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 Ejf Capital LP
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 Ejf Capital LP.
Reported ownership and control details
Form ADV · Filing date 2026-09-04 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | EMANUEL JOSHUA FRIEDMANCO-CHIEF EXECUTIVE OFFICERIndividual | EJF CAPITAL LP | 50% to less than 75%Code D | Yes | CO-CHIEF EXECUTIVE OFFICER09/2019 | Schedule APDF page 170 |
| 2 | NEAL JAMES WILSONCO-CHIEF EXECUTIVE OFFICER/ CHIEF FINANCIAL OFFICERIndividual | EJF CAPITAL LP | 10% to less than 25%Code B | Yes | CO-CHIEF EXECUTIVE OFFICER/ CHIEF FINANCIAL OFFICER09/2019 | Schedule APDF page 170 |
| 3 | KUDU INVESTMENT HOLDINGS, LLCMEMBER CLASS I INTERESTSDomestic entity | EJF CAPITAL LP | Less than 5%Code NA | No | MEMBER CLASS I INTERESTS08/2019 | Schedule APDF page 170 |
| 4 | ALEXANDRA CECILIA LAFRANKIECHIEF COMPLIANCE OFFICERIndividual | EJF CAPITAL LP | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER03/2025 | Schedule APDF page 170 |
| 5 | THOMAS MICHAEL DAVISONGENERAL COUNSELIndividual | EJF CAPITAL LP | Less than 5%Code NA | Yes | GENERAL COUNSEL03/2022 | Schedule APDF page 170 |
| 6 | EJF CAPITAL GP LLCLEGAL OWNERSHIP ENTITYDomestic entity | EJF CAPITAL LP | Less than 5%Code NA | No | LEGAL OWNERSHIP ENTITY01/2026 | Schedule APDF page 170 |
| 7 | JASON MICHAEL RUGGIEROMEMBER, GENERAL PARTNERSHIPIndividual | EJF CAPITAL LP | Less than 5%Code NA | Yes | MEMBER, GENERAL PARTNERSHIP01/2026 | Schedule APDF page 170 |
| 8 | WHITE MOUNTAINS CAPITAL, INC.OWNER (KUDU INVESTMENT MANAGEMENT, LLC)Domestic entity | KUDU INVESTMENT HOLDINGS, LLC | 75% or moreCode E | Yes | OWNER (KUDU INVESTMENT MANAGEMENT, LLC)02/2018 | Schedule BPDF page 171 |
| 9 | MASSACHUSETTS MUTUAL LIFE INSURANCE COMPANYPARTIAL OWNER OF KUDU INVESTMENT MANAGEMENT LLCDomestic entity | KUDU INVESTMENT HOLDINGS, LLC | 25% to less than 50%Code C | No | PARTIAL OWNER OF KUDU INVESTMENT MANAGEMENT LLC05/2022 | Schedule BPDF page 171 |
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 9/4/2026 4:58:53 PM
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 actions1 Yes4 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?No
- 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?No
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 proceedings2 Yes2 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?Yes
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?Yes
- 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 3 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 1FRIEDMAN, EMANUEL, JOSHUAPDF pages 183–185
- Advisory affiliate name — filed text
- FRIEDMAN, EMANUEL, JOSHUA
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
ON NOVEMBER 17, 2006, FRIEDMAN SUBMITTED AN OFFER OF SETTLEMENT TO THE SEC, WHICH WAS ACCEPTED BY THE SEC ON DECEMBER 19, 2006. IN THE OFFER OF SETTLEMENT, SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR IN WHICH THE COMMISSION IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, EXCEPT AS TO THE ENTRY OF THE FINAL JUDGMENT, FRIEDMAN ADMITTED TO THE JURISDICTION OF THE COMMISSION AND CONSENTED TO THE ENTRY OF AN ORDER BY THE COMMISSION CONTAINING THE FINDINGS DESCRIBED IN ITEM 7, ABOVE. FRIEDMAN ALSO CONSENTED TO THE IMPOSITION OF THE BAR DESCRIBED IN ITEM 12, ABOVE.
