Firm profile

Verus Capital Partners, LLC

SCOTTSDALE, AZCRD 151568Registration Status: ApprovedEffective since January 2, 2014SEC # 801-78989Latest ADV March 31, 2026

Verus Capital Partners, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in Scottsdale, AZ. Its latest Form ADV filing, dated March 31, 2026, reports $2.3B in regulatory assets under management, 68 employees, 32 offices, and 7,289 accounts.

Assets Under Management
$2.3B
Employees
68
Offices
32 offices
Total Clients
5,642

Associated firm names

49 names listed
  • 3 RIVERS FINANCIAL GROUP
  • WILLIAM F. SULLIVAN FINANCIAL SERVICES
  • WANN WEALTH PARTNERS, LLC
  • WANN FINANCIAL SERVICES

Leadership

1 roles identified
CCOStephen D. Bull

Advisory services offered

7 types reported
Educational seminars/workshops
Financial Planning Services
Pension consulting services

Fee models offered

3 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

SCOTTSDALE, Arizona, United States

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Primary office regionOther reported regions

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

Arizona

SCOTTSDALEPrimary office · CHANDLER · PHOENIX · SCOTSDALE · GILBERT

Alabama

MADISON

California

PASADENA · OCEANSIDE · HERMOSA BEACH · NORTHRIDGE · SAN DIEGO · ENCINO · ESCONDIDO · ONTARIO · VENTURA

Colorado

LITTLETON

Maryland

GLENELG

Massachusetts

MARLBOROUGH

Mississippi

OCEAN SPRINGS

Montana

GREAT FALLS

Oklahoma

POTEAU · HEAVENER

Tennessee

FAYETTEVILLE · SPRING HILL

Virginia

SOUTH BOSTON

27 office records listed · 32 total offices reported. 7 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$2.3Bas of March 31, 2026
Discretionary100.0%
$2.3B
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 82.6% of total clients.
Top client categories% of clientsClients
1
Individuals
82.6%
4,660
2
Pension Plans
8.5%
482
3
HNWI
7.6%
426
4
Corporations
1.0%
57
5
Charitable
0.3%
17

Assets under management Growth by Quarter

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

Total AUM$2.3B
Total Accounts7,289
10Y AUM Change+$2.0B (+685.8%)

Private Funds

Private funds reported by Verus Capital Partners, LLC

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Employee Growth by Quarter

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

Total Employees68
Clients per Employee83:1
10Y Employee Change+32 (+88.9%)

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%
ONE SZ, LLCDirect owner · Schedule AInterest in VERUS CAPITAL PARTNERS, LLC
75%+
STEPHEN DALE BULLDirect owner · Schedule AInterest in VERUS CAPITAL PARTNERS, LLC
< 5%
ZACHARY TAYLOR MASONDirect owner · Schedule AInterest in VERUS CAPITAL PARTNERS, LLC
< 5%
SQUIRM STEEL LLCIndirect owner · Schedule BInterest in ONE SZ, LLC
50% to < 75%
MASON CAPITAL LLCIndirect owner · Schedule BInterest in ONE SZ, LLC
50% to < 75%
ZACHARY TAYLOR MASONIndirect owner · Schedule BInterest in MASON CAPITAL LLC
50% to < 75%
STEPHEN DALE BULLIndirect owner · Schedule BInterest in SQUIRM STEEL LLC
50% to < 75%
Kristin Rachelle SnyderIndirect owner · Schedule BInterest in MASON CAPITAL LLC
50% to < 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 Verus Capital Partners, LLC.

Reported ownership and control details

Form ADV · Filing date 2026-03-31 · Schedules A and B

8 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1STEPHEN DALE BULLSENIOR PARTNER AND CHIEF COMPLIANCE OFFICERIndividualVERUS CAPITAL PARTNERS, LLCLess than 5%Code NAYesSENIOR PARTNER AND CHIEF COMPLIANCE OFFICER09/2009Schedule APDF page 45
2ONE SZ, LLCMEMBERDomestic entityVERUS CAPITAL PARTNERS, LLC75% or moreCode EYesMEMBER01/2022Schedule APDF page 45
3ZACHARY TAYLOR MASONMANAGING PARTNERIndividualVERUS CAPITAL PARTNERS, LLCLess than 5%Code NAYesMANAGING PARTNER10/2020Schedule APDF page 45
4SQUIRM STEEL LLCMEMBERDomestic entityONE SZ, LLC50% to less than 75%Code DYesMEMBER01/2022Schedule BPDF page 46
5MASON CAPITAL LLCMEMBERDomestic entityONE SZ, LLC50% to less than 75%Code DYesMEMBER01/2022Schedule BPDF page 46
6ZACHARY TAYLOR MASONMEMBERIndividualMASON CAPITAL LLC50% to less than 75%Code DYesMEMBER01/2022Schedule BPDF page 46
7STEPHEN DALE BULLMEMBERIndividualSQUIRM STEEL LLC50% to less than 75%Code DYesMEMBER01/2022Schedule BPDF page 46
8Kristin Rachelle SnyderMEMBERIndividualMASON CAPITAL LLC50% to less than 75%Code DYesMEMBER01/2022Schedule BPDF page 46

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 3/31/2026 4:45:08 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 none of the events below involve the firm or its supervised persons.RIA responseNo
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?Yes
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • 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 actions2 Yes3 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?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 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 46–48
Regulator name — filed text
THE SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 45,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

