Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total AUM
Total Accounts
10Y AUM Change
Private Funds
Private funds reported by U.S. Bancorp Advisors, LLC
Loading private fund disclosures…
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total Employees
Clients per Employee
10Y Employee Change
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
Each range applies to a separate reported relationship and should not be added together.
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
0%25%50%75%100%
U.S. BANCORPDirect owner · Schedule AInterest in U.S. BANCORP ADVISORS, LLC
75%+
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 U.S. Bancorp Advisors, LLC.
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-09-25 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | SHANE T TRIPLETTMANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | MANAGER02/2026 | Schedule APDF page 41 |
| 2 | SHANNON KEITH CLARKCHIEF FINANCIAL OFFICER AND MANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER AND MANAGER02/2026 | Schedule APDF page 41 |
| 3 | U.S. BANCORPSOLE MEMBERDomestic entity | U.S. BANCORP ADVISORS, LLC | 75% or moreCode E | Yes | SOLE MEMBER06/2023 | Schedule APDF page 41 |
| 4 | KIMBERLY NICOLE FERGUSONPRESIDENT, CHIEF EXECUTIVE OFFICER AND MANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | PRESIDENT, CHIEF EXECUTIVE OFFICER AND MANAGER09/2026 | Schedule APDF page 41 |
| 5 | EILEEN BEJASAMANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | MANAGER02/2026 | Schedule APDF page 41 |
| 6 | KYLE NORMAN SALSTROMCHIEF COMPLIANCE OFFICER AND MANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER AND MANAGER02/2026 | Schedule APDF page 41 |
| 7 | CARLOS ALONSO ARIASMANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | MANAGER02/2026 | Schedule APDF page 41 |
| 8 | JOEL IRA FLOUMMANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | MANAGER02/2026 | Schedule APDF page 41 |
| 9 | EILEEN RENEE MENACHERMANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | MANAGER02/2026 | Schedule APDF page 42 |
| 10 | STEPHEN WARD STEINERCHIEF OPERATIONS OFFICER AND MANAGERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | Yes | CHIEF OPERATIONS OFFICER AND MANAGER02/2026 | Schedule APDF page 42 |
| 11 | MATTHEW RYAN MCCARTHYCHIEF LEGAL OFFICERIndividual | U.S. BANCORP ADVISORS, LLC | Less than 5%Code NA | No | CHIEF LEGAL OFFICER02/2026 | Schedule APDF page 42 |
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 9/25/2026 3:43:15 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.
RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
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 actions3 Yes2 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?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 actions4 Yes1 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?Yes
ESelf-regulatory organization actions1 Yes3 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?Yes
- 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 8 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 1U.S. BANCORP INVESTMENTS, INC.PDF pages 43–44
- Advisory affiliate name — filed text
- U.S. BANCORP INVESTMENTS, INC.
- Regulator name — filed text
- THE SECURITIES AND EXCHANGE COMMISSION ("SEC")
- Monetary/Fine Amount — filed text
- $ 8,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN DETERMINING TO ACCEPT USBI'S OFFER OF SETTLEMENT, THE SEC CONSIDERED STEPS PROMPTLY UNDERTAKEN BY USBI PRIOR TOAND AFTER BEING APPROACHED BY THE SEC AND COOPERATION AFFORDED THE SEC STAFF. THE MONETARY FINE HAS BEEN PAID ANDUSBI IS COMPLYING WITH THE ORDERED UNDERTAKINGS.
Other filed details
Description of allegations — filed text
ON FEBRUARY 9, 2024, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED A SETTLED ADMINISTRATIVE ORDER FINDINGTHAT U.S. BANCORP INVESTMENTS, INC. ("USBI") VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGEACT") AND RULE 17A-4(B) (4) THEREUNDER, WHICH REQUIRE BROKER-DEALERS TO PRESERVE FOR AT LEAST THREE YEARS ORIGINALS OF ALL COMMUNICATIONS RECEIVED AND COPIES OF ALL COMMUNICATIONS SENT RELATING TO ITS BUSINESS AS SUCH. IN ADDITION,THE SEC FOUND USBI FAILED TO REASONABLY SUPERVISE ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THEEXCHANGE ACT.
Sanction detail — filed text
USBI PAID A FINE OF $8,000,000 ON FEBRUARY 13, 2024, AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDINGTHE RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT TO REVIEW POLICIES AND PROCEDURES RELATED TOELECTRONIC COMMUNICATIONS.
