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 York Capital Management
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 York Capital Management.
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-03-27 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | JAMES GERARD DINANFOUNDERIndividual | YORK CAPITAL MANAGEMENT | 25% to less than 50%Code C | Yes | FOUNDER10/1991 | Schedule APDF page 130 |
| 2 | WILLIAM CHARLES VRATTOSMANAGING PARTNER & CHIEF INVESTMENT OFFICERIndividual | YORK CAPITAL MANAGEMENT | 5% to less than 10%Code A | Yes | MANAGING PARTNER & CHIEF INVESTMENT OFFICER06/2017 | Schedule APDF page 130 |
| 3 | JONATHAN ZALMAN JACOBSPORTFOLIO MANAGER, PARTNERIndividual | YORK CAPITAL MANAGEMENT | Less than 5%Code NA | Yes | PORTFOLIO MANAGER, PARTNER01/2009 | Schedule APDF page 130 |
| 4 | CREDIT SUISSE MANAGER HOLDINGS LIMITEDPASSIVE INVESTORDomestic entity | YORK CAPITAL MANAGEMENT | 25% to less than 50%Code C | No | PASSIVE INVESTOR01/2016 | Schedule APDF page 130 |
| 5 | BRIAN STEVEN TRAFICANTECHIEF OPERATING OFFICER & GENERAL COUNSELIndividual | YORK CAPITAL MANAGEMENT | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER & GENERAL COUNSEL07/2021 | Schedule APDF page 130 |
| 6 | DANIEL ALEXANDER SCHWARTZFORMER PARTNERIndividual | YORK CAPITAL MANAGEMENT | 10% to less than 25%Code B | No | FORMER PARTNER01/2019 | Schedule APDF page 130 |
| 7 | MICHAEL H. ZHANGCHIEF FINANCIAL OFFICERIndividual | YORK CAPITAL MANAGEMENT | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER01/2023 | Schedule APDF page 130 |
| 8 | Meghan Gillmore ForceCHIEF COMPLIANCE OFFICERIndividual | YORK CAPITAL MANAGEMENT | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER01/2024 | Schedule APDF page 130 |
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 3/27/2026 11:40:35 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 actions5 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?No
- 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 actions2 Yes3 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?Yes
- 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?Yes
- 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 actions4 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?No
- 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?No
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 2 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 199–201
- Regulator name — filed text
- SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY AND SWISS FEDERAL DEPARTMENT OF FINANCE
- Monetary/Fine Amount — filed text
- $ 11,050.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON DECEMBER 23, 2021, THE FIRM RECEIVED A LETTER FROM THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA"), NOTIFYING THE FIRM THAT FINMA WAS REVIEWING WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER THE FINANCIAL MARKET INFRASTRUCTURE ACT (THE "FMIA") WITH REGARD TO AN INVESTMENT MADE BY YORK DISTRESSED ASSET FUND IV ("YDAF IV") IN ULTIMA CAPITAL AG ("ULTIMA"). THE FIRM HAD TIMELY NOTIFIED ULTIMA AND BX SWISS AG OF THE ACQUISITION OF AN AGGREGATE 7.27% INTEREST IN ULTIMA AND THE ENTRY INTO A CALL AND PUT OPTION AGREEMENT WITH