Folger Nolan Fleming Douglas Capital Management, Inc..

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:
319
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FOLGER NOLAN FLEMING
DOUGLAS INCORPORATED
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE AND RESTITUTION
3.
Date Initiated (MM/DD/YYYY): 
10/02/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20090183062
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MSRB RULES G:17 AND G-30(A): FROM OCTOBER 1, 2008, IN SEVEN TRANSACTIONS, FOLGER NOLAN FLEMING DOUGLAS INCORPORATED THE
BROKER/DEALER AFFILIATE OF FOLGER NOLAN FLEMING DOUGLAS CAPITAL MANAGEMENT, INC. PURCHASED MUNICIPAL SECURITIES FOR ITS OWN
ACCOUNT FROM A CUSTOMER AND/OR SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING
ANY MARK-UP OR MARK-DOWN) THAT WAS NOT FAIR AND REASONABLE, TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST
JUDGEMENT OF THE BROPKER, DEALER, OR MUNICIPAL SECURITIES DEALER AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE
TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING
THE TRANSACTION, THE FACT THAT THE BROKER,DEALER OR MUNICIPAL SECURITIES DEALER IS ENTITLED TO A PROFIT, AND THE TOTAL DOLLAR
AMOUNT OF THE TRANSACTION.
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):
10/17/2011
 Exact
 Explanation
If not exact, provide explanation:
WITHOUT ADMITTING OR DENYING THE FINDINGS, FOLGER NOLAN FLEMING DOUGLAS INCORPORATED CONSENTED TO THE DESCRIBED SANCTIONS
AND TO THE ENTRY OF FINDINGS, THEREFORE, THE FIRM IS CENSURED, FINED $10,000 AND ORDERED TO PAY $3,422.40, PLUS INTEREST, IN
RESTITUTION TO INVESTORS. THE FINE WAS PAID IN FULL ON 10/26/2011.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 10,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
NONE
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: 
$10,000 FIME LEVIED ENTIRELY AGAINST FOLGER NOLAN FLEMING DOUGLAS INCORPORATED.
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 REGULATORY ACTION AGAINST FOLGER NOLAN FLEMING DOUGLAS INCORPORATED DID NOT INVOLVE CLIENT ACCOUNTS OF FOLGER NOLAN
FLEMING DOUGLAS CAPITAL MANAGEMENT, INC.

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) 
US SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
UNDER THE TERMS OF THE ORDER, CMI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND
ANY FUTURE VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT. IN ADDITION, THE ORDER REQUIRES CMI TO PAY DISGORGEMENT AND
PREJUDGMENT INTEREST TO AFFECTED INVESTORS TOTALING $59,479.27, AND TO FULFILL CERTAIN RELATED UNDERTAKINGS. NO PENALTY WAS
IMPOSED ON CMI BECAUSE IT SELF-REPORTED THE DISCLOSURE DEFICIENCIES TO THE SEC.
3.
Date Initiated (MM/DD/YYYY): 
09/30/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-19558
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 30, 2019, CMI ELECTED TO PARTICIPATE IN THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE (THE "SCSD INITIATIVE").
THE SCSD INITIATIVE PROVIDED INVESTMENT ADVISERS WITH THE OPPORTUNITY TO VOLUNTARILY SELF-REPORT TO THE SEC'S DIVISION OF
ENFORCEMENT POSSIBLE SECURITIES LAW VIOLATIONS RELATED TO THE ADEQUACY OF THEIR DISCLOSURES CONCERNING MUTUAL FUND SHARE
CLASS SELECTION AND FEES RECEIVED PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940. AT THE CONCLUSION OF THE
SCSD INITIATIVE, THE SEC ISSUED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS AGAINST CMI, AND CMI
CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN. AS DESCRIBED IN THE ORDER, THE SEC FOUND
THAT AT TIMES FROM JANUARY 1, 2014 TO MAY 31, 2018 (THE "RELEVANT PERIOD"), CMI HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES
THAT CHARGED 12B-1 FEES INSTEAD OF LOWER COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE ELIGIBLE. THE FEES
WERE PAID BY MUTUAL FUNDS TO CMI'S AFFILIATED BROKER-DEALER IN CONNECTION WITH THESE INVESTMENTS. ACCORDING TO THE ORDER,
DURING THE RELEVANT PERIOD, CMI DID NOT DISCLOSE ADEQUATELY TO ITS INVESTMENT ADVISORY CLIENTS IN ITS FORM ADV OR OTHERWISE THE
CONFLICTS OF INTEREST RELATED TO CMI'S AFFILIATED BROKER-DEALER'S RECEIPT OF 12B-1 FEES. THE ORDER STATES THAT AS A RESULT OF THE
CONDUCT DESCRIBED ABOVE, CMI BREACHED ITS FIDUCIARY DUTY TO THE AFFECTED CLIENTS AND WILLFULLY VIOLATED SECTION 206(2) OF THE
ADVISERS ACT. UNDER THE TERMS OF THE ORDER, CMI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY
VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT. IN ADDITION, THE ORDER REQUIRES CMI TO PAY
DISGORGEMENT AND PREJUDGMENT INTEREST TO AFFECTED INVESTORS TOTALING $59,479.27, AND TO FULFILL CERTAIN RELATED UNDERTAKINGS. NO
PENALTY WAS IMPOSED ON CMI BECAUSE IT SELF-REPORTED THE DISCLOSURE DEFICIENCIES TO THE SEC.
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):
09/30/2019
 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:
NOTIFICATION OF AFFECTED INVESTORS OF THE SETTLEMENT TERMS OF THE ORDER.
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: 
DISGORGEMENT AND PREJUDGEMENT INTEREST OF $59,479.27 PAID ON MAY 30, 2018.
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).
FINAL DISPOSITION OF THE OFFER OF SETTLEMENT ON 9/30/2019.