Carnegie Investment Counsel

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

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE

No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
PRIVATE PLAINTIFF (JAMES CHASTAIN, ET AL)
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought: 
ORDER CONFIRMING A FINAL ARBITRATION AWARD ISSUED BY THE AMERICAN ARBITRATION ASSOCIATION (AAA)
3.
Filing Date of Court Action (MM/DD/YYYY):
12/30/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
PRIVATE EQUITY FUNDS
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
CUYAHOGA COUNTY (CONFIRMATION NBR. 3713968; AAA CASE NO. 01-22-0003-8217)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE PETITIONERS PETITIONED THE COURT PURSUANT TO THE OHIO ARBITRATION ACT, FOR AN ORDER CONFIRMING A FINAL ARBITRATION AWARD
ISSUED BY THE AMERICAN ARBITRATION ASSOCIATION (AAA) ON 12-19-2025 BETWEEN THE PETITIONERS AND CARNEGIE CAPITAL ASSET
MANAGEMENT, LLC (DBA CARNEGIE INVESTMENT COUNSEL) FOR ENTRY OF JUDGMENT CONSISTENT WITH THAT AWARD. THIS ARBITRATION CASE WAS
AN OLDER MATTER INVOLVING A LIMITED NUMBER OF ACCOUNTS TIED TO A FIRM CARNEGIE ACQUIRED IN 2018. THE INVESTMENTS IN QUESTION
WERE MADE BEFORE CARNEGIE'S INVOLVEMENT, AND CARNEGIE DID NOT CREATE OR RECOMMEND THOSE INVESTMENTS. THE DISPUTE CENTERED ON
CARNEGIE'S ROLE WITH LEGACY CLIENTS AND THE LEGACY HOLDINGS FOLLOWING THE ACQUISITION.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled

12. Resolution Date (MM/DD/YYYY): 
12/19/2025
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
ARBITRATION SETTLEMENT (COMPENSATORY DAMAGES): $2,324,000 PAID ON 02-10-2026
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
THIS WAS AN OLDER MATTER INVOLVING A LIMITED NUMBER OF ACCOUNTS TIED TO A FIRM CARNEGIE ACQUIRED IN 2018. THE INVESTMENTS IN
QUESTION WERE MADE BEFORE CARNEGIE'S INVOLVEMENT, AND CARNEGIE DID NOT CREATE OR RECOMMEND THOSE INVESTMENTS. THE DISPUTE
CENTERED ON CARNEGIE'S ROLE WITH LEGACY CLIENTS AND THE LEGACY HOLDINGS FOLLOWING THE ACQUISITION. CARNEGIE KNEW SOME
INHERITED CLIENTS HELD OLDER PRIVATE INVESTMENTS FROM BEFORE THE ACQUISITION, WHICH CARNEGIE ENCOURAGED CLIENTS TO REDEEM AND
EXIT. WHAT WAS NOT KNOWN AT THE TIME WAS THAT THOSE INVESTMENTS WERE TIED TO FRAUD, WHICH RESULTED IN FINANCIALLY IMPACTING
SOME OF THOSE CLIENTS. THIS ONLY BECAME FULLY CLEAR LATER THROUGH LAW ENFORCEMENT AND COURT PROCEEDINGS. THIS ARBITRATION AND
JUDGMENT MATTER INVOLVED A DISAGREEMENT OVER WHAT MORE CARNEGIE SHOULD HAVE DONE AFTER INHERITING CERTAIN CLIENT
RELATIONSHIPS. CARNEGIE DID NOT CREATE THE UNDERLYING INVESTMENTS, AND OUR FOCUS THEN AND NOW REMAINS ON SERVING CLIENTS
CAREFULLY AND RESPONSIBLY.