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:
17868
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANCORP INVESTMENTS,
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)
THE SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURE, CIVIL AND ADMINISTRATIVE PENALT(IES) / FINES, UNDERTAKINGS
3.
Date Initiated (MM/DD/YYYY):
02/09/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-21854
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):
ON FEBRUARY 9, 2024, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") ISSUED A SETTLED ADMINISTRATIVE ORDER FINDINGTHAT U.S.
BANCORP INVESTMENTS, INC. ("USBI") VIOLATED SECTION 17(A) OF THE SECURITIES EXCHANGE ACT OF 1934 ("EXCHANGEACT") AND RULE 17A-4(B)
(4) THEREUNDER, WHICH REQUIRE BROKER-DEALERS TO PRESERVE FOR AT LEAST THREE YEARS ORIGINALS OF ALL COMMUNICATIONS RECEIVED AND
COPIES OF ALL COMMUNICATIONS SENT RELATING TO ITS BUSINESS AS SUCH. IN ADDITION,THE SEC FOUND USBI FAILED TO REASONABLY SUPERVISE
ITS EMPLOYEES WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THEEXCHANGE ACT.
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):
02/09/2024
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: $ 8,000,000.00
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:
USBI PAID A FINE OF $8,000,000 ON FEBRUARY 13, 2024, AND AGREED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDINGTHE RETENTION
OF AN INDEPENDENT COMPLIANCE CONSULTANT TO REVIEW POLICIES AND PROCEDURES RELATED TOELECTRONIC COMMUNICATIONS.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN DETERMINING TO ACCEPT USBI'S OFFER OF SETTLEMENT, THE SEC CONSIDERED STEPS PROMPTLY UNDERTAKEN BY USBI PRIOR TOAND AFTER
BEING APPROACHED BY THE SEC AND COOPERATION AFFORDED THE SEC STAFF. THE MONETARY FINE HAS BEEN PAID ANDUSBI IS COMPLYING WITH
THE ORDERED UNDERTAKINGS.regulatory · block 2PDF pages 45–46
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
FINRA ALLEGES THAT FROM 1/2016 THROUGH 12/2018, UNIONBANC INVESTMENT SERVICES (UBIS) FAILED TO ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SUPERVISORY SYSTEM & WSPS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS WITH RESPECT TO CERTAIN TYPES OF VARIABLE ANNUITY (VA) TRANSACTIONS. IN ADDITION, FROM 1/2016 THROUGH 9/2019, UBIS FAILED TO ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SYSTEM AND WSPS FOR THE SURVEILLANCE OF RATES OF VA EXCHANGES. UBIS NEITHER ADMITTED NOR DENIED THOSE ALLEGATIONS.
Sanction detail — filed text
THE FIRM WAS CENSURED AND FINED $100,000.
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) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/05/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2019062972401 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Annuity(ies) - Variable Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FINRA ALLEGES THAT FROM 1/2016 THROUGH 12/2018, UNIONBANC INVESTMENT SERVICES (UBIS) FAILED TO ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SUPERVISORY SYSTEM & WSPS TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS AND REGULATIONS WITH RESPECT TO CERTAIN TYPES OF VARIABLE ANNUITY (VA) TRANSACTIONS. IN ADDITION, FROM 1/2016 THROUGH 9/2019, UBIS FAILED TO ESTABLISH AND MAINTAIN A REASONABLY DESIGNED SYSTEM AND WSPS FOR THE SURVEILLANCE OF RATES OF VA EXCHANGES. UBIS NEITHER ADMITTED NOR DENIED THOSE ALLEGATIONS. 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): 05/05/2021 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: $ 100,000.00 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 FIRM WAS CENSURED AND FINED $100,000. 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 3U.S. BANCORP; USB AMERICAS HOLDING COMPANYPDF pages 46–48
- Advisory affiliate name — filed text
- U.S. BANCORP; USB AMERICAS HOLDING COMPANY
- Regulator name — filed text
- BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
- Monetary/Fine Amount — filed text
- $ 15,000,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE BOARD ORDER REQUIRES THAT USB AND/OR THE AGREEMENT CORPORATION SUBMIT TO THE RESERVE BANK WRITTEN PLANS REGARDING ITS BSA/AML AND OFAC COMPLIANCE AND BOARD OVERSIGHT THEREOF. THE BOARD ORDER ALSO REQUIRES THAT USB ACT AS A SOURCE OF STRENGTH TO U.S. BANK, INCLUDING TAKING STEPS TO ENSURE U.S. BANK COMPLIES WITH ANY SUPERVISORY ACTION TAKEN AGAINST U.S. BANK BY ITS REGULATORS.
