The Eideard 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
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) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE AND CIVIL MONEY PENALTY.
3.
Date Initiated (MM/DD/YYYY): 
09/05/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-21608
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE FUNDS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT THE EIDEARD GROUP FAILED TO MAINTAIN SECURITIES OF CERTAIN PRIVATE FUNDS THAT IT ADVISED WITH A QUALIFIED
CUSTODIAN AND FAILED TO CONDUCT AND TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH
GENERALLY ACCEPTED ACCOUNTING PRINCIPLES ("GAAP") TO INVESTORS IN CERTAIN PRIVATE FUNDS ADVISED BY THE FIRM.
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:
Decision & Order of Offer of Settlement
11. Resolution Date (MM/DD/YYYY):
09/05/2023
 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: $ 80,000.00
 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: 
EIDEARD WAS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 THEREUNDER, AND ORDERED TO PAY AN $80,000 FINE. THE FINE IS TO BE PAID IN
INSTALLMENTS WITH THE FINAL PAYMENT DUE 359 DAYS FOLLOWING ENTRY OF THE ORDER (OR 8/30/2024). A COPY OF THE ORDER
(ADMINISTRATIVE PROCEEDING FILE NO. 3-21608) CAN BE FOUND ON THE SEC'S WEBSITE
(HTTPS://WWW.SEC.GOV/FILES/LITIGATION/ADMIN/2023/IA-6399.PDF).
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).
IN SEPTEMBER 2023, THE SEC ACCEPTED AN OFFER SUBMITTED BY EIDEARD TO SETTLE AN ADMINISTRATIVE PROCEEDING RELATING TO ALLEGATIONS
OF COMPLIANCE VIOLATIONS CONCERNING CERTAIN PRIVATE FUNDS ADVISED BY THE FIRM. WITHOUT ADMITTING OR DENYING THE ALLEGATIONS,
EIDEARD CONSENTED TO THE SEC'S ENTRY OF AN ADMINISTRATIVE ORDER ("ORDER"). ACCORDING TO THE ORDER, EIDEARD FAILED TO MAINTAIN
SECURITIES OF CERTAIN PRIVATE FUNDS THAT IT ADVISED WITH A QUALIFIED CUSTODIAN. THE ORDER ALSO FOUND THAT EIDEARD FAILED TO
CONDUCT AND TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING
PRINCIPLES ("GAAP") TO INVESTORS IN CERTAIN PRIVATE FUNDS ADVISED BY THE FIRM. ACCORDING TO THE ORDER, THESE FAILURES RESULTED IN
VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 THEREUNDER, COMMONLY REFERRED TO AS THE "CUSTODY RULE."
PURSUANT TO THE ORDER, EIDEARD WAS CENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY
FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 THEREUNDER, AND ORDERED TO PAY AN $80,000 FINE. A COPY OF
THE ORDER (ADMINISTRATIVE PROCEEDING FILE NO. 3-21608) CAN BE FOUND ON THE SEC'S WEBSITE
(HTTPS://WWW.SEC.GOV/FILES/LITIGATION/ADMIN/2023/IA-6399.PDF).

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ROBERTS ASSET MANAGEMENT,
LLC.
(For individuals, Last, First,
Middle)
CRD
Number:
139834
This advisory affiliate is 
a Firm
an Individual

Registered:
Yes
No
Name:
THE EIDEARD GROUP, LLC
(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.) 
BDP HOLDINGS LLC
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
07/28/2021
 Exact
 Explanation
If not exact, provide explanation:
INITIAL COMPLAINT MAY 19, 2021 1ST AMENDED COMPLAINT JULY 28, 2021
4.
Principal Product Type:
Other
Other Product Types: 
DIRECT PRIVATE INVESTMENT
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): 
STATE OF NEW HAMPSHIRE - SUPERIOR COURT (HILLSBOROUGH COUNTY) NORTHER DIRECT DOCKET NO. 216-2021-CV-00315
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
RONALD L. ROBERTS, ROBERTS ASSET MANAGEMENT, LLC. AND THE EIDEARD GROUP LLC.
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
MONETARY LOSS RELATED TO DIRECT PRIVATE INVESTMENT
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): 
JURY FOUND FOR PLAINTIFF AGAINST ALL 3 INDIVIDUALS IN ITEM 6. ABOVE ON 11/2/2023
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:
Judgment Rendered

12. Resolution Date (MM/DD/YYYY): 
08/01/2025
 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: $ 27,600,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
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:
SEE ABOVE
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). 
RONALD ROBERTS WAS THE MANAGING MEMBER WITH A NOMINAL .25% INTEREST IN BDP HOLDINGS, LLC. BDP WAS A PROPRIETARY FAMILY
INVESTMENT POOL FOR A LONG-TIME CLIENT FAMILY OF HIS. RONALD WAS GIVEN FULL DISCRETIONARY AUTHORITY BY THE FAMILY TO MANAGE THE
INVESTMENT POOL ON THEIR BEHALF. CIRCA 2011 HE BEGAN INVESTING IN AN EMERGING DIRECT PRIVATE EQUITY INVESTMENT KNOWN AS G-FORM,
LLC; A MANUFACTURER OF PROPRIETARY SPORTS PROTECTION FOR ALL MANNER OF SPORTS. OVER AN INVESTMENT TIMELINE CIRCA 2011-2019
RONALD BECAME A STOCKHOLDER, BOARD MEMBER AND ULTIMATELY CHAIRMAN OF G-FORM. THE COMPANY FINANCIAL STRUGGLED OVER THIS
TIMELINE INCLUDING THROUGH THE COVID PERIOD. THIS NECESSITATED SEVERAL RECAPS AND EMERGING DEBT TO REMAIN OPERATIONAL. AT DAY'S
END THE COMPANY WAS ACQUIRED BY ONE OF ITS EARLY INSTITUTIONAL CO-INVESTORS LEAVING THE FAMILY AT A MATERIAL LOSS ESTIMATED AT
SOME $30 MILLION. RONALD ROBERTS, HIS COMPANY ROBERTS ASSET MANAGEMENT, LLC (A 70% OWNER OF EIDEARD GROUP) AND THE EIDEARD
GROUP WERE FOUND LIABLE ON 11/2/23 BY JURY TRIAL FOR BDP'S LOSS ON (4) COUNTS: BREACH OF FIDUCIARY DUTY, NEGLIGENCE, BREACH OF
CONTRACT AND NEGLIGENT MISREPRESENTATION. (JOHN AUBIN AND KEVIN GABORIAULT, CPA WERE FULLY EXONERATED AND GEORGE LI, CFA WAS
EARLIER DISMISSED FROM THE CASE WITH PREJUDICE). ON ADVICE OF DEFENSE COUNSEL, ROBERTS IMMEDIATELY APPEALED THE VERDICT TO THE
NH SUPREME COURT CIRCA 1/2024 ON WHAT COUNSEL BELIEVED WERE (4) LOWER COURT ERRORS. THE COURT SCHEDULED THE CASE FOR HEARING
CIRCA JULY 2025 AND RENDERED ITS DECISION TO RE-AFFIRM THE LOWER COURT'S VERDICT ON 8/1/25 MAKING IT A FINAL JUDGMENT.