ULTIMA'S TWO CO-FOUNDERS PURSUANT TO WHICH SUCH CO- FOUNDERS WERE ENTITLED TO PURCHASE VOTING SHARES. THE CALL AND PUT OPTION AGREEMENT WAS TERMINATED ON OCTOBER 15, 2020, AND ULTIMA ISSUED A PRESS RELEASE NOTING THE TERMINATION OF THE AGREEMENT AND DISCLOSING THAT YORK MAINTAINED ITS 7.27% POSITION IN ULTIMA. THE FIRM DID NOT MAKE ITS OWN DISCLOSURE NOTIFICATION UNDER THE FMIA ACT WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AT THAT TIME. FINMA REFERRED THE MATTER TO THE SWISS FEDERAL DEPARTMENT OF FINANCE ("FDF") AS AN ADMINISTRATIVE CRIMINAL MATTER TO DETERMINE WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER THE FMIA. THE FDF ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AND IMPOSED A FINE OF CHF 10,000, WHICH WAS AT THE LOWER END OF THE APPLICABLE PENALTY RANGE, AND PROCEDURAL COSTS OF CHF 1,050. THE FDF DECISION WAS DATED FEBRUARY 2, 2023, AND BECAME EFFECTIVE ON MARCH 8, 2023, UPON THE FIRM'S DETERMINATION TO NOT APPEAL THE FDF DECISION. TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, YORK ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
Other filed details
Description of allegations — filed text
ON DECEMBER 23, 2021, THE FIRM RECEIVED A LETTER FROM THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA"), NOTIFYING THE FIRM THAT FINMA WAS REVIEWING WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER THE FINANCIAL MARKET INFRASTRUCTURE ACT (THE "FMIA") WITH REGARD TO AN INVESTMENT MADE BY YORK DISTRESSED ASSET FUND IV ("YDAF IV") IN ULTIMA CAPITAL AG ("ULTIMA"). THE FIRM HAD TIMELY NOTIFIED ULTIMA AND BX SWISS AG OF THE ACQUISITION OF AN AGGREGATE 7.27% INTEREST IN ULTIMA AND THE ENTRY INTO A CALL AND PUT OPTION AGREEMENT WITH ULTIMA'S TWO CO-FOUNDERS PURSUANT TO WHICH SUCH CO- FOUNDERS WERE ENTITLED TO PURCHASE VOTING SHARES. THE CALL AND PUT OPTION AGREEMENT WAS TERMINATED ON OCTOBER 15, 2020, AND ULTIMA ISSUED A PRESS RELEASE NOTING THE TERMINATION OF THE AGREEMENT AND DISCLOSING THAT YORK MAINTAINED ITS 7.27% POSITION IN ULTIMA. THE FIRM DID NOT MAKE ITS OWN DISCLOSURE NOTIFICATION UNDER THE FMIA ACT WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AT THAT TIME. FINMA REFERRED THE MATTER TO THE SWISS FEDERAL DEPARTMENT OF FINANCE ("FDF") AS AN ADMINISTRATIVE CRIMINAL MATTER TO DETERMINE WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER THE FMIA. THE FDF ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AND IMPOSED A FINE OF CHF 10,000, WHICH WAS AT THE LOWER END OF THE APPLICABLE PENALTY RANGE, AND PROCEDURAL COSTS OF CHF 1,050. THE FDF DECISION WAS DATED FEBRUARY 2, 2023, AND BECAME EFFECTIVE ON MARCH 8, 2023, UPON THE FIRM'S DETERMINATION TO NOT APPEAL THE FDF DECISION. TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, YORK ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
Sanction detail — filed text
WE ARE AWAITING AN INVOICE FOR THE FINE AND THE FIRM WILL PAY THE CHF 11,050 FINE PROMPTLY UPON RECEIPT. NO PORTION OF THE FINE WILL BE ALLOCATED TO YDAF IV.
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)
SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY AND SWISS FEDERAL DEPARTMENT OF FINANCE
2.
Principal Sanction:
Other
Other Sanctions:
FINE
3.
