American Independent Securities 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:
4209072
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CARLSON, RYAN SHANE
(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:
Restitution
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/29/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

2018060267902
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
AMERICAN INDEPENDENT SECURITIES GROUP, LLC
6.
Principal Product Type:
Debt - Asset Backed
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, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
APPLICABLE RULES RELATING TO SALES OF COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS). THE FINDINGS STATED THAT THE FIRM DID NOT
ESTABLISH ANY PROCEDURES RELATED TO CMO TRANSACTIONS OR THE SUITABILITY OF CMO RECOMMENDATIONS. THERE WAS NO REASONABLE
PROCESS TO EVALUATE AND DETERMINE WHETHER INVERSE FLOATERS (IFS) WERE APPROPRIATE FOR A GIVEN CUSTOMER OR TO ASSESS THE SIZE OF
THE CMO INVESTMENT. THERE WAS ALSO NO GUIDANCE ADDRESSING TO WHOM CMOS COULD BE OFFERED, THE EXTENT TO WHICH A CUSTOMER'S
ACCOUNT COULD BE CONCENTRATED IN IFS OR OTHER CMOS, OR THE PERCENTAGE OF A CUSTOMER'S NET WORTH THAT COULD BE INVESTED IN
CMOS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE A REGISTERED REPRESENTATIVE. THE FIRM'S CHIEF
COMPLIANCE OFFICER (CCO) DELEGATED TO A FIRM PRINCIPAL THE RESPONSIBILITY OF SUPERVISING THE REPRESENTATIVE. ALTHOUGH THE FIRM
DID NOT HAVE ANY WSPS ADDRESSING CMO TRANSACTIONS, THE PRINCIPAL IGNORED MULTIPLE RED FLAGS THAT SHOULD HAVE ALERTED HIM THAT
THE REPRESENTATIVE'S IF RECOMMENDATIONS WERE POTENTIALLY UNSUITABLE. IN PARTICULAR, IFS WERE RISKY AND ILLIQUID PRODUCTS THAT
WERE INCONSISTENT WITH THE CUSTOMERS' INVESTMENT OBJECTIVES AND RISK TOLERANCES, THE REPRESENTATIVE'S CUSTOMER ACCOUNTS WERE
ENTIRELY CONCENTRATED IN IFS, TRANSACTIONS WERE FLAGGED IN THE FIRM'S TRADE REVIEW SYSTEM, A MAJORITY OF THE CUSTOMERS WERE
SENIORS, MANY ACCOUNT HOLDERS HAD LIMITED INCOME AND NET WORTH, AND THE CUSTOMERS PURCHASED THE SAME CMOS AT THE SAME TIME.
THE PRINCIPAL SHOULD HAVE FOLLOWED UP ON THESE RED FLAGS BUT FAILED TO TAKE REASONABLE ACTION. THE FINDINGS ALSO INCLUDED THAT
THE FIRM FAILED TO TAKE REASONABLE ACTION TO ENSURE THE PRINCIPAL PROPERLY EXECUTED DELEGATED RESPONSIBILITIES AND FAILED TO
RESPOND TO RED FLAGS. THE CCO DELEGATED TO THE PRINCIPAL THE RESPONSIBILITY FOR SUPERVISING THE REGISTERED REPRESENTATIVE AND
THEREFORE WAS RESPONSIBLE FOR ENSURING THE PRINCIPAL PROPERLY EXECUTED THAT RESPONSIBILITY. THE CCO SHOULD HAVE BEEN
CONCERNED ABOUT THE REPRESENTATIVE'S RECOMMENDATIONS AND THE PRINCIPAL'S SUPERVISION OF THEM AND SHOULD HAVE ACTED ON THOSE
CONCERNS. THE CCO WAS AWARE OF THE RED FLAGS AND KNEW THAT THE PRINCIPAL SUPERVISED THE REPRESENTATIVE'S ACTIVITY EVEN THOUGH
HE HAD NO SPECIALIZED TRAINING RELATING TO CMOS AND IFS AND NO PRIOR EXPERIENCE SUPERVISING SALES OF THE PRODUCT. THE CCO ALSO
WAS AWARE THAT THE REPRESENTATIVE'S TRANSACTIONS SET OFF ALERTS IN THE FIRM'S TRADE REVIEW SYSTEM. NONETHELESS, THE CCO DID NOT
FOLLOW UP ON THESE RED FLAGS AND TOOK NO ACTION TO ADDRESS THE SUITABILITY ISSUES OR ENSURE THAT THE SUPERVISORY
RESPONSIBILITIES HE HAD DELEGATED WERE REASONABLY EXERCISED. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY SUPERVISE
DISCRETIONARY AND SENIOR ACCOUNTS. THE FIRM PROCEDURES ASSIGNED TO THE CCO RESPONSIBILITY FOR ENSURING THAT THE FIRM
CONSIDERED AN INDIVIDUAL'S INVESTMENT OBJECTIVES, EXPERIENCE, AND ACCOUNT SIZE BEFORE OPENING A DISCRETIONARY ACCOUNT AND
DOCUMENTED ITS RATIONALE, ORDER TICKETS NOTED WHETHER DISCRETION WAS EXERCISED, DISCRETIONARY ACCOUNTS WERE REVIEWED SEMI-
ANNUALLY TO ENSURE RECOMMENDATIONS WERE SUITABLE AND ACCOUNTS WERE NOT UNDULY CONCENTRATED, AND PRINCIPALS OF THE FIRM
SPOKE WITH EACH DISCRETIONARY ACCOUNT CLIENT ANNUALLY TO DETERMINE LEVELS OF SATISFACTION AND DOCUMENTED THE CONVERSATIONS.
