Firm profile

Coordinated Capital Securities, Inc..

FORT ATKINSON, WICRD 14762Registration Status: ApprovedEffective since August 31, 2017SEC # 801-111070Latest ADV June 25, 2026

Coordinated Capital Securities, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Fort Atkinson, WI. Its latest Form ADV filing, dated June 25, 2026, reports $137M in regulatory assets under management, 31 employees, 11 offices, and 186 accounts.

Assets Under Management
$137M
Employees
31
Offices
11 offices
Total Clients
186

Associated firm names

7 names listed
  • CCS OF WI
  • COORDINATED CAPITAL SECURITIES,INC.
  • COORDINATED CAPITAL SECURITIES, INC.
  • COORDINATED CAPITAL SECURITIES OF WISCONSIN, INC.

Leadership

2 roles identified
CEOMari Jo Buechner
CCOSara Danielle Williams

Advisory services offered

5 types reported
Financial Planning Services
Pension consulting services
Portfolio management for businesses

Fee models offered

3 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

FORT ATKINSON, Wisconsin, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Wisconsin

FORT ATKINSONPrimary office · KENOSHA · BROOKFIELD · MONONA

Ohio

STRONGSVILLE · CINCINNATI

Tennessee

MEMPHIS

7 office records listed · 11 total offices reported. 4 additional office addresses are undisclosed and are not mapped. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$137Mas of June 25, 2026
Discretionary61.5%
$84M
62% of total RAUM61.5%
Non-discretionary38.5%
$53M
38% of total RAUM38.5%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 79.0% of total clients.
Top client categories% of clientsClients
1
Individuals
79.0%
147
2
HNWI
21.0%
39
Categories with <5 clients
Corporations or other businesses not listed above<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$137M
Total Accounts186
10Y AUM Change+$23M (+19.7%)

Private Funds

Private funds reported by Coordinated Capital Securities, Inc..

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees31
Clients per Employee6:1
10Y Employee Change-34 (-52.3%)

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%
COORDINATED CAPITAL HOLDINGS, INC.Direct owner · Schedule AInterest in COORDINATED CAPITAL SECURITIES, INC.
75%+
MARI JO BUECHNERIndirect owner · Schedule BInterest in COORDINATED CAPITAL HOLDINGS, INC.
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 Coordinated Capital Securities, Inc...

Reported ownership and control details

Form ADV · Filing date 2026-06-25 · Schedules A and B

5 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1MARI JO BUECHNERCHIEF EXECUTIVE OFFICER, PRESIDENTIndividualCOORDINATED CAPITAL SECURITIES, INC.Less than 5%Code NAYesCHIEF EXECUTIVE OFFICER, PRESIDENT03/2002Schedule APDF page 24
2COORDINATED CAPITAL HOLDINGS, INC.HOLDING COMPANYDomestic entityCOORDINATED CAPITAL SECURITIES, INC.75% or moreCode EYesHOLDING COMPANY11/1992Schedule APDF page 24
3TRACY NAIOMA WILLIAMSVICE PRESIDENTIndividualCOORDINATED CAPITAL SECURITIES, INC.Less than 5%Code NAYesVICE PRESIDENT04/2014Schedule APDF page 24
4SARA DANIELLE WILLIAMSCHIEF COMPLIANCE OFFICERIndividualCOORDINATED CAPITAL SECURITIES, INC.Less than 5%Code NAYesCHIEF COMPLIANCE OFFICER01/2022Schedule APDF page 24
5MARI JO BUECHNEROWNER OF HOLDING COMPANYIndividualCOORDINATED CAPITAL HOLDINGS, INC.75% or moreCode EYesOWNER OF HOLDING COMPANY06/2007Schedule BPDF page 25

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 6/25/2026 12:17:17 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 actions5 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
  • 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?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 2 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 25–27
Regulator name — filed text
U.S. SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 581,961.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTERST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS. THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, THE FIRM HAS TAKEN THE FOLLOWING ACTIONS: UPDATED FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER-COST SHARE CLASS; IDENTIFIED CLIENTS ELIGIBLE FOR REIMBURSEMENT OF THE 12B-1 FEES PAID DURING THE RELEVANT PERIOD.
Other filed details

Description of allegations — filed text

THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12-B1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES.

