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 Realta Investment Advisors, 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 Realta Investment Advisors, Inc..
Reported ownership and control details
Form ADV · Filing date 2026-08-06 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ORANGE STREET HOLDINGS INCSHAREHOLDERDomestic entity | REALTA INVESTMENT ADVISORS, INC | 75% or moreCode E | Yes | SHAREHOLDER01/2012 | Schedule APDF page 35 |
| 2 | Amy Enith OdomCHIEF COMPLIANCE OFFICERIndividual | REALTA INVESTMENT ADVISORS, INC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER06/2026 | Schedule APDF page 35 |
| 3 | CAMERON FINANCIAL HOLDINGS LLCSHAREHOLDERDomestic entity | ORANGE STREET HOLDINGS INC | 75% or moreCode E | Yes | SHAREHOLDER10/2022 | Schedule BPDF page 35 |
| 4 | MADISON CAPITAL GROUP LLCSHAREHOLDERDomestic entity | CAMERON FINANCIAL HOLDINGS LLC | 75% or moreCode E | No | SHAREHOLDER10/2022 | Schedule BPDF page 35 |
| 5 | RYAN LEE HANKSSHAREHOLDERIndividual | MADISON CAPITAL GROUP LLC | 75% or moreCode E | No | SHAREHOLDER10/2022 | Schedule BPDF page 35 |
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 8/6/2026 8:41:22 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 actions2 Yes2 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?Yes
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 4 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 36–38
- Regulator name — filed text
- SEC
- Monetary/Fine Amount — filed text
- $ 40,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
TOTAL FINE IS $40000, AND $40000 LEVIED AGAINST THE FIRM'S AFFILIATE, COASTAL EQUITIES, INC. AS TO BOTH FIRMS, THE SUM OF $5000 WAS DUE WITHIN TEN (10) DAYS OF THE DATE OF THE ORDER, AND THE REMAINDER DUE WITHIN 360 DAYS OF THE ORDER. THE FIRM HAS PAID THE $5000 IN A TIMELY MANNER. THE FIRM'S AFFILIATE HAS PAID THE TOTAL FINE APPORTIONED TO IT IN FULL.
Other filed details
Description of allegations — filed text
THE SEC ALLEGES THAT THE FIRM FAILED REASONABLY TO SUPERVISE ITS FORMER CEO BY NOT HAVING IN PLACE, UNTIL 2013, REASONABLE POLICIES AND PROCEDURES FOR THE CREATION, USE AND REVIEW OF A CERTAIN TYPE OF CONSOLIDATED REPORTS. THE FIRM CONSENTED TO ENTRY OF AN ORDER OF CENSURE AND A FINE.
Sanction detail — filed text
TOTAL FINE IS $40000, AND $40000 LEVIED AGAINST THE FIRM'S AFFILIATE, COASTAL EQUITIES, INC. AS TO BOTH FIRMS, THE SUM OF $5000 WAS DUE WITHIN TEN (10) DAYS OF THE DATE OF THE ORDER, AND THE REMAINDER DUE WITHIN 360 DAYS OF THE ORDER. THE FIRM HAS PAID THE $5000 IN A TIMELY MANNER. THE FIRM'S AFFILIATE HAS PAID THE TOTAL FINE APPORTIONED TO IT IN FULL.
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) SEC 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 12/11/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-18305 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 SEC ALLEGES THAT THE FIRM FAILED REASONABLY TO SUPERVISE ITS FORMER CEO BY NOT HAVING IN PLACE, UNTIL 2013, REASONABLE POLICIES AND PROCEDURES FOR THE CREATION, USE AND REVIEW OF A CERTAIN TYPE OF CONSOLIDATED REPORTS. THE FIRM CONSENTED TO ENTRY OF AN ORDER OF CENSURE AND A FINE. 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): 12/11/2017 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: $ 40,000.00 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: TOTAL FINE IS $40000, AND $40000 LEVIED AGAINST THE FIRM'S AFFILIATE, COASTAL EQUITIES, INC. AS TO BOTH FIRMS, THE SUM OF $5000 WAS DUE WITHIN TEN (10) DAYS OF THE DATE OF THE ORDER, AND THE REMAINDER DUE WITHIN 360 DAYS OF THE ORDER. THE FIRM HAS PAID THE $5000 IN A TIMELY MANNER. THE FIRM'S AFFILIATE HAS PAID THE TOTAL FINE APPORTIONED TO IT IN FULL. 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). TOTAL FINE IS $40000, AND $40000 LEVIED AGAINST THE FIRM'S AFFILIATE, COASTAL EQUITIES, INC. AS TO BOTH FIRMS, THE SUM OF $5000 WAS DUE WITHIN TEN (10) DAYS OF THE DATE OF THE ORDER, AND THE REMAINDER DUE WITHIN 360 DAYS OF THE ORDER. THE FIRM HAS PAID THE $5000 IN A TIMELY MANNER. THE FIRM'S AFFILIATE HAS PAID THE TOTAL FINE APPORTIONED TO IT IN FULL.
regulatory · block 2LAYTON, LLOYD, THOMASPDF pages 38–39
- Advisory affiliate name — filed text
- LAYTON, LLOYD, THOMAS
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: 1618414 This advisory affiliate is a Firm an Individual Registered: Yes No Name: LAYTON, LLOYD, THOMAS (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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 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: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: 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: 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 3PDF pages 39–41
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE STATUS OF THIS ACTION IS A FINAL ORDER.