Date Initiated (MM/DD/YYYY):
12/23/2021
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:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DECEMBER 23, 2021, THE FIRM RECEIVED A LETTER FROM THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA"), NOTIFYING THE
FIRM THAT FINMA WAS REVIEWING WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER
THE FINANCIAL MARKET INFRASTRUCTURE ACT (THE "FMIA") WITH REGARD TO AN INVESTMENT MADE BY YORK DISTRESSED ASSET FUND IV ("YDAF IV")
IN ULTIMA CAPITAL AG ("ULTIMA"). THE FIRM HAD TIMELY NOTIFIED ULTIMA AND BX SWISS AG OF THE ACQUISITION OF AN AGGREGATE 7.27%
INTEREST IN ULTIMA AND THE ENTRY INTO A CALL AND PUT OPTION AGREEMENT WITH ULTIMA'S TWO CO-FOUNDERS PURSUANT TO WHICH SUCH CO-
FOUNDERS WERE ENTITLED TO PURCHASE VOTING SHARES. THE CALL AND PUT OPTION AGREEMENT WAS TERMINATED ON OCTOBER 15, 2020, AND
ULTIMA ISSUED A PRESS RELEASE NOTING THE TERMINATION OF THE AGREEMENT AND DISCLOSING THAT YORK MAINTAINED ITS 7.27% POSITION IN
ULTIMA. THE FIRM DID NOT MAKE ITS OWN DISCLOSURE NOTIFICATION UNDER THE FMIA ACT WITH REGARD TO THE TERMINATION OF THE CALL AND
PUT OPTION AGREEMENT AT THAT TIME. FINMA REFERRED THE MATTER TO THE SWISS FEDERAL DEPARTMENT OF FINANCE ("FDF") AS AN
ADMINISTRATIVE CRIMINAL MATTER TO DETERMINE WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE
OBLIGATIONS UNDER THE FMIA. THE FDF ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS
WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AND IMPOSED A FINE OF CHF 10,000, WHICH WAS AT THE LOWER
END OF THE APPLICABLE PENALTY RANGE, AND PROCEDURAL COSTS OF CHF 1,050. THE FDF DECISION WAS DATED FEBRUARY 2, 2023, AND BECAME
EFFECTIVE ON MARCH 8, 2023, UPON THE FIRM'S DETERMINATION TO NOT APPEAL THE FDF DECISION. TO AVOID THE DISTRACTION AND EXPENSE OF
LITIGATION, YORK ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
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:
Order
11. Resolution Date (MM/DD/YYYY):
03/08/2023
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: $ 11,050.00
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:
WE ARE AWAITING AN INVOICE FOR THE FINE AND THE FIRM WILL PAY THE CHF 11,050 FINE PROMPTLY UPON RECEIPT. NO PORTION OF THE
FINE WILL BE ALLOCATED TO YDAF IV.
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 23, 2021, THE FIRM RECEIVED A LETTER FROM THE SWISS FINANCIAL MARKET SUPERVISORY AUTHORITY ("FINMA"), NOTIFYING THE
FIRM THAT FINMA WAS REVIEWING WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE OBLIGATIONS UNDER
THE FINANCIAL MARKET INFRASTRUCTURE ACT (THE "FMIA") WITH REGARD TO AN INVESTMENT MADE BY YORK DISTRESSED ASSET FUND IV ("YDAF IV")
IN ULTIMA CAPITAL AG ("ULTIMA"). THE FIRM HAD TIMELY NOTIFIED ULTIMA AND BX SWISS AG OF THE ACQUISITION OF AN AGGREGATE 7.27%
INTEREST IN ULTIMA AND THE ENTRY INTO A CALL AND PUT OPTION AGREEMENT WITH ULTIMA'S TWO CO-FOUNDERS PURSUANT TO WHICH SUCH CO-
FOUNDERS WERE ENTITLED TO PURCHASE VOTING SHARES. THE CALL AND PUT OPTION AGREEMENT WAS TERMINATED ON OCTOBER 15, 2020, AND
ULTIMA ISSUED A PRESS RELEASE NOTING THE TERMINATION OF THE AGREEMENT AND DISCLOSING THAT YORK MAINTAINED ITS 7.27% POSITION IN
ULTIMA. THE FIRM DID NOT MAKE ITS OWN DISCLOSURE NOTIFICATION UNDER THE FMIA ACT WITH REGARD TO THE TERMINATION OF THE CALL AND