Other filed details
Description of allegations — filed text
U.S. BANCORP ("USB") LACKED ADEQUATE RISK MANAGEMENT AND COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES CONDUCTED AT U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") AND USB AMERICAS HOLDINGS COMPANY (THE "AGREEMENT CORPORATION") COMPLIED WITH APPLICABLE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") AND OFAC RULES AND REGULATIONS AND WERE TIMELY REPORTED IN RESPONSE TO INQUIRIES BY THE FEDERAL RESERVE BANK OF MINNEAPOLIS ("RESERVE BANK").
Sanction detail — filed text
PURSUANT TO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "BOARD ORDER"), THE FEDERAL RESERVE ORDERED USB TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000.
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:
U.S. BANCORP; USB AMERICAS
HOLDING COMPANY
(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)
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
02/15/2018
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
18-005-B-HC18-005-B-HC; 18-005-B-AC; 18-005-CMP-B-HC
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):
U.S. BANCORP ("USB") LACKED ADEQUATE RISK MANAGEMENT AND COMPLIANCE POLICIES AND PROCEDURES TO ENSURE THAT ACTIVITIES
CONDUCTED AT U.S. BANK NATIONAL ASSOCIATION ("U.S. BANK") AND USB AMERICAS HOLDINGS COMPANY (THE "AGREEMENT CORPORATION")
COMPLIED WITH APPLICABLE BANK SECRECY ACT AND ANTI-MONEY LAUNDERING ("BSA/AML") AND OFAC RULES AND REGULATIONS AND WERE TIMELY
REPORTED IN RESPONSE TO INQUIRIES BY THE FEDERAL RESERVE BANK OF MINNEAPOLIS ("RESERVE BANK").
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):
02/18/2018
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: $ 15,000,000.00
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:
PURSUANT TO AN ORDER TO CEASE AND DESIST AND ORDER OF ASSESSMENT OF A CIVIL MONEY PENALTY (THE "BOARD ORDER"), THE FEDERAL
RESERVE ORDERED USB TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $15,000,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN ADDITION TO PAYMENT OF THE CIVIL MONEY PENALTY, THE BOARD ORDER REQUIRES THAT USB AND/OR THE AGREEMENT CORPORATION SUBMIT TO
THE RESERVE BANK WRITTEN PLANS REGARDING ITS BSA/AML AND OFAC COMPLIANCE AND BOARD OVERSIGHT THEREOF. THE BOARD ORDER ALSO
REQUIRES THAT USB ACT AS A SOURCE OF STRENGTH TO U.S. BANK, INCLUDING TAKING STEPS TO ENSURE U.S. BANK COMPLIES WITH ANY
SUPERVISORY ACTION TAKEN AGAINST U.S. BANK BY ITS REGULATORS.regulatory · block 4PDF pages 48–50
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
UBIS AND FINRA ENTERED INTO AN AWC ON JUNE 6, 2023. UBIS WAS CENSURED AND FINED $75,000.
Other filed details
Description of allegations — filed text
FINRA ALLEGES THAT FROM 2/2020 THROUGH 5/2021, UNIONBANC INVESTMENT SERVICES (UBIS) VIOLATED FINRA RULE 2010 AND FINRA IM-13000 BY FAILING TO COMPLY WITH ITS DISCOVERY OBLIGATIONS PRIOR TO THE HEARING ON THE MERITS DURING AN ARBITRATION FILED AGAINST UBIS IN FINRA'S DISPUTE RESOLUTION FORUM FOR CLAIMS ARISING OUT OF THE TERMINATION OF A FORMER UBIS REGISTERED REPRESENTATIVE. FINRA NOTES THAT THE ARBITRATION PANEL AWARDED CLAIMANT SANCTIONS AND ATTORNEY FEES OF $35,000, WHICH UBIS SUBSEQUENTLY PAID. CLAIMANT'S SUBSTANTIVE ARBITRATION CLAIMS WERE ULTIMATELY DENIED AFTER THE HEARING. UBIS NEITHER ADMITTED NOR DENIED THE ALLEGATIONS.
