TO SECTION 203(E) AND 203(K) OF
THE ADVISERS ACT, FINDING THAT THE REGISTRANT HAD VIOLATED ADVISERS ACT RULE 206(4)-5 WHEN A FORMER EMPLOYEE MADE A $500 PERSONAL
POLITICAL CONTRIBUTION TO A CANDIDATE FOR THE DEMOCRATIC PARTY NOMINATION FOR GOVERNOR OF MASSACHUSETTS (THE "CONTRIBUTION")
WHILE THE REGISTRANT ADVISED A FUND WHERE A MASSACHUSETTS GOVERNMENT ENTITY (THE "INVESTOR") WAS AN INVESTOR. THE SEC FOUND
THAT, AFTER THE CONTRIBUTION WAS MADE, ITS RETURN WAS SOUGHT AND RECEIVED, AND NOTED THAT ADVISERS ACT RULE 206(4)-5 DOES NOT
REQUIRE A SHOWING OF QUID PRO QUO OR ACTUAL INTENT TO INFLUENCE AN ELECTED OFFICIAL OR CANDIDATE.
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):
01/17/2017
 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: $ 75,000.00
 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: 
WITHOUT ADMITTING TO ANY ALLEGATIONS, THE REGISTRANT CONSENTED TO THE ISSUANCE OF AN ORDER AND PAID A CIVIL MONEY PENALTY
OF $75,000 ON JANUARY 18, 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).
ON JANUARY 17, 2017, THE REGISTRANT AND THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "COMMISSION") ENTERED INTO A SETTLEMENT
REGARDING A PREVIOUSLY REPORTED CAMPAIGN CONTRIBUTION BY A FORMER EMPLOYEE MADE IN VIOLATION OF THE COMMISSION'S RULES
GOVERNING POLITICAL CONTRIBUTIONS BY INVESTMENT ADVISER EMPLOYEES AND THE REGISTRANT'S OWN COMPLIANCE POLICIES. WITHOUT
ADMITTING OR DENYING LIABILITY, THE REGISTRANT AGREED TO PAY $75,000 TO RESOLVE THIS MATTER. THE $500 CONTRIBUTION IN QUESTION WAS
TO THE SISTER OF A PERSONAL FRIEND OF THE FORMER EMPLOYEE. THE FRIEND'S SISTER WAS TRYING, UNSUCCESSFULLY, TO ENTER ONE OF THE
GUBERNATORIAL PRIMARIES IN MASSACHUSETTS. THE CONTRIBUTION WAS MADE OVER TWO YEARS AFTER A MASSACHUSETTS PENSION FUND FIRST
INVESTED WITH THE REGISTRANT'S FUNDS. THE FORMER EMPLOYEE REQUESTED THAT THE CONTRIBUTION BE RETURNED, AND IT WAS REFUNDED. THE
REGISTRANT WAS UNAWARE OF THE CONTRIBUTION AT THE TIME IT WAS MADE. UPON LEARNING OF THE CONTRIBUTION, THE REGISTRANT FILED AN
EXEMPTION APPLICATION WITH THE COMMISSION'S DIVISION OF INVESTMENT MANAGEMENT STATING THAT IT SHOULD NOT BEAR ANY LIABILITY FOR
ITS FORMER EMPLOYEE'S ERROR. AS MADE CLEAR IN THE EXEMPTION APPLICATION, THE $500 CONTRIBUTION, WHICH WAS $350 GREATER THAN
PERMITTED BY COMMISSION RULES, WAS MADE BY A FORMER EMPLOYEE WHO WAS NOT A MEMBER OF THE REGISTRANT'S INVESTOR RELATIONS
GROUP AND WAS NOT RESPONSIBLE FOR SECURING OR RETAINING INVESTMENTS IN THE REGISTRANT'S FUNDS. THE CONTRIBUTION WAS MADE IN
DIRECT VIOLATION OF THE REGISTRANT'S WRITTEN COMPLIANCE POLICIES AND WAS CONTRARY TO A SUBSEQUENT CERTIFICATION BY THE EMPLOYEE
THAT HE HAD COMPLIED WITH THE REGISTRANT'S POLICIES GOVERNING POLITICAL CAMPAIGN CONTRIBUTIONS. MOREOVER, AT PRECISELY THE SAME
TIME AS THE UNREPORTED CONTRIBUTION, THE REGISTRANT'S CHIEF EXECUTIVE OFFICER WILLIAM A. ACKMAN REQUESTED PERMISSION FROM THE
REGISTRANT'S COMPLIANCE GROUP TO MAKE AN IDENTICAL CONTRIBUTION TO THE SAME PERSON IN MASSACHUSETTS. WHEN INFORMED OF THE
$150 LIMIT, MR. ACKMAN MADE A $150 CONTRIBUTION, AS PERMITTED BY LAW. THE ORDER SETTLING THIS MATTER BRIEFLY DESCRIBES THE
CIRCUMSTANCES THAT SERVE AS THE BASIS FOR THE VIOLATION, WHICH ARE SET FORTH IN GREATER DETAIL IN THE REGISTRANT'S EXEMPTION
APPLICATION AND WHICH, AS OF THE DATE HEREOF, IS AVAILABLE ON THE COMMISSION'S WEBSITE. THE ORDER ALSO FINDS THAT THE RULE IN
QUESTION DOES NOT REQUIRE A SHOWING OF ACTUAL INTENT TO INFLUENCE A CANDIDATE FOR ELECTED OFFICE, AND THAT THE COMMISSION WAS
NOT REQUIRED TO SHOW THAT THE REGISTRANT WAS EVEN AWARE THAT IT WAS VIOLATING THE RULE. THE REGISTRANT FOLLOWS RIGOROUS
COMPLIANCE PROCEDURES, TAKES ALL REASONABLE STEPS TO ENFORCE ITS POLICIES, AND CAREFULLY TRAINS AND PERIODICALLY REMINDS ALL
EMPLOYEES AND RELATED PARTIES OF THOSE POLICIES.