First Citizens Asset 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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT, PREJUDGMENT INTEREST, AND UNDERTAKINGS.
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19026
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):
IN FEBRUARY 2018, THE U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC") ANNOUNCED AN INDUSTRY-WIDE INITIATIVE TO IDENTIFY AND REMEDY
CONFLICTS OF INTEREST THAT ARISE WHERE INVESTMENT ADVISERS FAILED TO MAKE REQUIRED DISCLOSURES RELATING TO THEIR SELECTION OF
CERTAIN MUTUAL FUND SHARE CLASSES THAT PAID THE ADVISER (OR ITS RELATED ENTITIES) A FEE PURSUANT TO RULE 12B-1 UNDER THE
INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEE") WHEN A LOWER-COST SHARE CLASS FOR THE SAME FUND WAS AVAILABLE TO CLIENTS. BASED ON
INFORMATION THAT FIRST CITIZENS ASSET MANAGEMENT, INC. ("FCAM") SELF-DISCLOSED, THE SEC ISSUED AN ORDER INSTITUTING ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS AGAINST FCAM ON MARCH 11, 2019 (THE "ORDER"). THE SEC DETERMINED THAT, FOR THE PERIOD FROM
JANUARY 1, 2014 TO JULY 20, 2018, FCAM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT PAID
12B-1 FEES TO FCAM (OR ITS AFFILIATED BROKER-DEALER) INSTEAD OF LOWER-COST SHARE CLASSES FOR THE SAME FUNDS FOR WHICH THE CLIENTS
WERE ELIGIBLE. THE SEC DETERMINED THAT FCAM DID NOT ADEQUATELY DISCLOSE: (A) ITS (OR ITS AFFILIATED BROKER-DEALER'S) RECEIPT OF 12B-1
FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. THE SEC FOUND THAT THIS CONDUCT VIOLATED SECTIONS
206(2) AND 207 OF THE INVESTMENT ADVISERS ACT OF 1940 (THE "ADVISERS ACT"). FCAM CONSENTED TO THE ORDER WITHOUT ADMITTING OR
DENYING THE SEC'S FINDINGS.
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):
03/11/2019
 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:
PREJUDGMENT INTEREST, AND, WITHIN 30 DAYS OF THE ORDER: (A) REVISE, AS NECESSARY, DISCLOSURE DOCUMENTS CONCERNING MUTUAL
FUND SHARE CLASS SELECTION AND 12B-1 FEES; (B) MOVE CLIENTS TO A LOWER-COST SHARE CLASS, AS NECESSARY; (C) REVISE, AS
NECESSARY, POLICIES AND PROCEDURES RELATED TO MUTUAL FUND SHARE CLASS SELECTION DISCLOSURES; AND (D) NOTIFY AFFECTED
INVESTORS OF THE 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: 
THE SEC CENSURED AND ORDERED FCAM TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. THE SEC ALSO ORDERED FCAM TO PAY $ 54,820.40 IN DISGORGEMENT AND $
7,598.04 IN PREJUDGMENT INTEREST TO FCAM INVESTORS AFFECTED BY THE CONDUCT DESCRIBED IN THE ORDER, PURSUANT TO PROCEDURES
OUTLINED THEREIN. THE SEC DID NOT ORDER A CIVIL MONETARY PENALTY OR FINE
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 MARCH 11, 2019, FCAM CONSENTED, WITHOUT ADMITTING OR DENYING THE FINDINGS (EXCEPT AS TO JURISDICTION), TO THE ISSUANCE OF THE
ORDER. (ON THE SAME DAY, THE SEC ISSUED SIMILAR ORDERS AGAINST 78 OTHER INVESTMENT ADVISERS.) THE SEC'S FINDINGS AGAINST FCAM ARE
SUMMARIZED IN RESPONSE TO QUESTION 7 ABOVE. IN ACCORDANCE WITH THE SEC'S ORDER, FCAM HAS DEPOSITED THE DISGORGEMENT AND
PREJUDGMENT INTEREST AMOUNTS INTO AN ESCROW ACCOUNT AND HAS COMPLIED WITH ALL RELEVANT DEADLINES RELATED TO THE
CONTEMPLATED DISTRIBUTION OF THESE FUNDS. FCAM ALSO IS IN THE PROCESS OF IMPLEMENTING (AND IN SOME CASES ALREADY HAS
IMPLEMENTED) THE UNDERTAKINGS SET FORTH IN RESPONSE TO QUESTION 12.B, ABOVE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates

One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
PRIVATE PLAINTIFF, PAMELA O'NEIL
2.
Principal Relief Sought:
Restitution
Other Relief Sought: 
ATTORNEY FEES, LITIGATION COSTS, EXCESS TAXES, LOST SOCIAL SECURITY REVENUE
3.
Filing Date of Court Action (MM/DD/YYYY):
02/26/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Annuity(ies) - Variable
Other Product Types: 
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 SOUTH CAROLINA MAGISTRATE COURT, AIKEN COUNTY, DOCKET #2018CV0210900134
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
COMPLAINANT ALLEGED ANNUITY SALE WAS IMPROPER AND UNSUITABLE GIVEN FINANCIAL CIRCUMSTANCES AND NEEDS.
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:
Dismissed

12. Resolution Date (MM/DD/YYYY): 
05/31/2018
 Exact
 Explanation
If not exact, provide explanation:
DETERMINED THROUGH COURT RECORD SEARCH.
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 0.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
DISMISSED
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:
DISMISSED
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). 
CLAIMANT, THROUGH COUNSEL, FILED A COMPLAINT THROUGH THE STATE OF SOUTH CAROLINA'S MAGISTRATE COURT DEMANDING A JURY BY TRIAL.
THE ADVISOR, FIRST CITIZENS ASSET MANAGEMENT, INC., WAS NAMED AS DEFENDANT. CLAIMANT ALLEGED FCAM NEGLIGENTLY ADVISED HER TO
INVEST FUNDS INTO AN ANNUITY THAT FCAM KNEW THE COMPLAINANT MIGHT NEED FOR A LOAN REFINANCE. THE COMPLAINANT ALLEGEDLY SUFFERED
LOSSES DUE TO THE WITHDRAWAL OF FUNDS FROM THE ANNUITY, WHICH ALSO SERVED TO INCREASE HER ANNUAL INCOME. THE INCREASE TO
ANNUAL INCOME IS ALLEGED TO HAVE CAUSED ADVERSE TAX AND SOCIAL SECURITY INCOME CONSEQUENCES. CLAIMANT REQUESTED
REIMBURSEMENT FOR THE COSTS OF LITIGATION, ATTORNEY'S FEES, EARLY WITHDRAWAL CHARGES IMPOSED, ADDITIONAL TAX AMOUNTS PAID, AND
THE REDUCED PORTION OF SOCIAL SECURITY PAYMENTS RESULTING FROM THE WITHDRAWAL OF FUNDS FROM THE ANNUITY. FCAM DENIES ANY AND
ALL ALLEGATIONS MADE BY CLAIMANT. CASE STATUS IS PENDING.