Sanction detail — filed text
UBIS WAS CENSURED AND FINED $75,000. NO PORTION OF THE PENALTY WAS WAIVED.
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) FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 06/06/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2022073798101 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): FINRA ALLEGES THAT FROM 2/2020 THROUGH 5/2021, UNIONBANC INVESTMENT SERVICES (UBIS) VIOLATED FINRA RULE 2010 AND FINRA IM-13000 BY FAILING TO COMPLY WITH ITS DISCOVERY OBLIGATIONS PRIOR TO THE HEARING ON THE MERITS DURING AN ARBITRATION FILED AGAINST UBIS IN FINRA'S DISPUTE RESOLUTION FORUM FOR CLAIMS ARISING OUT OF THE TERMINATION OF A FORMER UBIS REGISTERED REPRESENTATIVE. FINRA NOTES THAT THE ARBITRATION PANEL AWARDED CLAIMANT SANCTIONS AND ATTORNEY FEES OF $35,000, WHICH UBIS SUBSEQUENTLY PAID. CLAIMANT'S SUBSTANTIVE ARBITRATION CLAIMS WERE ULTIMATELY DENIED AFTER THE HEARING. UBIS NEITHER ADMITTED NOR DENIED THE ALLEGATIONS. 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): 06/06/2023 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: $ 75,000.00 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: UBIS WAS CENSURED AND FINED $75,000. NO PORTION OF THE 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). UBIS AND FINRA ENTERED INTO AN AWC ON JUNE 6, 2023. UBIS WAS CENSURED AND FINED $75,000.
regulatory · block 5PDF pages 50–52
- Regulator name — filed text
- CALIFORNIA DEPARTMENT OF INSURANCE
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
TO SETTLE THE MATTER, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE CDI, UBIS PAID A FINE AND COSTS OF $5268.00 AND AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22, 2023. THE SPECIAL NOTICE OF DEFENSE WAS APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023. THE TERMS INCLUDED ACCEPTANCE OF A RESTRICTED LICENSE AND UNDERTAKING NOT TO VIOLATE THE LAW.
Other filed details
Description of allegations — filed text
THE CALIFORNIA DEPARTMENT OF INSURANCE ("CDI") ISSUED A RESTRICTED LICENSE TO UBIS ON JULY 5, 2023, TO SELL INSURANCE IN THE STATE OF CALIFORNIA. THE RESTRICTION WAS IMPOSED PURSUANT TO CALIFORNIA INSURANCE CODE ("CIC") SECTION 1742 IN LIEU OF DENIAL OF UBIS'S APPLICATION. THE CDI TOOK THIS ACTION AFTER DETERMINING THAT FACTS ALLEGED IN FINRA DISCIPLINARY ACTIONS DATED DECEMBER 23, 2013, MAY 5, 2021, AND JUNE 6, 2023, AND FAILURE TO DISCLOSE THE DECEMBER 23, 2013 FINRA DISCIPLINARY ACTION IN ITS LICENSE APPLICATION WOULD HAVE CONSTITUTED GROUNDS FOR DENIAL OF UBIS'S APPLICATION FOR AN UNRESTRICTED LICENSE TO SELL LIFE INSURANCE PURSUANT TO CIC SECTION 1668(E). THE CDI ALSO DETERMINED THAT ITS ALLEGATION THAT UBIS KNOWINGLY OR WILLFULLY FAILED TO DISCLOSE THE DECEMBER 23, 2013 FINRA DISCIPLINARY ACTION IN ITS LICENSE APPLICATION CONSTITUTED GROUNDS FOR DENIAL OF ITS APPLICATION PURSUANT TO CIC SECTION 1668(H). TO SETTLE THE MATTER, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE CDI, UBIS PAID A FINE AND COSTS OF $5,268.00 AND AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22, 2023. THE SPECIAL NOTICE OF DEFENSE WAS APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023.
Sanction detail — filed text
UBIS PAID A FINE AND COSTS OF $5268.00 AND AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22, 2023. THE SPECIAL NOTICE OF DEFENSE WAS APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023.
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)
CALIFORNIA DEPARTMENT OF INSURANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DENIAL; UNDERTAKING
3.