Other filed details
Description of allegations — filed text
PURSUANT TO FRIEDMAN'S CONSENT, THE SEC ORDER FINDS THAT HE WAS A REGISTERED REPRESENTATIVE OF REGISTERED BROKER-DEALER FBR AND EITHER CHAIRMAN OR CO-CHAIRMAN AND EITHER THE CEO OR CO-CEO OF THAT FIRM DURING HIS ENTIRE TENURE THERE. THE ORDER FURTHER FINDS THAT A FINAL JUDGMENT WAS ENTERED BY CONSENT AGAINST FRIEDMAN ENJOINING HIM FROM VIOLATING SECURITIES ACT SECTION 5 AND, AS A CONTROLLING PERSON PURSUANT TO EXCHANGE ACT SECTION 20(A), FROM VIOLATING EXCHANGE ACT SECTIONS 10(B) AND 15(F) AND RULE 10B-5 IN THE CIVIL ACTION SEC V. FRIEDMAN, BILLLINGS, RAMSEY & CO., INC., ET AL., CIVIL ACTION NO. 06-CV-02160 (D.D.C.). THE ORDER ALSO FINDS THAT: THE SEC'S COMPLAINT ALLEGED THAT IN SEPTEMBER/OCTOBER 2001, FRIEDMAN, WITH OTHERS, DIRECTED OR CONTROLLED THE DAY-TO-DAY MANAGEMENT OF FBR; IN CONNECTION WITH A PIPE OFFERING BY COMPUDYNE CORP., FBR FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL, NON-PUBLIC INFORMATION, AND IT IMPROPERLY TRADED COMPUDYNE STOCK IN ITS MARKET-MAKING ACCOUNT WHILE AWARE OF MATERIAL, NON-PUBLIC INFORMATION CONCERNING THE PIPE OFFERING; FRIEDMAN, AS A CONTROLLING PERSON, IS LIABLE FOR THE FOREGOING FBR CONDUCT; AND FRIEDMAN ENGAGED IN UNREGISTERED SALES OF COMPUDYNE SECURITIES.
Sanction detail — filed text
FRIEDMAN WAS BARRED FROM ASSOCIATING IN A SUPERVISORY CAPACITY WITH ANY BROKER OR DEALER, WITH THE RIGHT TO REAPPLY FOR SUCH ASSOCIATION AFTER TWO YEARS TO THE APPROPRIATE SELF REGULATORY ORGANIZATION, OR IF THERE IS NONE, TO THE COMMISSION. SUCH RIGHT TO REAPPLY BECAME AVAILABLE TO FRIEDMAN ON JANUARY 12, 2009.
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: 214565 This advisory affiliate is a Firm an Individual Registered: Yes No Name: FRIEDMAN, EMANUEL, JOSHUA (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: Bar Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/12/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ADMIN PROCEEDING FILE NO. [33-8761] 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): FRIEDMAN, BILLINGS, RAMSEY & CO., INC. 6. Principal Product Type: Equity - OTC Other Product Types: PRIVATE INVESTMENT IN PUBLIC EQUITY OFFERING OF COMMON STOCK 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): PURSUANT TO FRIEDMAN'S CONSENT, THE SEC ORDER FINDS THAT HE WAS A REGISTERED REPRESENTATIVE OF REGISTERED BROKER-DEALER FBR AND EITHER CHAIRMAN OR CO-CHAIRMAN AND EITHER THE CEO OR CO-CEO OF THAT FIRM DURING HIS ENTIRE TENURE THERE. THE ORDER FURTHER FINDS THAT A FINAL JUDGMENT WAS ENTERED BY CONSENT AGAINST FRIEDMAN ENJOINING HIM FROM VIOLATING SECURITIES ACT SECTION 5 AND, AS A CONTROLLING PERSON PURSUANT TO EXCHANGE ACT SECTION 20(A), FROM VIOLATING EXCHANGE ACT SECTIONS 10(B) AND 15(F) AND RULE 10B-5 IN THE CIVIL ACTION SEC V. FRIEDMAN, BILLLINGS, RAMSEY & CO., INC., ET AL., CIVIL ACTION NO. 06-CV-02160 (D.D.C.). THE ORDER ALSO FINDS THAT: THE SEC'S COMPLAINT ALLEGED THAT IN SEPTEMBER/OCTOBER 2001, FRIEDMAN, WITH OTHERS, DIRECTED OR CONTROLLED THE DAY-TO-DAY MANAGEMENT OF FBR; IN CONNECTION WITH A PIPE OFFERING BY COMPUDYNE CORP., FBR FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE MISUSE OF MATERIAL, NON-PUBLIC INFORMATION, AND IT IMPROPERLY TRADED COMPUDYNE STOCK IN ITS MARKET-MAKING ACCOUNT WHILE AWARE OF MATERIAL, NON-PUBLIC INFORMATION CONCERNING THE PIPE OFFERING; FRIEDMAN, AS A CONTROLLING PERSON, IS LIABLE FOR THE FOREGOING FBR CONDUCT; AND FRIEDMAN ENGAGED IN UNREGISTERED SALES OF COMPUDYNE SECURITIES. 