ORDER RECEIVED FROM COMMISSION ON JUNE 7, 2021. VERUS RETAINED A COMPLIANCE CONSULTANT PRIOR TO THE ISSUANCE OF THIS ORDER, AND INTENDS TO FULLY COMPLY WITH ALL SEC SANCTIONS AND REQUIREMENTS SET FORTH IN FILE NO. 3-20361
Other filed details

Description of allegations — filed text

THAT VERUS (THE FIRM) DID NOT DISCLOSE FORGIVABLE LOANS, EITHER IN ITS FILINGS OR OTHERWISE TO CLIENTS. BY FAILING TO DISCLOSE ITS CONFLICTS OF INTEREST COMPLETELY AND ACCURATELY, VERUS VIOLATED SECTION 206(2) OF THE ADVISERS ACT.

Sanction detail — filed text

$45,000 100% LEVIED AGAINST THE FIRM (VERUS CAPITAL), PAID WITHIN 14 DAYS OF ORDER. 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) 
THE SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT.
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
06/07/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-20361 ADMINISTRATIVE PROCEEDING
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):
THAT VERUS (THE FIRM) DID NOT DISCLOSE FORGIVABLE LOANS, EITHER IN ITS FILINGS OR OTHERWISE TO CLIENTS. BY FAILING TO DISCLOSE ITS
CONFLICTS OF INTEREST COMPLETELY AND ACCURATELY, VERUS VIOLATED SECTION 206(2) OF THE ADVISERS 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:
Settled
11. Resolution Date (MM/DD/YYYY):
06/07/2021
 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: $ 45,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT. VERUS SHALL WITHIN 30 DAYS OF THE ISSUANCE OF THE ORDER RETAIN THE
SERVICES OF AN INDEPENDENT COMPLIANCE CONSULTANT. COMPREHENSIVE REVIEW OF VERUS' DISCLOSURES, SUBMIT WRITTEN AND DATED
REPORT, COMMENCE AN ANNUAL REVIEW 365 DAYS FROM THE ISSUANCE OF INDEPENDENT CONSULTANT INITIAL REPORT.
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: 
$45,000 100% LEVIED AGAINST THE FIRM (VERUS CAPITAL), PAID WITHIN 14 DAYS OF ORDER. 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).
ORDER RECEIVED FROM COMMISSION ON JUNE 7, 2021. VERUS RETAINED A COMPLIANCE CONSULTANT PRIOR TO THE ISSUANCE OF THIS ORDER, AND
INTENDS TO FULLY COMPLY WITH ALL SEC SANCTIONS AND REQUIREMENTS SET FORTH IN FILE NO. 3-20361
regulatory · block 2PDF pages 48–50
Regulator name — filed text
MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION
Monetary/Fine Amount — filed text
$ 25,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

THE STATE ALLEGED THE FIRM FAILED TO REGISTER AN IAR IN HIS HOME STATE OF MA AS REQUIRED BY APPLICABLE LAW. THE FIRM HAS REVIEWED ITS REGISTRATION PROCEDURES TO ENSURE THAT THE FIRM IS PROMPTLY NOTICE-FILED AND ITS IARS REGISTERED AS REQUIRED BY APPLICABLE LAW.
Other filed details

Description of allegations — filed text

MASSACHUSETTS ALLEGED THE FIRM'S ADVISORY REPRESENTATIVE HAD A PLACE OF BUSINESS IN MA AND PROVIDED INVESTMENT ADVICE TO MORE THAN FIVE CLIENTS WHO ARE NATURAL PERSONS, AND MORE THAN 10% PERCENT OF WHOSE CLIENTS ARE NATURAL PERSONS WHILE NOT REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE IN MA, CONSTITUTING A VIOLATION OF APPLICABLE LAW.

Sanction detail — filed text

FINE OF $25,000 WAS ASSESSED AGAINST THE FIRM, NOT AGAINST THE IAR. THE FINE WAS PAID IN FULL ON SEPT 2, 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
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) 
MASSACHUSETTS OFFICE OF THE SECRETARY OF THE COMMONWEALTH SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/27/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-2024-00365
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):
MASSACHUSETTS ALLEGED THE FIRM'S ADVISORY REPRESENTATIVE HAD A PLACE OF BUSINESS IN MA AND PROVIDED INVESTMENT ADVICE TO MORE
THAN FIVE CLIENTS WHO ARE NATURAL PERSONS, AND MORE THAN 10% PERCENT OF WHOSE CLIENTS ARE NATURAL PERSONS WHILE NOT
REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE IN MA, CONSTITUTING A VIOLATION OF APPLICABLE LAW.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):
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: $ 25,000.00
 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: 
FINE OF $25,000 WAS ASSESSED AGAINST THE FIRM, NOT AGAINST THE IAR. THE FINE WAS PAID IN FULL ON SEPT 2, 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).
THE STATE ALLEGED THE FIRM FAILED TO REGISTER AN IAR IN HIS HOME STATE OF MA AS REQUIRED BY APPLICABLE LAW. THE FIRM HAS REVIEWED
ITS REGISTRATION PROCEDURES TO ENSURE THAT THE FIRM IS PROMPTLY NOTICE-FILED AND ITS IARS REGISTERED AS REQUIRED BY APPLICABLE
LAW.

* 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.