Date Initiated (MM/DD/YYYY):
07/05/2023
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:
No Product
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CALIFORNIA DEPARTMENT OF INSURANCE ("CDI") ISSUED A RESTRICTED LICENSE TO UBIS ON JULY 5, 2023, TO SELL INSURANCE IN THE STATE OF
CALIFORNIA. THE RESTRICTION WAS IMPOSED PURSUANT TO CALIFORNIA INSURANCE CODE ("CIC") SECTION 1742 IN LIEU OF DENIAL OF UBIS'S
APPLICATION. THE CDI TOOK THIS ACTION AFTER DETERMINING THAT FACTS ALLEGED IN FINRA DISCIPLINARY ACTIONS DATED DECEMBER 23, 2013,
MAY 5, 2021, AND JUNE 6, 2023, AND FAILURE TO DISCLOSE THE DECEMBER 23, 2013 FINRA DISCIPLINARY ACTION IN ITS LICENSE APPLICATION
WOULD HAVE CONSTITUTED GROUNDS FOR DENIAL OF UBIS'S APPLICATION FOR AN UNRESTRICTED LICENSE TO SELL LIFE INSURANCE PURSUANT TO
CIC SECTION 1668(E). THE CDI ALSO DETERMINED THAT ITS ALLEGATION THAT UBIS KNOWINGLY OR WILLFULLY FAILED TO DISCLOSE THE DECEMBER
23, 2013 FINRA DISCIPLINARY ACTION IN ITS LICENSE APPLICATION CONSTITUTED GROUNDS FOR DENIAL OF ITS APPLICATION PURSUANT TO CIC
SECTION 1668(H). TO SETTLE THE MATTER, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE CDI, UBIS PAID A FINE AND COSTS
OF $5,268.00 AND AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22, 2023. THE SPECIAL NOTICE OF
DEFENSE WAS APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023.
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):
07/05/2023
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 5,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
RESTRICTED LICENSE ISSUED.
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:
UBIS PAID A FINE AND COSTS OF $5268.00 AND AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22,
2023. THE SPECIAL NOTICE OF DEFENSE WAS APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023.
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).
TO SETTLE THE MATTER, AND WITHOUT ADMITTING OR DENYING THE ALLEGATIONS MADE BY THE CDI, UBIS PAID A FINE AND COSTS OF $5268.00 AND
AGREED TO THE TERMS OF A SPECIAL NOTICE OF DEFENSE SUBMITTED TO THE CDI ON JUNE 22, 2023. THE SPECIAL NOTICE OF DEFENSE WAS
APPROVED AND AGREED TO BY THE CDI ON JULY 5, 2023. THE TERMS INCLUDED ACCEPTANCE OF A RESTRICTED LICENSE AND UNDERTAKING NOT TO
VIOLATE THE LAW.regulatory · block 6U.S. BANCORP INVESTMENTS, INC.PDF pages 52–54
- Advisory affiliate name — filed text
- U.S. BANCORP INVESTMENTS, INC.
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY
- Monetary/Fine Amount — filed text
- $ 500,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON AUGUST 12, 2025, U.S. BANCORP INVESTMENTS CONSENTED TO THE TERMS OF AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRA. PURSUANT TO THAT AGREEMENT, ON AUGUST 22, 2025, USBI ACCEPTED THE IMPOSITION OF A CENSURE AND A $500,000 FINE, WHICH WAS PAID ON SEPTEMBER 3, 2025.
Other filed details
Description of allegations — filed text
WHEN DETERMINING WHETHER TO FILE SUSPICIOUS ACTIVITY REPORTS (SARS), U.S. BANCORP INVESTMENTS (USBI), THROUGH ITS PARENT COMPANY'S ENTERPRISE-WIDE SAR FILING UNIT, INCORRECTLY USED A $25,000 MONETARY THRESHOLD APPLICABLE TO BANKS RATHER THAN THE $5,000 THRESHOLD APPLICABLE TO BROKER-DEALERS AND, AS A RESULT, DID NOT TIMELY FILE 42 SARS BETWEEN APRIL 2020 AND AUGUST 2023. USBI THUS FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS IN VIOLATION OF FINRA RULES 3310(A) AND 2010. USBI IS CENSURED AND FINED $500,000.
Sanction detail — filed text
USBI WAS CENSURED AND ORDERED TO PAY A $500,000 FINE. THE FINE WAS PAID ON SEPTEMBER 3, 2025.