THE PROCEDURES ALSO ASSIGNED TO THE CCO RESPONSIBILITY FOR ENSURING THAT THE FIRM CONDUCTED AN ANNUAL REVIEW OF SENIOR
ACCOUNTS. HOWEVER, THE FIRM DID NOT DOCUMENT ITS RATIONALE FOR OPENING DISCRETIONARY ACCOUNTS, ORDER TICKETS FAILED TO NOTE
WHETHER DISCRETION WAS EXERCISED, FIRM PRINCIPALS DID NOT SPEAK WITH DISCRETIONARY ACCOUNT CLIENTS, AND NOBODY CONDUCTED THE
REVIEWS OF DISCRETIONARY AND SENIOR ACCOUNTS.
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):
03/29/2021
 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: 
THE FIRM WAS CENSURED AND ORDERED TO PAY PARTIAL RESTITUTION TO CUSTOMERS OF $275,000. FINRA IMPOSED PARTIAL RESTITUTION
AND NO FINE AFTER CONSIDERING, AMONG OTHER THINGS, THE FIRM'S FINANCIAL RESOURCES.
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).
ALL REQUIREMENTS IMPOSED BY THE ABOVE ACTION HAVE BEEN COMPLETED.

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:
4209072
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CARLSON, RYAN SHANE
(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:
Restitution
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/29/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018060267902
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
AMERICAN INDEPENDENT SECURITIES GROUP, LLC
6.
Principal Product Type:
Debt - Asset Backed
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, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH
APPLICABLE RULES RELATING TO SALES OF COLLATERALIZED MORTGAGE OBLIGATIONS (CMOS). THE FINDINGS STATED THAT THE FIRM DID NOT
ESTABLISH ANY PROCEDURES RELATED TO CMO TRANSACTIONS OR THE SUITABILITY OF CMO RECOMMENDATIONS. THERE WAS NO REASONABLE
PROCESS TO EVALUATE AND DETERMINE WHETHER INVERSE FLOATERS (IFS) WERE APPROPRIATE FOR A GIVEN CUSTOMER OR TO ASSESS THE SIZE OF
THE CMO INVESTMENT. THERE WAS ALSO NO GUIDANCE ADDRESSING TO WHOM CMOS COULD BE OFFERED, THE EXTENT TO WHICH A CUSTOMER'S
ACCOUNT COULD BE CONCENTRATED IN IFS OR OTHER CMOS, OR THE PERCENTAGE OF A CUSTOMER'S NET WORTH THAT COULD BE INVESTED IN
CMOS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE A REGISTERED REPRESENTATIVE. THE FIRM'S CHIEF
COMPLIANCE OFFICER (CCO) DELEGATED TO A FIRM PRINCIPAL THE RESPONSIBILITY OF SUPERVISING THE REPRESENTATIVE. ALTHOUGH THE FIRM
DID NOT HAVE ANY WSPS ADDRESSING CMO TRANSACTIONS, THE PRINCIPAL IGNORED MULTIPLE RED FLAGS THAT SHOULD HAVE ALERTED HIM THAT
THE REPRESENTATIVE'S IF RECOMMENDATIONS WERE POTENTIALLY UNSUITABLE. IN PARTICULAR, IFS WERE RISKY AND ILLIQUID PRODUCTS THAT
WERE INCONSISTENT WITH THE CUSTOMERS' INVESTMENT OBJECTIVES AND RISK TOLERANCES, THE REPRESENTATIVE'S CUSTOMER ACCOUNTS WERE
ENTIRELY CONCENTRATED IN IFS, TRANSACTIONS WERE FLAGGED IN THE FIRM'S TRADE REVIEW SYSTEM, A MAJORITY OF THE CUSTOMERS WERE
SENIORS, MANY ACCOUNT HOLDERS HAD LIMITED INCOME AND NET WORTH, AND THE CUSTOMERS PURCHASED THE SAME CMOS AT THE SAME TIME.