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): 01/12/2007 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: OTHER SANCTIONS HAVE BEEN IMPOSED IN RELATED NASD AND SEC FILED CIVIL INJUNCTIVE PROCEEDINGS, EACH OF WHICH IS DESCRIBED IN A SEPARATE DISCLOSURE REPORTING PAGE. 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: FRIEDMAN WAS BARRED FROM ASSOCIATING IN A SUPERVISORY CAPACITY WITH ANY BROKER OR DEALER, WITH THE RIGHT TO REAPPLY FOR SUCH ASSOCIATION AFTER TWO YEARS TO THE APPROPRIATE SELF REGULATORY ORGANIZATION, OR IF THERE IS NONE, TO THE COMMISSION. SUCH RIGHT TO REAPPLY BECAME AVAILABLE TO FRIEDMAN ON JANUARY 12, 2009. 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 NOVEMBER 17, 2006, FRIEDMAN SUBMITTED AN OFFER OF SETTLEMENT TO THE SEC, WHICH WAS ACCEPTED BY THE SEC ON DECEMBER 19, 2006. IN THE OFFER OF SETTLEMENT, SOLELY FOR THE PURPOSE OF THE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR IN WHICH THE COMMISSION IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE ORDER, EXCEPT AS TO THE ENTRY OF THE FINAL JUDGMENT, FRIEDMAN ADMITTED TO THE JURISDICTION OF THE COMMISSION AND CONSENTED TO THE ENTRY OF AN ORDER BY THE COMMISSION CONTAINING THE FINDINGS DESCRIBED IN ITEM 7, ABOVE. FRIEDMAN ALSO CONSENTED TO THE IMPOSITION OF THE BAR DESCRIBED IN ITEM 12, ABOVE.
regulatory · block 2FRIEDMAN, EMANUEL, JOSHUAPDF pages 185–187
- Advisory affiliate name — filed text
- FRIEDMAN, EMANUEL, JOSHUA
- Regulator name — filed text
- NATIONAL ASSOCATION OF SECURITES DEALERS
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON DECEMBER 14, 2006, FRIEDMAN SUBMITTED THE EXECUTED AWC TO COUNSEL IN NASD'S MARKET REGULATION DEPARTMENT, WHICH WAS ACCEPTED BY NASD ON DECEMBER 19, 2006. IN THE AWC, SOLELY FOR THE PURPOSE OF THE PROCEEDING AND ANY OTHER PROCEEDING BROUGHT BY OR ON BEHALF OF NASD OR TO WHICH NASD IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE AWC, FRIEDMAN CONSENTED TO THE FINDINGS DESCRIBED IN ITEM 7, ABOVE. AS A RESULT OF THE FINDINGS, FRIEDMAN CONSENTED TO THE IMPOSITION OF THE SANCTIONS DESCRIBED IN ITEM 12, ABOVE.
Other filed details
Description of allegations — filed text
MR. FRIEDMAN ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, TO THE ENTRY OF FINDINGS BY THE NATIONAL ASSOCIATION OF SECURITIES DEALERS ("NASD") THAT MR. FRIEDMAN, WHILE HE WAS SERVING AS CO-CHAIRMAN AND CO-CHIEF EXECUTIVE OFFICER OF FRIEDMAN, BILLINGS, RAMSEY & CO. INC., ("FBR"), VIOLATED NASD RULE 2110 AND IS LIABLE AS A CONTROLLING PERSON, PURSUANT TO SECTION 20(A) OF THE SECURITIES EXCHANGE ACT OF 1934, FOR VIOLATIONS BY FBR IN 2001 OF EXCHANGE ACT SECTIONS 10(B) AND 15(F) AND RULE 10B-5 THEREUNDER.