Sanction detail — filed text

THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961
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: 
THE ORDER ALSO INSTRUCTS US TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, A CIVIL PENALTY, CENSURE AND TO COMPLETE CERTAIN UNDERTAKINGS AS DEFINED BY THE
ORDER.
3.
Date Initiated (MM/DD/YYYY): 
09/17/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20012
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):
THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE
CLASSES THAT CHARGED 12-B1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY
DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED
ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY
DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE
CLASS SELECTION PRACTICES.
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):
09/17/2020
 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: $ 581,961.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE ORDER ALSO REQUIRED THE FIRM TO COMPLETE CERTAIN UNDERTAKINGS AS DEFINED BY THE ORDER.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.).
If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been
satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate,
date paid and if any portion of penalty was waived: 
THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961
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).
AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER,
AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTERST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS.
THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, THE FIRM HAS TAKEN THE FOLLOWING ACTIONS: UPDATED
FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER-COST SHARE CLASS; IDENTIFIED CLIENTS
ELIGIBLE FOR REIMBURSEMENT OF THE 12B-1 FEES PAID DURING THE RELEVANT PERIOD.
regulatory · block 2PDF pages 27–29
Regulator name — filed text
US SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 581,961.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER, AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS. THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, CCS HAS TAKEN THE FOLLOWING ACTIONS: UPDATED FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER COST CHARE CLASS; IDENTIFIED CLIENTS ELIGIBLE FOR REIMBURSEMENT OF THE 12-B1 FEES PAID DURING THE RELEVANT PERIOD.
Other filed details

Description of allegations — filed text

THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES.

Sanction detail — filed text

THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961
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) 
US SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
THE ORDER ALSO INSTRUCTS US TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, A CIVIL PENALTY, CENSURE AND TO COMPLETE CERTAIN UNDERTAKINGS AS DEFINED BY THE
ORDER.
3.
Date Initiated (MM/DD/YYYY): 
09/17/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20012
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):
THE SEC'S ORDER FINDS THAT FROM JANUARY 1, 2014 THROUGH DECEMBER 2018 THE FIRM PURCHASED, RECOMMENDED OR HELD FOR ADVISORY CLIENTS MUTUAL FUND SHARE
CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS THAT WERE AVAILABLE TO THOSE CLIENTS, AND DID NOT ADEQUATELY
DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO THE SELECTION OF THESE SHARE CLASSES. THE ORDER ALSO FINDS THAT THE FIRM VIOLATED
ITS DUTY TO SEEK BEST EXECUTION FOR THOSE TRANSACTIONS AND THAT THE FIRM FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY
DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE
CLASS SELECTION PRACTICES.
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):
09/17/2020
 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: $ 581,961.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE ORDER ALSO REQUIRED FIRM TO COMPLETE CERTAIN UNDERTAKINGS AS DEFINED BY THE ORDER.

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.).
If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been
satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate,
date paid and if any portion of penalty was waived: 
THE ORDER INSTRUCTS THE FIRM TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST OF $511,961 AND A CIVIL PENALTY OF $70,000 TOTALING $581,961
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).
AS PART OF THE SETTLEMENT TERMS OF THE ORDER, THE SEC FOUND THAT THE FIRM WILLFULLY VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER,
AND ORDERED THE FIRM TO PAY DISGORGEMENT, PREJUDGEMENT INTEREST, A CIVIL PENALTY, TO COMPENSATE AFFECTED INVESTORS AND TO COMPLETE CERTAIN UNDERTAKINGS.
THE FIRM CONSENTED TO THE ENTRY OF THE ORDER WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS. AS A RESULT, CCS HAS TAKEN THE FOLLOWING ACTIONS: UPDATED
FORM ADV DISCLOSURES; UPDATED COMPANY POLICIES AND PROCEDURES; IDENTIFIED CLIENTS ELIGIBLE TO CONVERT TO A LOWER COST CHARE CLASS; IDENTIFIED CLIENTS
ELIGIBLE FOR REIMBURSEMENT OF THE 12-B1 FEES PAID DURING THE RELEVANT PERIOD.

* 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.