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 Wl Ross & Co.. LLC
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 Wl Ross & Co.. LLC.
Reported ownership and control details
Form ADV · Filing date 2026-03-26 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | INVESCO PRIVATE CAPITAL, INC.SOLE MEMBERDomestic entity | WL ROSS & CO. LLC | 75% or moreCode E | Yes | SOLE MEMBER10/2006 | Schedule APDF page 64 |
| 2 | Joshua Evan LevitCHIEF COMPLIANCE OFFICERIndividual | WL ROSS & CO. LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER09/2018 | Schedule APDF page 64 |
| 3 | Richard Scott DennisSENIOR MANAGING DIRECTORIndividual | WL ROSS & CO. LLC | Less than 5%Code NA | Yes | SENIOR MANAGING DIRECTOR03/2020 | Schedule APDF page 64 |
| 4 | ANTONIO MICHAEL REINASECRETARYIndividual | WL ROSS & CO. LLC | Less than 5%Code NA | Yes | SECRETARY03/2021 | Schedule APDF page 64 |
| 5 | COURTNEY RYAN POPELKACHIEF FINANCIAL OFFICERIndividual | WL ROSS & CO. LLC | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER10/2024 | Schedule APDF page 64 |
| 6 | INVESCO ADVISERS, INC.SOLE SHAREHOLDERDomestic entity | INVESCO PRIVATE CAPITAL, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER12/2005 | Schedule BPDF page 64 |
| 7 | INVESCO GROUP SERVICES, INCSOLE SHAREHOLDERDomestic entity | INVESCO ADVISERS, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER06/2018 | Schedule BPDF page 64 |
| 8 | INVESCO HOLDING COMPANY (US), INC.SOLE SHAREHOLDERDomestic entity | OPPENHEIMER ACQUISITION CORP. (GATC) | 75% or moreCode E | Yes | SOLE SHAREHOLDER02/1997 | Schedule BPDF page 64 |
| 9 | INVESCO HOLDING COMPANY LIMITEDSOLE SHAREHOLDERForeign entity | INVESCO HOLDING COMPANY (US), INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER06/2018 | Schedule BPDF page 64 |
| 10 | INVESCO LTD.SOLE SHAREHOLDERForeign entity | INVESCO HOLDING COMPANY LIMITED | 75% or moreCode E | Yes | SOLE SHAREHOLDER01/2002 | Schedule BPDF page 64 |
| 11 | OPPENHEIMERFUNDS, INC.SOLE SHAREHOLDERDomestic entity | INVESCO GROUP SERVICES, INC | 75% or moreCode E | Yes | SOLE SHAREHOLDER05/2019 | Schedule BPDF page 64 |
| 12 | OPPENHEIMER ACQUISITION CORP. (GATC)SOLE SHAREHOLDERDomestic entity | OPPENHEIMERFUNDS, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER05/2019 | Schedule BPDF page 65 |
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 3/26/2026 3:35:05 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 actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- 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?Yes
DOther regulatory actions3 Yes2 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?Yes
- 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 Yes
- 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?Yes
HCivil judicial actions and proceedings1 Yes3 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?Yes
(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 7 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 1AIM ADVISORS, INC.PDF pages 65–67
- Advisory affiliate name — filed text
- AIM ADVISORS, INC.
- Regulator name — filed text
- WEST VIRGINIA OFFICE OF THE STATE AUDITOR SECURITIES COMMISSION.