Sanction detail — filed text
FRIEDMAN WAS SUSPENDED FROM ASSOCIATING WITH ANY NASD MEMBER IN A SUPERVISORY CAPACITY FOR TWO YEARS. FRIEDMAN WAS FINED $500,000, WHICH WAS PAYABLE TO NASD, AND HE WAS REQUIRED TO PAY A CIVIL PENALTY OF $754,046 IN ACCORDANCE WITH THE TERMS OF THE FINAL JUDGMENT ENTERED IN SEC V. FRIEDMAN, BILLINGS, RAMSEY & CO., INC., ET AL. THE FINE WAS PAID ON DECEMBER 29, 2006, AND THE CIVIL PENALTY ON JANUARY 4, 2007.
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:
214565
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
FRIEDMAN, EMANUEL, JOSHUA
(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)
NATIONAL ASSOCATION OF SECURITES DEALERS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
SUSPENSION OF ASSOCIATION WITH ANY NASD MEMBER IN A SUPERVISORY CAPACITY FOR TWO YEARS.
3.
Date Initiated (MM/DD/YYYY):
12/19/2006
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050002450-04AWC
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
FRIEDMAN, BILLINGS, RAMSEY & CO., INC.
6.
Principal Product Type:
Equity - OTC
Other Product Types:
PRIVATE INVESTMENT IN PUBLIC EQUITY OFFERING OF COMMON STOCK
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MR. FRIEDMAN ACCEPTED AND CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS, TO THE ENTRY OF FINDINGS BY THE NATIONAL
ASSOCIATION OF SECURITIES DEALERS ("NASD") THAT MR. FRIEDMAN, WHILE HE WAS SERVING AS CO-CHAIRMAN AND CO-CHIEF EXECUTIVE OFFICER
OF FRIEDMAN, BILLINGS, RAMSEY & CO. INC., ("FBR"), VIOLATED NASD RULE 2110 AND IS LIABLE AS A CONTROLLING PERSON, PURSUANT TO SECTION
20(A) OF THE SECURITIES EXCHANGE ACT OF 1934, FOR VIOLATIONS BY FBR IN 2001 OF EXCHANGE ACT SECTIONS 10(B) AND 15(F) AND RULE 10B-5
THEREUNDER.
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):
12/19/2006
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: $ 500,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
IN ADDITION TO THE $500,000 FINE PAYABLE TO THE NASD, MR. FRIEDMAN AGREED TO PAY A CIVIL MONETARY PENALTY OF $754,046 IN
ACCORDANCE WITH THE TERMS OF A FINAL JUDGMENT ISSUED IN A SEPARATE SEC INJUNCTIVE ACTION (CIVIL ACTION NO. 06-CV-02160
(D.D.C.)). ADDITIONAL SANCTIONS WERE IMPOSED IN THAT SEC INJUNCTIVE ACTION, AS WELL AS IN A RELATED SEC ADMINISTRATIVE
PROCEEDING. EACH OF THESE SEC ENFORCEMENT PROCEEDINGS IS DESCRIBED ON SEPARATE DISCLOSURE REPORTING PAGES.
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:
FRIEDMAN WAS SUSPENDED FROM ASSOCIATING WITH ANY NASD MEMBER IN A SUPERVISORY CAPACITY FOR TWO YEARS. FRIEDMAN WAS FINED
$500,000, WHICH WAS PAYABLE TO NASD, AND HE WAS REQUIRED TO PAY A CIVIL PENALTY OF $754,046 IN ACCORDANCE WITH THE TERMS OF
THE FINAL JUDGMENT ENTERED IN SEC V. FRIEDMAN, BILLINGS, RAMSEY & CO., INC., ET AL. THE FINE WAS PAID ON DECEMBER 29, 2006, AND
THE CIVIL PENALTY ON JANUARY 4, 2007.