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: 17868 This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANCORP INVESTMENTS, 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) FINANCIAL INDUSTRY REGULATORY AUTHORITY 2. Principal Sanction: Censure Other Sanctions: CIVIL AND ADMINISTRATIVE PENALTIES/FINES 3. Date Initiated (MM/DD/YYYY): 05/16/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023079913301 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): WHEN DETERMINING WHETHER TO FILE SUSPICIOUS ACTIVITY REPORTS (SARS), U.S. BANCORP INVESTMENTS (USBI), THROUGH ITS PARENT COMPANY'S ENTERPRISE-WIDE SAR FILING UNIT, INCORRECTLY USED A $25,000 MONETARY THRESHOLD APPLICABLE TO BANKS RATHER THAN THE $5,000 THRESHOLD APPLICABLE TO BROKER-DEALERS AND, AS A RESULT, DID NOT TIMELY FILE 42 SARS BETWEEN APRIL 2020 AND AUGUST 2023. USBI THUS FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS IN VIOLATION OF FINRA RULES 3310(A) AND 2010. USBI IS CENSURED AND FINED $500,000. 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): 08/22/2025 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: $ 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: USBI WAS CENSURED AND ORDERED TO PAY A $500,000 FINE. THE FINE WAS PAID ON SEPTEMBER 3, 2025. 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 12, 2025, U.S. BANCORP INVESTMENTS CONSENTED TO THE TERMS OF AN ACCEPTANCE, WAIVER AND CONSENT WITH FINRA. PURSUANT TO THAT AGREEMENT, ON AUGUST 22, 2025, USBI ACCEPTED THE IMPOSITION OF A CENSURE AND A $500,000 FINE, WHICH WAS PAID ON SEPTEMBER 3, 2025.
Show 2 more source blocks
regulatory · block 7U.S. BANCORP INVESTMENTS, INC.PDF pages 54–56
- Advisory affiliate name — filed text
- U.S. BANCORP INVESTMENTS, INC.
- Regulator name — filed text
- FINRA
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONTEND SALES CHARGE BUT WERE INSTEAD SOLD CLASS B OR C SHARES WITH BACKEND SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS STATED THAT THESE SALES DISADVANTAGED THE CUSTOMERS BY CAUSING THEM TO PAY HIGHER FEES THAN THEY WERE REQUIRED TO PAY. THE FIRM CONDUCTED AN INTERNAL REVIEW AND BASED ON THEIR FINDINGS SELF-REPORTED TO FINRA THAT CERTAIN CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST ITS FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. THE FINDINGS FURTHER STATED THAT THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS AND FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY WERE NOT APPLIED.
Sanction detail — filed text
THE FIRM WAS CENSURED AND ORDERED TO PROVIDE RESTITUTION TO ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS IN THE AMOUNT $100,401 (THE AMOUNT THE CUSTOMERS WERE OVERCHARGED PLUS INTEREST).
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: 17868 This advisory affiliate is a Firm an Individual Registered: Yes No Name: U.S. BANCORP INVESTMENTS, 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) FINRA 2. Principal Sanction: Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/20/2016 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2015046401801 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DISADVANTAGED CERTAIN RETIREMENT PLAN CUSTOMERS THAT WERE ELIGIBLE TO PURCHASE CLASS A SHARES IN CERTAIN MUTUAL FUNDS WITHOUT A FRONTEND SALES CHARGE BUT WERE INSTEAD SOLD CLASS B OR C SHARES WITH BACKEND SALES CHARGES AND HIGHER ONGOING FEES AND EXPENSES. THE FINDINGS STATED THAT THESE SALES DISADVANTAGED THE CUSTOMERS BY CAUSING THEM TO PAY HIGHER FEES THAN THEY WERE REQUIRED TO PAY. THE FIRM CONDUCTED AN INTERNAL REVIEW AND BASED ON THEIR FINDINGS SELF-REPORTED TO FINRA THAT CERTAIN CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE APPLICATION OF SALES CHARGE WAIVERS TO ELIGIBLE MUTUAL FUND SALES. THE FIRM RELIED ON ITS FINANCIAL ADVISORS TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS BUT FAILED TO MAINTAIN ADEQUATE WRITTEN POLICIES OR PROCEDURES TO ASSIST ITS FINANCIAL ADVISORS IN MAKING THIS DETERMINATION. THE FINDINGS FURTHER STATED THAT THE FIRM FAILED TO ADEQUATELY NOTIFY AND TRAIN ITS FINANCIAL ADVISORS REGARDING THE AVAILABILITY OF MUTUAL FUND SALES CHARGE WAIVERS AND FAILED TO ADOPT ADEQUATE CONTROLS TO DETECT INSTANCES IN WHICH THEY WERE NOT APPLIED. 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): 04/20/2016 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: $ 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 FIRM WAS CENSURED AND ORDERED TO PROVIDE RESTITUTION TO ELIGIBLE CUSTOMERS WHO QUALIFIED FOR, BUT DID NOT RECEIVE, APPLICABLE MUTUAL FUND SALES CHARGE WAIVERS IN THE AMOUNT $100,401 (THE AMOUNT THE CUSTOMERS WERE OVERCHARGED PLUS INTEREST). 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 8U.S. BANCORP INVESTMENTS, INC.PDF pages 56–58
- Advisory affiliate name — filed text
- U.S. BANCORP INVESTMENTS, INC.