Action status / disposition — filed text
ON AUGUST 30, 2005, THE WEST VIRGINIA OFFICE OF THE STATE AUDITOR - SECURITIES COMMISSION ("WVASC") ISSUED A SUMMARY ORDER TO CEASE AND DESIST AND NOTICE OF RIGHT TO HEARING TO AIM AND ADI (ORDER NO. 05-1318). THE WVASC ALLEGES THAT AIM AND ADI FAILED TO DISCLOSE MARKET TIMING ARRAGEMENTS. THE WVASC PURPORTS TO ORDER AIM AND ADI TO CEASE ANY FURTHER VIOLATIONS AND SEEKS TO IMPOSE MONETARY SANCTIONS, INCLUDING RESTITUTION TO AFFECTED INVESTORS, DISGORGEMENT OF FEES, REIMBURSEMENT OF INVESTIGATORY, ADMINISTRATIVE AND LEGAL COSTS AND AN "ADMINISTRATIVE ASSESSMENT" TO BE DETERMINED BY THE COMMISSIONER. WE BELIEVE THIS MATTER HAS BEEN INDEFINITELY SUSPENDED.
Other filed details
Description of allegations — filed text
ALLEGEDLY, AIM AND ADI FAILED TO DISCLOSE THAT THEY HAD ENTERED INTO CERTAIN ARRANGEMENTS PERMITTING MARKET TIMING OF SUCH FUNDS, THEREBY BREACHING THEIR FIDUCIARY DUTIES TO THE FUNDS.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
AIM ADVISORS, INC.
(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)
WEST VIRGINIA OFFICE OF THE STATE AUDITOR SECURITIES COMMISSION.
2.
Principal Sanction:
Other
Other Sanctions:
SEEKS CEASE AND DESIST
3.
Date Initiated (MM/DD/YYYY):
08/30/2005
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ORDER NO. 05-1318
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):
ALLEGEDLY, AIM AND ADI FAILED TO DISCLOSE THAT THEY HAD ENTERED INTO CERTAIN ARRANGEMENTS PERMITTING MARKET TIMING OF SUCH FUNDS,
THEREBY BREACHING THEIR FIDUCIARY DUTIES TO THE FUNDS.
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:
11. Resolution Date (MM/DD/YYYY):
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:
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:
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 AUGUST 30, 2005, THE WEST VIRGINIA OFFICE OF THE STATE AUDITOR - SECURITIES COMMISSION ("WVASC") ISSUED A SUMMARY ORDER TO
CEASE AND DESIST AND NOTICE OF RIGHT TO HEARING TO AIM AND ADI (ORDER NO. 05-1318). THE WVASC ALLEGES THAT AIM AND ADI FAILED TO
DISCLOSE MARKET TIMING ARRAGEMENTS. THE WVASC PURPORTS TO ORDER AIM AND ADI TO CEASE ANY FURTHER VIOLATIONS AND SEEKS TO
IMPOSE MONETARY SANCTIONS, INCLUDING RESTITUTION TO AFFECTED INVESTORS, DISGORGEMENT OF FEES, REIMBURSEMENT OF INVESTIGATORY,
ADMINISTRATIVE AND LEGAL COSTS AND AN "ADMINISTRATIVE ASSESSMENT" TO BE DETERMINED BY THE COMMISSIONER. WE BELIEVE THIS MATTER
HAS BEEN INDEFINITELY SUSPENDED.regulatory · block 2PDF pages 67–69
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 2,300,000.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
THE SEC ADMINISTRATIVE ORDER IS FINAL. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY WL ROSS AND COOPERATION AFFORDED THE COMMISSION STAFF, INCLUDING WL ROSS' SELF-REPORTING OF THE TRANSACTION FEE ALLOCATION ISSUE TO THE OCIE STAFF, WL ROSS' VOLUNTARY DETERMINATION TO REVISE ITS FEE ALLOCATION METHODOLOGY, AND WL ROSS' VOLUNTARY REIMBURSEMENT, WITH INTEREST, OF $11,873,571 IN MANAGEMENT FEE CREDITS RESULTING FROM ITS RETROACTIVE APPLICATION OF THE REVISED ALLOCATION METHODOLOGY TO THE INCEPTION OF THE WLR FUNDS.