Other filed details
Description of allegations — filed text
AS PART OF THE SECURITIES EXCHANGE COMMISSION'S (SEC) MUTUAL FUND SHARE CLASS SELECTION DISCLOSURE INITIATIVE, THE SEC ENCOURAGED INVESTMENT ADVISERS TO SELF-REPORT THE FAILURE TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST ASSOCIATED WITH THE RECOMMENDATION OR SELECTION OF A MUTUAL FUND SHARE CLASS THAT CHARGED DISTRIBUTION FEES ("12B-1 FEES") WHEN A LOWER-COST SHARE CLASS OF THE SAME FUND EXISTED. FOR COMPANIES WHO SELF-REPORTED, THE SEC INDICATED IT WOULD RECOMMEND FAVORABLE STANDARDIZED SETTLEMENT TERMS, INCLUDING NO PENALTIES. COASTAL ELECTED TO JOIN THE SEC'S INDUSTRY-WIDE VOLUNTARY INITIATIVE REGARDING FEES COLLECTED ON CERTAIN MUTUAL FUND CLASSES BETWEEN 2014 AND 2018. COASTAL WILL REFUND THE ASSOCIATED 12B-1 FEES AND INTEREST TO CLIENTS WHO HELD THOSE TYPES OF FUNDS DURING THIS TIME PERIOD.
Sanction detail — filed text
DISGORGEMENT TOTAL AMOUNT IS $69,167.81 PLUS INTEREST IN THE SUM OF $6,976.27.
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:
Disgorgement
Other Sanctions:
CEASE AND DESIST AND CENSURE
3.
Date Initiated (MM/DD/YYYY):
08/22/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-19085
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):
AS PART OF THE SECURITIES EXCHANGE COMMISSION'S (SEC) MUTUAL FUND SHARE CLASS SELECTION DISCLOSURE INITIATIVE, THE SEC
ENCOURAGED INVESTMENT ADVISERS TO SELF-REPORT THE FAILURE TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST ASSOCIATED WITH THE
RECOMMENDATION OR SELECTION OF A MUTUAL FUND SHARE CLASS THAT CHARGED DISTRIBUTION FEES ("12B-1 FEES") WHEN A LOWER-COST SHARE
CLASS OF THE SAME FUND EXISTED. FOR COMPANIES WHO SELF-REPORTED, THE SEC INDICATED IT WOULD RECOMMEND FAVORABLE STANDARDIZED
SETTLEMENT TERMS, INCLUDING NO PENALTIES. COASTAL ELECTED TO JOIN THE SEC'S INDUSTRY-WIDE VOLUNTARY INITIATIVE REGARDING FEES
COLLECTED ON CERTAIN MUTUAL FUND CLASSES BETWEEN 2014 AND 2018. COASTAL WILL REFUND THE ASSOCIATED 12B-1 FEES AND INTEREST TO
CLIENTS WHO HELD THOSE TYPES OF FUNDS DURING THIS TIME PERIOD.
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):
03/11/2019
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:
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 TOTAL AMOUNT IS $69,167.81 PLUS INTEREST IN THE SUM OF $6,976.27.