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 18,392,441.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
RESPONDENT HAS UNDERTAKEN TO: A. WITHIN 30 DAYS OF THE ENTRY OF THE ORDER, NOTIFY AFFECTED INVESTORS . . . (II) WITHIN TEN (10) DAYS OF THE ENTRY OF THIS ORDER, RESPONDENT SHALL DEPOSIT $15,992,441 (THE "DISTRIBUTION FUND") INTO AN ESCROW ACCOUNT.
Other filed details
Description of allegations — filed text
SEC ALLEGED THE FOLLOWING VIOLATIONS: INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") SECTIONS 206(2) AND 206(4), AND RULE 206(4)-7 USBI DID NOT: *SEEK BEST EXECUTION FOR CLIENT MUTUAL FUND TRANSACTIONS BY RECOMMENDING SHARE CLASSES THAT CHARGED 12B- 1 AND SHAREHOLDER SERVICING FEES WHEN A SHARE CLASS WITH MORE FAVORABLE VALUE WAS AVAILABLE. *ADEQUATELY DISCLOSE THE CONFLICTS OF INTEREST RELATED TO (A) RECEIPT OF 12B-1 FEES AND SHAREHOLDER SERVICING FEES AND (B) SELECTION OF MUTUAL FUND SHARE CLASSES THAT PAY SUCH FEES. *ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER RELATED TO DISCLOSURE OF CONFLICTS OF INTEREST UNDER MUTUAL FUND SHARE CLASS SELECTION AND MAKING MUTUAL FUND SHARE CLASS RECOMMENDATIONS THAT WERE IN THE CLIENT'S BEST INTEREST. THIS DISCIPLINARY ACTION FROM THE SEC IS RELATED TO OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND RECEIPT OF SHAREHOLDER SERVICING AND 12B-1 FEES DURING THE PERIOD OF OCTOBER 2012 THROUGH NOVEMBER 2017. DURING THIS TIME, WE RECOMMENDED AND PURCHASED MUTUAL FUND SHARES FOR CLIENTS THAT CHARGED 12B-1 AND SHAREHOLDER SERVICING FEES INSTEAD OF THE LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE. IN ADDITION, DISCLOSURE OF THE CONFLICT OF INTEREST RELATED TO THESE FEES AND OUR SELECTION OF THESE SHARE CLASSES WAS INADEQUATE. WE BEGAN REBATING 12B-1 FEES ON ALL NON-QUALIFIED ACCOUNTS BEGINNING IN FEBRUARY 2016 (WE WERE ALREADY REBATING 12B-1 FEES IN QUALIFIED ACCOUNTS), AND IN DECEMBER 2017 WE INITIATED THE PROCESS OF CONVERTING EXISTING MUTUAL FUND POSITIONS TO THE LOWEST- COST SHARE CLASS AVAILABLE ON OUR PLATFORM. IN MARCH 2018 WE ENHANCED OUR DISCLOSURE LANGUAGE RELATED TO OUR RECEIPT OF 12B-1 FEES AND SHAREHOLDER SERVICING FEES. ALL IMPACTED ADVISORY CLIENTS WILL BE NOTIFIED OF THE SETTLEMENT TERMS WITHIN 30 DAYS OF THE SEC ORDER. WE SUBMITTED AN OFFER OF SETTLEMENT TO THE SEC AND AGREED TO THE FOLLOWING SANCTIONS UNDER THE SEC ORDER DATED JUNE 1, 2020: *CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. *CENSURE. *PAY DISGORGEMENT
Sanction detail — filed text
*CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. *CENSURE. *PAY A CIVIL PENALTY OF $2.4 MILLION TO THE SEC.