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT WL ROSS FAILED TO ADEQUATELY DISCLOSE ITS FEE ALLOCATION PRACTICES TO CERTAIN PRIVATE EQUITY FUNDS IT ADVISED (THE "WLR FUNDS") AND THEIR INVESTORS AND THAT AMBIGUOUS LANGUAGE IN ITS PRIVATE EQUITY FUND LIMITED PARTNERSHIP AGREEMENTS RESULTED IN CERTAIN WLR FUNDS PAYING HIGHER MANAGEMENT FEES BEWTEEN 2001 AND 2011.
Sanction detail — filed text
THE ORDER IMPOSES A CIVIL PENALTY OF $2.3 MILLION. THE PORTION LEVIED AGAINST WL ROSS IS 100%. THE PENALTY WAS PAID ON AUGUST 26, 2016
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) U.S. SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: CIVIL PENALTY 3. Date Initiated (MM/DD/YYYY): 08/24/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ADMINISTRATIVE PROCEEDING FILE NO. 3-17491 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 EQUITY FUNDS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE SEC ALLEGED THAT WL ROSS FAILED TO ADEQUATELY DISCLOSE ITS FEE ALLOCATION PRACTICES TO CERTAIN PRIVATE EQUITY FUNDS IT ADVISED (THE "WLR FUNDS") AND THEIR INVESTORS AND THAT AMBIGUOUS LANGUAGE IN ITS PRIVATE EQUITY FUND LIMITED PARTNERSHIP AGREEMENTS RESULTED IN CERTAIN WLR FUNDS PAYING HIGHER MANAGEMENT FEES BEWTEEN 2001 AND 2011. 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): 08/24/2016 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: $ 2,300,000.00 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: THE ORDER IMPOSES A CIVIL PENALTY OF $2.3 MILLION. THE PORTION LEVIED AGAINST WL ROSS IS 100%. THE PENALTY WAS PAID ON AUGUST 26, 2016 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 SEC ADMINISTRATIVE ORDER IS FINAL. IN DETERMINING TO ACCEPT THE OFFER, THE COMMISSION CONSIDERED REMEDIAL ACTS PROMPTLY UNDERTAKEN BY WL ROSS AND COOPERATION AFFORDED THE COMMISSION STAFF, INCLUDING WL ROSS' SELF-REPORTING OF THE TRANSACTION FEE ALLOCATION ISSUE TO THE OCIE STAFF, WL ROSS' VOLUNTARY DETERMINATION TO REVISE ITS FEE ALLOCATION METHODOLOGY, AND WL ROSS' VOLUNTARY REIMBURSEMENT, WITH INTEREST, OF $11,873,571 IN MANAGEMENT FEE CREDITS RESULTING FROM ITS RETROACTIVE APPLICATION OF THE REVISED ALLOCATION METHODOLOGY TO THE INCEPTION OF THE WLR FUNDS.
regulatory · block 3PDF pages 69–70
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: 104983 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OPPENHEIMERFUNDS INC (For individuals, Last, First, Middle) CRD Number: 7834 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OPPENHEIMERFUNDS DISTRIBUTOR, INC. (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) 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 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: Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): 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: 11. Resolution Date (MM/DD/YYYY): 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: 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: 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).
regulatory · block 4INVESCO LTD.PDF pages 70–72
- Advisory affiliate name — filed text
- INVESCO LTD.
- Regulator name — filed text
- FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
- Monetary/Fine Amount — filed text
- $ 309,595.00
- How was matter resolved — filed text
- Decision
Action status / disposition — filed text
BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.
Other filed details
Description of allegations — filed text
INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS.
Sanction detail — filed text
DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021 DEADLINE.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO LTD.
(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)
FEDERAL FINANCIAL SUPERVISORY AUTHORITY ("BAFIN")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
07/30/2020
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
WA 17-WP 3120-2020/0003; WA 17-WP 3120-2020/0004
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
INVESCO LTD
6.
