Triaxx Asset 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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Disgorgement
Other Sanctions: 
PERMANENT INJUNCTIONS ENJOINING THE FIRM FROM FUTURE VIOLATIONS OF THE SECURITIES LAWS THAT IT WAS ALLEGED TO HAVE VIOLATED.
3.
Date Initiated (MM/DD/YYYY): 
06/21/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
10-CV-4791
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
ICP ASSET MANAGEMENT, LLC
6.
Principal Product Type:
Other
Other Product Types: 
CDOS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IT WAS ALLEGED THAT THE FIRM VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933, AS AMENDED; SECTIONS 10(B) AND 15(C)(1)(A) OF THE
SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 10B-3 AND 10B-5 UNDER THE EXCHANGE ACT; SECTIONS 206(1),
(2), (3), AND (4) OF THE ADVISERS ACT; AND RULES 204-2, 206(4)-7 AND 206(4)-8 UNDER 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:
Settled
11. Resolution Date (MM/DD/YYYY):
09/06/2012
 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:
PERMANENT INJUNCTIONS ENJOINING THE FIRM FROM FUTURE VIOLATIONS OF THE SECURITIES LAWS THAT IT WAS ALLEGED TO HAVE
VIOLATED.
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: 
PERMANENT INJUNCTIONS ENJOINING THE FIRM FROM FUTURE VIOLATIONS OF THE SECURITIES LAWS THAT IT WAS ALLEGED TO HAVE
VIOLATED.
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 SEC ALLEGED THAT THE FIRM, AND CERTAIN AFFILIATES, VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933, AS AMENDED; SECTIONS
10(B) AND 15(C)(1)(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 10B-3 AND 10B-5 UNDER THE
EXCHANGE ACT; SECTIONS 206(1), (2), (3), AND (4) OF THE ADVISERS ACT; AND RULES 204-2, 206(4)-7 AND 206(4)-8 UNDER THE ADVISERS ACT. THE

( ) ( ) ( )
( )
( )
( )
BASIS OF THESE CLAIMS WAS THE SEC'S ALLEGATION THAT THE FIRM AND CERTAIN AFFILIATES ENGAGED IN FRAUDULENT PRACTICES AND
MISREPRESENTATIONS THAT CAUSED ITS STRUCTURED PRODUCT VEHICLES TO OVERPAY FOR CERTAIN SECURITIES AND SUFFER SUBSTANTIAL LOSSES
AS A RESULT. THE SEC FURTHER ALLEGED THAT THE FIRM AND CERTAIN AFFILIATES ALSO IMPROPERLY OBTAINED FEES AND UNDISCLOSED PROFITS AT
THE EXPENSE OF THE STRUCTURED PRODUCT VEHICLES AND THEIR INVESTORS.

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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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.H.
(1)(a), 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.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Relief Sought:
Other
Other Relief Sought: 
PERMANENT INJUNCTION FROM VIOLATION OF CERTAIN SECURITIES LAWS THAT THE FIRM WAS ALLEGED TO HAVE VIOLATED.

3.
Filing Date of Court Action (MM/DD/YYYY):
06/21/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
CDOS
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
US DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
IT WAS ALLEGED THAT THE FIRM VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933, AS AMENDED; SECTIONS 10(B) AND 15(C)(1)(A) OF THE
SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 10B-3 AND 10B-5 UNDER THE EXCHANGE ACT; SECTIONS 206(1),
(2), (3), AND (4) OF THE ADVISERS ACT; AND RULES 204-2, 206(4)-7 AND 206(4)-8 UNDER THE ADVISERS ACT.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
09/06/2012
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
PERMANENT INJUNCTIONS ENJOINING THE FIRM FROM FUTURE VIOLATIONS OF THE SECURITIES LAWS THAT IT WAS ALLEGED TO HAVE VIOLATED
C.
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:
PERMANENT INJUNCTIONS ENJOINING THE FIRM FROM FUTURE VIOLATIONS OF THE SECURITIES LAWS THAT IT WAS ALLEGED TO HAVE VIOLATED
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THE SEC ALLEGED THAT THE FIRM, AND CERTAIN AFFILIATES, VIOLATED SECTION 17(A) OF THE SECURITIES ACT OF 1933, AS AMENDED; SECTIONS
10(B) AND 15(C)(1)(A) OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED (THE "EXCHANGE ACT"); RULES 10B-3 AND 10B-5 UNDER THE
EXCHANGE ACT; SECTIONS 206(1), (2), (3), AND (4) OF THE ADVISERS ACT; AND RULES 204-2, 206(4)-7 AND 206(4)-8 UNDER THE ADVISERS ACT. THE
BASIS OF THESE CLAIMS WAS THE SEC'S ALLEGATION THAT THE FIRM AND CERTAIN AFFILIATES ENGAGED IN FRAUDULENT PRACTICES AND
MISREPRESENTATIONS THAT CAUSED ITS STRUCTURED PRODUCT VEHICLES TO OVERPAY FOR CERTAIN SECURITIES AND SUFFER SUBSTANTIAL LOSSES
AS A RESULT. THE SEC FURTHER ALLEGED THAT THE FIRM AND CERTAIN AFFILIATES ALSO IMPROPERLY OBTAINED FEES AND UNDISCLOSED PROFITS AT
THE EXPENSE OF THE STRUCTURED PRODUCT VEHICLES AND THEIR INVESTORS.