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:
17868
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
U.S. BANCORP INVESTMENTS,
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)
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
CENSURE CIVIL AND ADMINISTRATIVE PENALT(IES) / FINES DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY):
06/01/2020
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19818
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):
SEC ALLEGED THE FOLLOWING VIOLATIONS: INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") SECTIONS 206(2) AND 206(4), AND RULE
206(4)-7 USBI DID NOT: *SEEK BEST EXECUTION FOR CLIENT MUTUAL FUND TRANSACTIONS BY RECOMMENDING SHARE CLASSES THAT CHARGED 12B-
1 AND SHAREHOLDER SERVICING FEES WHEN A SHARE CLASS WITH MORE FAVORABLE VALUE WAS AVAILABLE. *ADEQUATELY DISCLOSE THE
CONFLICTS OF INTEREST RELATED TO (A) RECEIPT OF 12B-1 FEES AND SHAREHOLDER SERVICING FEES AND (B) SELECTION OF MUTUAL FUND SHARE
CLASSES THAT PAY SUCH FEES. *ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS
ACT AND THE RULES THEREUNDER RELATED TO DISCLOSURE OF CONFLICTS OF INTEREST UNDER MUTUAL FUND SHARE CLASS SELECTION AND MAKING
MUTUAL FUND SHARE CLASS RECOMMENDATIONS THAT WERE IN THE CLIENT'S BEST INTEREST. THIS DISCIPLINARY ACTION FROM THE SEC IS RELATED
TO OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND RECEIPT OF SHAREHOLDER SERVICING AND 12B-1 FEES DURING THE PERIOD OF
OCTOBER 2012 THROUGH NOVEMBER 2017. DURING THIS TIME, WE RECOMMENDED AND PURCHASED MUTUAL FUND SHARES FOR CLIENTS THAT
CHARGED 12B-1 AND SHAREHOLDER SERVICING FEES INSTEAD OF THE LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE. IN
ADDITION, DISCLOSURE OF THE CONFLICT OF INTEREST RELATED TO THESE FEES AND OUR SELECTION OF THESE SHARE CLASSES WAS INADEQUATE.
WE BEGAN REBATING 12B-1 FEES ON ALL NON-QUALIFIED ACCOUNTS BEGINNING IN FEBRUARY 2016 (WE WERE ALREADY REBATING 12B-1 FEES IN
QUALIFIED ACCOUNTS), AND IN DECEMBER 2017 WE INITIATED THE PROCESS OF CONVERTING EXISTING MUTUAL FUND POSITIONS TO THE LOWEST-
COST SHARE CLASS AVAILABLE ON OUR PLATFORM. IN MARCH 2018 WE ENHANCED OUR DISCLOSURE LANGUAGE RELATED TO OUR RECEIPT OF 12B-1
FEES AND SHAREHOLDER SERVICING FEES. ALL IMPACTED ADVISORY CLIENTS WILL BE NOTIFIED OF THE SETTLEMENT TERMS WITHIN 30 DAYS OF THE
SEC ORDER. WE SUBMITTED AN OFFER OF SETTLEMENT TO THE SEC AND AGREED TO THE FOLLOWING SANCTIONS UNDER THE SEC ORDER DATED JUNE
1, 2020: *CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE
206(4)-7 THEREUNDER. *CENSURE. *PAY DISGORGEMENT
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):
06/01/2020
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: $ 18,392,441.00
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:
*CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE
206(4)-7 THEREUNDER. *CENSURE. *PAY A CIVIL PENALTY OF $2.4 MILLION TO THE SEC.
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).
RESPONDENT HAS UNDERTAKEN TO: A. WITHIN 30 DAYS OF THE ENTRY OF THE ORDER, NOTIFY AFFECTED INVESTORS . . . (II) WITHIN TEN (10) DAYS
OF THE ENTRY OF THIS ORDER, RESPONDENT SHALL DEPOSIT $15,992,441 (THE "DISTRIBUTION FUND") INTO AN ESCROW ACCOUNT.* 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.