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 DECEMBER 14, 2006, FRIEDMAN SUBMITTED THE EXECUTED AWC TO COUNSEL IN NASD'S MARKET REGULATION DEPARTMENT, WHICH WAS
ACCEPTED BY NASD ON DECEMBER 19, 2006. IN THE AWC, SOLELY FOR THE PURPOSE OF THE PROCEEDING AND ANY OTHER PROCEEDING BROUGHT
BY OR ON BEHALF OF NASD OR TO WHICH NASD IS A PARTY AND WITHOUT ADMITTING OR DENYING THE FINDINGS CONTAINED IN THE AWC, FRIEDMAN
CONSENTED TO THE FINDINGS DESCRIBED IN ITEM 7, ABOVE. AS A RESULT OF THE FINDINGS, FRIEDMAN CONSENTED TO THE IMPOSITION OF THE
SANCTIONS DESCRIBED IN ITEM 12, ABOVE.civil judicial · block 1PDF pages 187–189
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 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
CRD
Number:
214565
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
FRIEDMAN, EMANUEL, JOSHUA
(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.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:
Injunction
Other Relief Sought:
ISSUE A JUDGMENT REQUIRING FRIEDMAN TO PAY CIVIL PENALTIES OF $754,046.
3.
Filing Date of Court Action (MM/DD/YYYY):
12/20/2006
Exact
Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Equity - OTC
Other Product Types:
PRIVATE INVESTMENT IN PUBLIC EQUITY OFFERING OF COMMON STOCK
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):
SECURITIES AND EXCHANGE COMMISSION V. FRIEDMAN, BILLINGS, RAMSEY & CO., EMANUEL J. FRIEDMAN, AND NICHOLAS J. NICHOLS, CIVIL ACTION
NO. 06-CV-02160 (D.D.C.)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
FRIEDMAN, BILLINGS, RAMSEY & CO., INC.
7.
Describe the allegations related to this civil action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ALLEGED IN ITS COMPLAINT THAT MR. FRIEDMAN, WHILE HE WAS SERVING AS CO-CHAIRMAN
AND CO-CHIEF EXECUTIVE OFFICER OF FRIEDMAN, BILLINGS, RAMSEY & CO., INC. ("FBR"), MADE UNREGISTERED SALES OF SECURITIES IN 2001 IN
VIOLATION OF SECTION 5 OF THE SECURITIES ACT OF 1933 AND IS LIABLE AS A CONTROLLING PERSON, PURSUANT TO SECTION 20(A) OF THE
SECURITIES EXCHANGE ACT OF 1934, FOR VIOLATIONS BY FBR IN 2001 OF EXCHANGE ACT SECTIONS 10(B) AND 15(F) AND RULE 10B-5 THEREUNDER.
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:
Consent
12. Resolution Date (MM/DD/YYYY):
12/22/2006
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: $ 754,046.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
OTHER SANCTIONS HAVE BEEN IMPOSED IN RELATED SEC ADMINISTRATIVE AND NASD PROCEEDINGS, EACH OF WHICH IS DESCRIBED ON A
SEPARATE DISCLOSURE REPORTING PAGE.
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:
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS IN THE COMPLAINT, MR. FRIEDMAN CONSENTED TO THE ENTRY OF A FINAL JUDGMENT (I)
PERMANENTLY ENJOINING HIM FROM VIOLATING SECTION 5 OF THE SECURITIES ACT AND, AS A CONTROLLING PERSON, FROM VIOLATING
SECTIONS 10(B) AND 15(F) OF THE EXCHANGE ACT AND RULE 10B-5 THEREUNDER AND (II) ORDERING HIM TO PAY CIVIL MONEY PENALTIES OF
$754,046 BY CHECK, WHICH WAS DELIVERED TO THE COMMISSION'S OFFICE OF FINANCIAL MANAGEMENT ON JANUARY 4, 2007.
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).
AFTER AN INVESTIGATION CONDUCTED BY THE ENFORCEMENT STAFF OF THE SEC AND AFTER SETTLEMENT NEGOTIATIONS WITH THE STAFF, FRIEDMAN
SUBMITTED TO THE COMMISSION A SIGNED CONSENT OF DEFENDANT EMANUEL J. FRIEDMAN ON DECEMBER 14, 2006, WHICH CONSENTED TO THE
ENTRY OF THE FINAL JUDGMENT DESCRIBED ABOVE. THE COMMISSION APPROVED THE PROPOSED SETTLEMENT ON DECEMBER 19, 2006, AND THE
COMPLAINT AND PROPOSED FINAL JUDGMENT WERE FILED WITH THE COURT ON DECEMBER 20, 2006. THE COURT SIGNED AND ENTERED THE FINAL
JUDGMENT ON DECEMBER 22, 2006.* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.