PUT OPTION AGREEMENT AT THAT TIME. FINMA REFERRED THE MATTER TO THE SWISS FEDERAL DEPARTMENT OF FINANCE ("FDF") AS AN
ADMINISTRATIVE CRIMINAL MATTER TO DETERMINE WHETHER THE FIRM OR ITS CONTROLLING PERSONS FAILED TO TIMELY MEET DISCLOSURE
OBLIGATIONS UNDER THE FMIA. THE FDF ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS
WITH REGARD TO THE TERMINATION OF THE CALL AND PUT OPTION AGREEMENT AND IMPOSED A FINE OF CHF 10,000, WHICH WAS AT THE LOWER
END OF THE APPLICABLE PENALTY RANGE, AND PROCEDURAL COSTS OF CHF 1,050. THE FDF DECISION WAS DATED FEBRUARY 2, 2023, AND BECAME
EFFECTIVE ON MARCH 8, 2023, UPON THE FIRM'S DETERMINATION TO NOT APPEAL THE FDF DECISION. TO AVOID THE DISTRACTION AND EXPENSE OF
LITIGATION, YORK ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.regulatory · block 2PDF pages 201–203
- Regulator name — filed text
- FINANCIAL SUPERVISORY AUTHORITY OF NORWAY (FINANSTILSYNET)
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
ON DECEMBER 10, 2025, THE FIRM RECEIVED A LETTER (THE "LETTER") FROM THE FINANCIAL AUTHORITY OF NORWAY (NW.: FINANSTILSYNET) (THE "NFSA"), NOTIFYING THE FIRM THAT NFSA WAS CONSIDERING IMPOSING A VIOLATION PENALTY OF NOK 100,000 ON THE FIRM WITH REGARD TO A TRADE MADE BY YORK TACTICAL ENERGY FUND, L.P. AND YORK TACTICAL ENERGY FUND AIV-AN, L.P. (COLLECTIVELY, THE "YTEF FUNDS") IN SHARES OF BLUENORD ASA ("BLUENORD"). THE YTEF FUNDS PARTICIPATED IN A TENDER OFFER CONDUCTED BY BLUENORD AND ULTIMATELY SOLD 250,556 SHARES PURSUANT TO THE TENDER OFFER. THE FIRM WAS UNCERTAIN AS TO BOTH THE NUMBER OF SHARES THAT WOULD BE ACCEPTED BY BLUENORD IN THE TENDER OFFER AND THE FINAL SETTLEMENT DATE. AS A RESULT OF THIS SALE, THE FIRM'S AGGREGATE HOLDINGS IN BLUENORD FELL BELOW 5% AND A NOTIFICATION FILING WAS REQUIRED PURSUANT TO THE NORWEGIAN SECURITIES ACT ("NSTA"). WHILE THE FIRM MADE ITS NOTIFICATION FILING IMMEDIATELY UPON ITS COMPLIANCE TEAM BEING NOTIFIED THAT THE TRADE WAS ACCEPTED AND HAD SETTLED, NFSA INDICATED IN THE LETTER THAT IT BELIEVED THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS UNDER THE NSTA AND, ACCORDINGLY, WAS CONSIDERING IMPOSING THE VIOLATION PENALTY. THE NFSA ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS WITH REGARD TO THE SHARES SOLD PURSUANT TO THE TENDER OFFER AND IMPOSED A FINE OF NOK 100,000, WHICH THE FIRM UNDERSTANDS IS A STANDARD FINE ISSUED IN SIMILAR CIRCUMSTANCES. THE NFSA DECISION WAS PUBLISHED FEBRUARY 19, 2026. THE FIRM HAD THREE WEEKS TO APPEAL THE DECISION, BUT, TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, THE FIRM HAS ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
Other filed details
Description of allegations — filed text
ON DECEMBER 10, 2025, THE FIRM RECEIVED A LETTER (THE "LETTER") FROM THE FINANCIAL AUTHORITY OF NORWAY (NW.: FINANSTILSYNET) (THE "NFSA"), NOTIFYING THE FIRM THAT NFSA WAS CONSIDERING IMPOSING A VIOLATION PENALTY OF NOK 100,000 ON THE FIRM WITH REGARD TO A TRADE MADE BY YORK TACTICAL ENERGY FUND, L.P. AND YORK TACTICAL ENERGY FUND AIV-AN, L.P. (COLLECTIVELY, THE "YTEF FUNDS") IN SHARES OF BLUENORD ASA ("BLUENORD"). THE YTEF FUNDS PARTICIPATED IN A TENDER OFFER CONDUCTED BY BLUENORD AND ULTIMATELY SOLD 250,556 SHARES PURSUANT TO THE TENDER OFFER. THE FIRM WAS