Principal Product Type:
Other
Other Product Types:
THE MATTER RELATED TO OWNERSHIP FILINGS WITH THE GERMAN REGULATOR IN RELATION TO GERMAN LISTED COMPANIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
INVESCO LTD AND AIM INTERNATIONAL MUTUAL FUNDS FAILED TO SUBMIT VOTING RIGHTS NOTIFICATIONS TO BAFIN AND THE ISSUERS BY THE
REQUIRED DEADLINE. BAFIN ISSUED A NOTICE OF HEARING ON JULY 30, 2020 TO INVESCO LTD ALLEGING THAT VIOLATIONS OF THE VOTING RIGHTS
REQUIREMENTS OCCURED ON 26 OCCASSIONS RELATING TO THE VOTING RIGHTS NOTIFICATIONS OF INVESCO LTD AND ON 28 OCCASIONS RELATING
TO VOTING RIGHTS NOTIFICATIONS OF AIM INTERNATIONAL MUTUAL FUNDS.
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):
05/31/2021
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: $ 309,595.00
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:
DECISION TO IMPOSE A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 USD) AGAINST INVESCO LTD WILL BE PAID BY THE JULY 2, 2021
DEADLINE.
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).
BAFIN IMPOSED A FINE OF 260,000 EUROS (APPROXIMATELY $309,595 US DOLLARS) AGAINST INVESCO LTD FOR 54 INCORRECT THRESHOLD FILINGS
BETWEEN 05/2019 AND 10/2019. THE FINE WILL BE PAID BY THE JULY 2, 2021 DEADLINE.regulatory · block 5PDF pages 72–74
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC")
- Monetary/Fine Amount — filed text
- $ 35,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON SEPTEMBER 24, 2024, IAI, AN INVESTMENT ADVISORY AFFILIATE OF WL ROSS & CO. LLC AND IDI, AN AFFILIATED BROKER-DEALER THEREOF (TOGETHER, WITH IAI, "INVESCO") HAVE ENTERED INTO A SETTLEMENT WITH THE SEC IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE INVESTIGATION INTO THE MAINTENANCE AND PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT, FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO ELECTRONIC COMMUNICATIONS, INCLUDING BY ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE USE OF ELECTRONIC COMMUNICATIONS, AND BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW.
Sanction detail — filed text
THE SETTLEMENT REQUIRED IAI AND IDI TO PAY A CIVIL MONETARY PENALTY OF $35 MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL MONETARY PENALTY ON OCTOBER 1, 2024.
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:
105360
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO ADVISERS, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
7369
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO DISTRIBUTORS, INC.
(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)
U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALTY/FINE, CENSURE AND UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY):
05/15/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-22165
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") AND INVESCO DISTRIBUTORS, INC. ("IDI") FAILED TO ADEQUATELY PRESERVE CERTAIN
ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING PROVISIONS OF FEDERAL SECURITIES LAW.
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):
09/24/2024
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: $ 35,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
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 SETTLEMENT REQUIRED IAI AND IDI TO PAY A CIVIL MONETARY PENALTY OF $35 MILLION AND COMPLY WITH CERTAIN UNDERTAKINGS,
INCLUDING THE RETENTION OF A COMPLIANCE CONSULTANT. INVESCO PAID THE CIVIL MONETARY PENALTY ON OCTOBER 1, 2024.