THE PRINCIPAL SHOULD HAVE FOLLOWED UP ON THESE RED FLAGS BUT FAILED TO TAKE REASONABLE ACTION. THE FINDINGS ALSO INCLUDED THAT
THE FIRM FAILED TO TAKE REASONABLE ACTION TO ENSURE THE PRINCIPAL PROPERLY EXECUTED DELEGATED RESPONSIBILITIES AND FAILED TO
RESPOND TO RED FLAGS. THE CCO DELEGATED TO THE PRINCIPAL THE RESPONSIBILITY FOR SUPERVISING THE REGISTERED REPRESENTATIVE AND
THEREFORE WAS RESPONSIBLE FOR ENSURING THE PRINCIPAL PROPERLY EXECUTED THAT RESPONSIBILITY. THE CCO SHOULD HAVE BEEN
CONCERNED ABOUT THE REPRESENTATIVE'S RECOMMENDATIONS AND THE PRINCIPAL'S SUPERVISION OF THEM AND SHOULD HAVE ACTED ON THOSE
CONCERNS. THE CCO WAS AWARE OF THE RED FLAGS AND KNEW THAT THE PRINCIPAL SUPERVISED THE REPRESENTATIVE'S ACTIVITY EVEN THOUGH
HE HAD NO SPECIALIZED TRAINING RELATING TO CMOS AND IFS AND NO PRIOR EXPERIENCE SUPERVISING SALES OF THE PRODUCT. THE CCO ALSO
WAS AWARE THAT THE REPRESENTATIVE'S TRANSACTIONS SET OFF ALERTS IN THE FIRM'S TRADE REVIEW SYSTEM. NONETHELESS, THE CCO DID NOT
FOLLOW UP ON THESE RED FLAGS AND TOOK NO ACTION TO ADDRESS THE SUITABILITY ISSUES OR ENSURE THAT THE SUPERVISORY
RESPONSIBILITIES HE HAD DELEGATED WERE REASONABLY EXERCISED. FINRA FOUND THAT THE FIRM FAILED TO REASONABLY SUPERVISE
DISCRETIONARY AND SENIOR ACCOUNTS. THE FIRM PROCEDURES ASSIGNED TO THE CCO RESPONSIBILITY FOR ENSURING THAT THE FIRM
CONSIDERED AN INDIVIDUAL'S INVESTMENT OBJECTIVES, EXPERIENCE, AND ACCOUNT SIZE BEFORE OPENING A DISCRETIONARY ACCOUNT AND
DOCUMENTED ITS RATIONALE, ORDER TICKETS NOTED WHETHER DISCRETION WAS EXERCISED, DISCRETIONARY ACCOUNTS WERE REVIEWED SEMI-
ANNUALLY TO ENSURE RECOMMENDATIONS WERE SUITABLE AND ACCOUNTS WERE NOT UNDULY CONCENTRATED, AND PRINCIPALS OF THE FIRM
SPOKE WITH EACH DISCRETIONARY ACCOUNT CLIENT ANNUALLY TO DETERMINE LEVELS OF SATISFACTION AND DOCUMENTED THE CONVERSATIONS.
THE PROCEDURES ALSO ASSIGNED TO THE CCO RESPONSIBILITY FOR ENSURING THAT THE FIRM CONDUCTED AN ANNUAL REVIEW OF SENIOR
ACCOUNTS. HOWEVER, THE FIRM DID NOT DOCUMENT ITS RATIONALE FOR OPENING DISCRETIONARY ACCOUNTS, ORDER TICKETS FAILED TO NOTE
WHETHER DISCRETION WAS EXERCISED, FIRM PRINCIPALS DID NOT SPEAK WITH DISCRETIONARY ACCOUNT CLIENTS, AND NOBODY CONDUCTED THE
REVIEWS OF DISCRETIONARY AND SENIOR ACCOUNTS.
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):
03/29/2021
 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: 
THE FIRM WAS CENSURED AND ORDERED TO PAY PARTIAL RESTITUTION TO CUSTOMERS OF $275,000. FINRA IMPOSED PARTIAL RESTITUTION
AND NO FINE AFTER CONSIDERING, AMONG OTHER THINGS, THE FIRM'S FINANCIAL RESOURCES.
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).