UNCERTAIN AS TO BOTH THE NUMBER OF SHARES THAT WOULD BE ACCEPTED BY BLUENORD IN THE TENDER OFFER AND THE FINAL SETTLEMENT DATE. AS A RESULT OF THIS SALE, THE FIRM'S AGGREGATE HOLDINGS IN BLUENORD FELL BELOW 5% AND A NOTIFICATION FILING WAS REQUIRED PURSUANT TO THE NORWEGIAN SECURITIES ACT ("NSTA"). WHILE THE FIRM MADE ITS NOTIFICATION FILING IMMEDIATELY UPON ITS COMPLIANCE TEAM BEING NOTIFIED THAT THE TRADE WAS ACCEPTED AND HAD SETTLED, NFSA INDICATED IN THE LETTER THAT IT BELIEVED THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS UNDER THE NSTA AND, ACCORDINGLY, WAS CONSIDERING IMPOSING THE VIOLATION PENALTY. THE NFSA ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS WITH REGARD TO THE SHARES SOLD PURSUANT TO THE TENDER OFFER AND IMPOSED A FINE OF NOK 100,000, WHICH THE FIRM UNDERSTANDS IS A STANDARD FINE ISSUED IN SIMILAR CIRCUMSTANCES. THE NFSA DECISION WAS PUBLISHED FEBRUARY 19, 2026. THE FIRM HAD THREE WEEKS TO APPEAL THE DECISION, BUT, TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, THE FIRM HAS ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
Sanction detail — filed text
THE FINE IS FOR NOK 100,000. YORK PAID THE NOK 100,000 PROMPTLY UPON RECEIPT OF THE FINAL INVOICE FROM THE NFSA.
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)
(
y
)
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)
FINANCIAL SUPERVISORY AUTHORITY OF NORWAY (FINANSTILSYNET)
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
12/10/2025
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:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON DECEMBER 10, 2025, THE FIRM RECEIVED A LETTER (THE "LETTER") FROM THE FINANCIAL AUTHORITY OF NORWAY (NW.: FINANSTILSYNET) (THE
"NFSA"), NOTIFYING THE FIRM THAT NFSA WAS CONSIDERING IMPOSING A VIOLATION PENALTY OF NOK 100,000 ON THE FIRM WITH REGARD TO A
TRADE MADE BY YORK TACTICAL ENERGY FUND, L.P. AND YORK TACTICAL ENERGY FUND AIV-AN, L.P. (COLLECTIVELY, THE "YTEF FUNDS") IN SHARES OF
BLUENORD ASA ("BLUENORD"). THE YTEF FUNDS PARTICIPATED IN A TENDER OFFER CONDUCTED BY BLUENORD AND ULTIMATELY SOLD 250,556
SHARES PURSUANT TO THE TENDER OFFER. THE FIRM WAS UNCERTAIN AS TO BOTH THE NUMBER OF SHARES THAT WOULD BE ACCEPTED BY BLUENORD
IN THE TENDER OFFER AND THE FINAL SETTLEMENT DATE. AS A RESULT OF THIS SALE, THE FIRM'S AGGREGATE HOLDINGS IN BLUENORD FELL BELOW
5% AND A NOTIFICATION FILING WAS REQUIRED PURSUANT TO THE NORWEGIAN SECURITIES ACT ("NSTA"). WHILE THE FIRM MADE ITS NOTIFICATION
FILING IMMEDIATELY UPON ITS COMPLIANCE TEAM BEING NOTIFIED THAT THE TRADE WAS ACCEPTED AND HAD SETTLED, NFSA INDICATED IN THE
LETTER THAT IT BELIEVED THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS UNDER THE NSTA AND, ACCORDINGLY, WAS CONSIDERING
IMPOSING THE VIOLATION PENALTY. THE NFSA ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE
OBLIGATIONS WITH REGARD TO THE SHARES SOLD PURSUANT TO THE TENDER OFFER AND IMPOSED A FINE OF NOK 100,000, WHICH THE FIRM
UNDERSTANDS IS A STANDARD FINE ISSUED IN SIMILAR CIRCUMSTANCES. THE NFSA DECISION WAS PUBLISHED FEBRUARY 19, 2026. THE FIRM HAD
THREE WEEKS TO APPEAL THE DECISION, BUT, TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, THE FIRM HAS ELECTED TO ACCEPT THE
DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.