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 SEPTEMBER 24, 2024, IAI, AN INVESTMENT ADVISORY AFFILIATE OF WL ROSS & CO. LLC AND IDI, AN AFFILIATED BROKER-DEALER THEREOF
(TOGETHER, WITH IAI, "INVESCO") HAVE ENTERED INTO A SETTLEMENT WITH THE SEC IN CONNECTION WITH THE AGENCY'S INDUSTRY-WIDE
INVESTIGATION INTO THE MAINTENANCE AND PRESERVATION OF ELECTRONIC COMMUNICATIONS PURSUANT TO APPLICABLE RECORDKEEPING
PROVISIONS OF FEDERAL SECURITIES LAW. THE SETTLEMENT CENSURES INVESCO AND REQUIRES THAT INVESCO CEASE AND DESIST FROM ANY
EXISTING AND FUTURE VIOLATIONS, PAY A CIVIL MONETARY PENALTY OF $35,000,000 AND RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT,
FOLLOWING THE FORMAT FOR ALL OTHER RECENT ELECTRONIC COMMUNICATIONS SETTLEMENTS. INVESCO COOPERATED WITH THE GOVERNMENT'S
INQUIRY AND HAS ALREADY TAKEN SIGNIFICANT STEPS TO FURTHER STRENGTHEN THE FIRM'S COMPLIANCE ENVIRONMENT AS IT RELATES TO
ELECTRONIC COMMUNICATIONS, INCLUDING BY ENHANCING ITS POLICIES AND PROCEDURES, IMPLEMENTING INCREASED TRAINING REGARDING THE
USE OF ELECTRONIC COMMUNICATIONS, AND BEGINNING TO IMPLEMENT CHANGES TO THE TECHNOLOGY AVAILABLE TO EMPLOYEES.regulatory · block 6INVESCO ADVISERS, INC.PDF pages 74–76
- Advisory affiliate name — filed text
- INVESCO ADVISERS, INC.
- Regulator name — filed text
- U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC")
- Monetary/Fine Amount — filed text
- $ 17,500,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON NOVEMBER 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF WL ROSS & CO. LLC, ENTERED INTO A SETTLEMENT WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED.
Sanction detail — filed text
THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL MONETARY PENALTY ON NOVEMBER 14, 2024.
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:
105360
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
INVESCO ADVISERS, INC.
(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)
U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALTY AND CENSURE
3.
Date Initiated (MM/DD/YYYY):
11/28/2022
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-22306
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:
ETFS AND SEPARATELY MANAGED ACCOUNTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT INVESCO ADVISERS, INC. ("IAI") LACKED COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF
COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS ESG INTEGRATED. THE SEC ALSO ALLEGED THAT IAI MADE MISLEADING STATEMENTS
CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS ESG INTEGRATED.
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):
11/08/2024
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: $ 17,500,000.00
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:
THE SETTLEMENT REQUIRED INVESCO ADVISERS, INC. ("IAI") TO PAY A CIVIL MONETARY PENALTY OF $17.5 MILLION. IAI PAID THE CIVIL
MONETARY PENALTY ON NOVEMBER 14, 2024.
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 8, 2024, INVESCO ADVISERS, INC. ("IAI"), AN INVESTMENT ADVISORY AFFILIATE OF WL ROSS & CO. LLC, ENTERED INTO A SETTLEMENT
WITH THE SEC REGARDING IAI'S ENVIRONMENTAL, SOCIAL AND GOVERNANCE ("ESG") POLICIES AND PROCEDURES. THE SEC FOUND THAT IAI LACKED
COMPREHENSIVE POLICIES AND PROCEDURES TO DETERMINE THE PERCENTAGE OF COMPANY-WIDE ASSETS UNDER MANAGEMENT ("AUM") THAT WAS
ESG INTEGRATED. THE SEC ALSO FOUND THAT IAI MADE MISLEADING STATEMENTS CONCERNING THE COMPANY-WIDE PERCENTAGE OF AUM THAT WAS
ESG INTEGRATED. IAI WAS CENSURED AND ORDERED TO CEASE AND DESIST FROM VIOLATING SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT
AND RULES 206(4)-1, 206(4)-7 AND 206(4)-8 THEREUNDER. IAI AGREED TO PAY A PENALTY OF $17.5 MILLION.Show 1 more source blocks
civil judicial · block 1PDF pages 76–78
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: 107807 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OFI PRIVATE INVESTMENTS INC (For individuals, Last, First, Middle) CRD Number: 7834 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OPPENHEIMERFUNDS DISTRIBUTOR, INC. (For individuals, Last, First, Middle) CRD Number: 104983 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OPPENHEIMERFUNDS INC (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.) 2. Principal Relief Sought: Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Principal Product Type: 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): 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): 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: 12. Resolution Date (MM/DD/YYYY): 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: $ 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: 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).
* 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.