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 STATUS OF THIS ACTION IS A FINAL ORDER.regulatory · block 4HORN, STEVENPDF pages 41–43
- Advisory affiliate name — filed text
- HORN, STEVEN
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
SUSPENSION ENDED 5/16/2023.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, HORN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE MADE RECKLESS MISREPRESENTATIONS IN A LOAN APP AND LOAN AGREEMENT HE SUBMITTED TO THE SMALL BUSINESS ADMINISTRATION (SBA) TO OBTAIN AN ECONOMIC INJURY DISASTER LOAN (EIDL). THE FINDINGS STATED THAT IN THE APPLICATION, HORN RECKLESSLY MISREPRESENTED THAT HE OWNED A SOLE PROPRIETORSHIP UNDER THE BUSINESS NAME STEVEN HORN, USING A TAX ID NUMBER THAT WAS IDENTIC PERSONAL SOCIAL SECURITY NUMBER, THAT THE PRIMARY EMAIL ADDRESS FOR THIS BUSINESS WAS HIS PERSONAL EMAIL ADDRESS AND THAT THE REVENUES AND COSTS ASSOCIATED W MEMBER FIRM BUSINESS WERE THOSE OF THE SOLE PROPRIETORSHIP. IN ACTUALITY, HORN WAS PROVIDING FINANCIAL SERVICES ONLY IN HIS CAPACITY AS A REGISTERED REPRESENTATIV THE FIRM. HORN DID NOT HAVE ANY OBAS, INCLUDING ANY SOLE PROPRIETORSHIP OR OTHER FINANCIAL SERVICES BUSINESS BEARING HIS NAME AND PERSONAL SOCIAL SECURITY NUMB ADDITION, HORN WAS USING ONLY HIS FIRM- ISSUED EMAIL ADDRESS TO CONDUCT HIS FINANCIAL SERVICES BUSINESS, NOT HIS PERSONAL EMAIL ADDRESS. HORN'S FIRM BUSINESS WAS ELIGIBLE FOR AN EIDL, AND HE DID NOT HAVE ANY OTHER BUSINESS ELIGIBLE FOR AN EIDL FROM THE SBA. BASED ON HORN'S MISREPRESENTATIONS, THE SBA APPROVED HORN'S APPLICATION. HORN SIGNED THE LOAN AGREEMENT, WHICH CONTAINED AN AFFIRMATION THAT THE REPRESENTATIONS MADE IN HIS APPLICATION WERE CORRECT. HORN DID NOT REVIEW LOAN AGREEMENT BEFORE SIGNING IT. SUBSEQUENTLY, THE SBA PROVIDED HORN WITH A $150,000 LOAN. HORN LATER REPAID THE LOAN IN FULL, WITH INTEREST TO THE SBA.
Sanction detail — filed text
SUSPENSION OF ALL CAPACITY FOR SEVEN MONTHS, STARTING 10/17/2022 AND ENDING 5/16/2023.
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: 2579003 This advisory affiliate is a Firm an Individual Registered: Yes No Name: HORN, STEVEN (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) FINRA 2. Principal Sanction: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 09/30/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2020068856201 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): CITI GROUP GLOBAL MARKETS INC 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, HORN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE MADE RECKLESS MISREPRESENTATIONS IN A LOAN APP AND LOAN AGREEMENT HE SUBMITTED TO THE SMALL BUSINESS ADMINISTRATION (SBA) TO OBTAIN AN ECONOMIC INJURY DISASTER LOAN (EIDL). THE FINDINGS STATED THAT IN THE APPLICATION, HORN RECKLESSLY MISREPRESENTED THAT HE OWNED A SOLE PROPRIETORSHIP UNDER THE BUSINESS NAME STEVEN HORN, USING A TAX ID NUMBER THAT WAS IDENTIC PERSONAL SOCIAL SECURITY NUMBER, THAT THE PRIMARY EMAIL ADDRESS FOR THIS BUSINESS WAS HIS PERSONAL EMAIL ADDRESS AND THAT THE REVENUES AND COSTS ASSOCIATED W MEMBER FIRM BUSINESS WERE THOSE OF THE SOLE PROPRIETORSHIP. IN ACTUALITY, HORN WAS PROVIDING FINANCIAL SERVICES ONLY IN HIS CAPACITY AS A REGISTERED REPRESENTATIV THE FIRM. HORN DID NOT HAVE ANY OBAS, INCLUDING ANY SOLE PROPRIETORSHIP OR OTHER FINANCIAL SERVICES BUSINESS BEARING HIS NAME AND PERSONAL SOCIAL SECURITY NUMB ADDITION, HORN WAS USING ONLY HIS FIRM- ISSUED EMAIL ADDRESS TO CONDUCT HIS FINANCIAL SERVICES BUSINESS, NOT HIS PERSONAL EMAIL ADDRESS. HORN'S FIRM BUSINESS WAS ELIGIBLE FOR AN EIDL, AND HE DID NOT HAVE ANY OTHER BUSINESS ELIGIBLE FOR AN EIDL FROM THE SBA. BASED ON HORN'S MISREPRESENTATIONS, THE SBA APPROVED HORN'S APPLICATION. HORN SIGNED THE LOAN AGREEMENT, WHICH CONTAINED AN AFFIRMATION THAT THE REPRESENTATIONS MADE IN HIS APPLICATION WERE CORRECT. HORN DID NOT REVIEW LOAN AGREEMENT BEFORE SIGNING IT. SUBSEQUENTLY, THE SBA PROVIDED HORN WITH A $150,000 LOAN. HORN LATER REPAID THE LOAN IN FULL, WITH INTEREST TO THE SBA. 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): 09/30/2022 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: $ 10,000.00 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: SUSPENSION OF ALL CAPACITY FOR SEVEN MONTHS, STARTING 10/17/2022 AND ENDING 5/16/2023. 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). SUSPENSION ENDED 5/16/2023.
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