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
11. Resolution Date (MM/DD/YYYY):
03/04/2026
Exact
Explanation
If not exact, provide explanation:
THE NFSA DECISION WAS PUBLISHED FEBRUARY 19, 2026. THE FIRM HAD THREE WEEKS TO APPEAL THE DECISION, BUT, TO AVOID THE DISTRACTION
AND EXPENSE OF LITIGATION, THE FIRM HAS ELECTED TO ACCEPT THE DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION. YORK
PAID THE NOK 100,000 PROMPTLY UPON RECEIPT OF THE FINAL INVOICE FROM THE NFSA.
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
THE FINE IS FOR NOK 100,000
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 FINE IS FOR NOK 100,000. YORK PAID THE NOK 100,000 PROMPTLY UPON RECEIPT OF THE FINAL INVOICE FROM THE NFSA.
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 10, 2025, THE FIRM RECEIVED A LETTER (THE "LETTER") FROM THE FINANCIAL AUTHORITY OF NORWAY (NW.: FINANSTILSYNET) (THE
"NFSA"), NOTIFYING THE FIRM THAT NFSA WAS CONSIDERING IMPOSING A VIOLATION PENALTY OF NOK 100,000 ON THE FIRM WITH REGARD TO A
TRADE MADE BY YORK TACTICAL ENERGY FUND, L.P. AND YORK TACTICAL ENERGY FUND AIV-AN, L.P. (COLLECTIVELY, THE "YTEF FUNDS") IN SHARES OF
BLUENORD ASA ("BLUENORD"). THE YTEF FUNDS PARTICIPATED IN A TENDER OFFER CONDUCTED BY BLUENORD AND ULTIMATELY SOLD 250,556
SHARES PURSUANT TO THE TENDER OFFER. THE FIRM WAS UNCERTAIN AS TO BOTH THE NUMBER OF SHARES THAT WOULD BE ACCEPTED BY BLUENORD
IN THE TENDER OFFER AND THE FINAL SETTLEMENT DATE. AS A RESULT OF THIS SALE, THE FIRM'S AGGREGATE HOLDINGS IN BLUENORD FELL BELOW
5% AND A NOTIFICATION FILING WAS REQUIRED PURSUANT TO THE NORWEGIAN SECURITIES ACT ("NSTA"). WHILE THE FIRM MADE ITS NOTIFICATION
FILING IMMEDIATELY UPON ITS COMPLIANCE TEAM BEING NOTIFIED THAT THE TRADE WAS ACCEPTED AND HAD SETTLED, NFSA INDICATED IN THE
LETTER THAT IT BELIEVED THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE OBLIGATIONS UNDER THE NSTA AND, ACCORDINGLY, WAS CONSIDERING
IMPOSING THE VIOLATION PENALTY. THE NFSA ISSUED A FINAL DETERMINATION THAT THE FIRM FAILED TO TIMELY MEET ITS DISCLOSURE
OBLIGATIONS WITH REGARD TO THE SHARES SOLD PURSUANT TO THE TENDER OFFER AND IMPOSED A FINE OF NOK 100,000, WHICH THE FIRM
UNDERSTANDS IS A STANDARD FINE ISSUED IN SIMILAR CIRCUMSTANCES. THE NFSA DECISION WAS PUBLISHED FEBRUARY 19, 2026. THE FIRM HAD
THREE WEEKS TO APPEAL THE DECISION, BUT, TO AVOID THE DISTRACTION AND EXPENSE OF LITIGATION, THE FIRM HAS ELECTED TO ACCEPT THE
DETERMINATION INSTEAD OF SEEKING AN APPEAL OF THE DECISION.* 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.