Firm profile

Kestra Private Wealth Services, LLC

AUSTIN, TXCRD 155193Registration Status: ApprovedEffective since November 22, 2010SEC # 801-71936Latest ADV September 22, 2026

Kestra Private Wealth Services, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in Austin, TX. Its latest Form ADV filing, dated September 22, 2026, reports $13.5B in regulatory assets under management, 211 employees, 43 offices, and 33,333 accounts.

Assets Under Management
$13.5B
Employees
211
Offices
43 offices
Total Clients
20,230

Associated firm names

32 names listed
  • 1626 WEALTH MANAGEMENT
  • WOODS ASSET MANAGEMENT
  • WASHINGTON WEALTH MANAGEMENT, LLC
  • WASHINGTON WEALTH MANAGEMENT

Leadership

3 roles identified
CEORobert M. Bartenstein
CCOMichael R. Pedlow
CFOScott M. Zegers

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

AUSTIN, Texas, 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.

Texas

AUSTINPrimary office · PLANO

Alabama

MOBILE

Arizona

SCOTTSDALE · TEMPE

California

CALABASAS · SAN DIEGO

Florida

STUART · BOCA RATON · MELBOURNE

Georgia

WAYCROSS

Massachusetts

BURLINGTON

Michigan

BLOOMFIELD HILLS · AUBURN HILLS

Missouri

CHESTERFIELD

New York

MIDDLETOWN

North Carolina

HUNTERSVILLE

Ohio

ZANESVILLE · SANDUSKY

Pennsylvania

SEWICKLEY

Rhode Island

CRANSTON

South Carolina

GREENVILLE

Tennessee

MEMPHIS

Utah

OGDEN · SALT LAKE CITY

Virginia

ALEXANDRIA · ARLINGTON

27 office records listed · 43 total offices reported. 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$13.5Bas of September 22, 2026
Discretionary99.9%
$13.4B
100% of total RAUM99.9%
Non-discretionary0.1%
$18M
0% of total RAUM0.1%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 72.6% of total clients.
Top client categories% of clientsClients
1
Individuals
72.6%
14,677
2
HNWI
26.2%
5,300
3
Corporations
1.0%
210
4
Charitable
0.1%
23
5
Pension Plans
0.1%
15
Additional categories (<0.1%)
Insurance Cos.5 clients
Categories with <5 clients
Banking or thrift institutions<5 clients
Other investment advisers<5 clients
Other categories<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$13.5B
Total Accounts33,333
10Y AUM Change+$12.4B (+1222.5%)

Private Funds

Private funds reported by Kestra Private Wealth Services, 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 Employees211
Clients per Employee96:1
10Y Employee Change+153 (+263.8%)

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%
KESTRA FINANCIAL, INC.Direct owner · Schedule AInterest in KESTRA PRIVATE WEALTH SERVICES, LLC
75%+
KESTRA ADVISOR SERVICES HOLDINGS C, INC.Indirect owner · Schedule BInterest in KESTRA FINANCIAL, INC.
75%+
KESTRA ADVISOR SERVICES HOLDINGS B, INCIndirect owner · Schedule BInterest in KESTRA ADVISOR SERVICES HOLDINGS C, INC.
75%+
KESTRA ADVISOR SERVICES HOLDINGS A, INCIndirect owner · Schedule BInterest in KESTRA ADVISOR SERVICES HOLDINGS B, INC
75%+
KINGFISHER HOLDING B, INC.Indirect owner · Schedule BInterest in KESTRA ADVISOR SERVICES HOLDINGS A, INC
75%+
KINGFISHER HOLDING A, INC.Indirect owner · Schedule BInterest in KINGFISHER HOLDING B, INC.
75%+
KINGFISHER TOPCO HOLDINGS, LPIndirect owner · Schedule BInterest in KESTRA ADVISOR SERVICES HOLDINGS A, INC
75%+
OHCP VI ENZO AGGREGATOR, L.P.Indirect owner · Schedule BInterest in KINGFISHER TOPCO HOLDINGS, LP
25% to < 50%
T-IX KRAKEN CO-INVEST, LPIndirect owner · Schedule BInterest in KINGFISHER TOPCO HOLDINGS, LP
25% to < 50%

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 Kestra Private Wealth Services, LLC.

Reported ownership and control details

Form ADV · Filing date 2026-09-22 · Schedules A and B

20 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1ROBERT MASON BARTENSTEINCHIEF EXECUTIVE OFFICERIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesCHIEF EXECUTIVE OFFICER05/2012Schedule APDF page 58
2KESTRA FINANCIAL, INC.MANAGING MEMBERDomestic entityKESTRA PRIVATE WEALTH SERVICES, LLC75% or moreCode EYesMANAGING MEMBER03/2014Schedule APDF page 58
3MICHAEL ROSS PEDLOWEVP, CHIEF COMPLIANCE OFFICERIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesEVP, CHIEF COMPLIANCE OFFICER03/2018Schedule APDF page 58
4YIN YINASSISTANT SECRETARYIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NANoASSISTANT SECRETARY06/2016Schedule APDF page 58
5MARK PAUL SCHOENBECKEVP, ADVISOR ENGAGEMENTIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesEVP, ADVISOR ENGAGEMENT07/2017Schedule APDF page 58
6Jean-Luc DupontHEAD OF CYBERSECURITY AND TECHNOLOGY RISKIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NANoHEAD OF CYBERSECURITY AND TECHNOLOGY RISK07/2023Schedule APDF page 58
7Vinay KantEVP, CHIEF DIGITAL TECHNOLOGY OFFICERIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesEVP, CHIEF DIGITAL TECHNOLOGY OFFICER08/2024Schedule APDF page 58
8JOHN VINCENT AMOREPRESIDENTIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesPRESIDENT04/2025Schedule APDF page 58
9Scott Matthew ZegersCHIEF FINANCIAL OFFICERIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesCHIEF FINANCIAL OFFICER12/2024Schedule APDF page 58
10Angela Diane XavierEVP, CLIENT EXPERIENCE OFFICERIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NAYesEVP, CLIENT EXPERIENCE OFFICER09/2025Schedule APDF page 58
11Jeremy Scott CarrEVP, GENERAL COUNSELIndividualKESTRA PRIVATE WEALTH SERVICES, LLCLess than 5%Code NANoEVP, GENERAL COUNSEL09/2025Schedule APDF page 58
12KESTRA ADVISOR SERVICES HOLDINGS C, INC.OWNERDomestic entityKESTRA FINANCIAL, INC.75% or moreCode EYesOWNER10/2014Schedule BPDF page 59
13KESTRA ADVISOR SERVICES HOLDINGS B, INCOWNERDomestic entityKESTRA ADVISOR SERVICES HOLDINGS C, INC.75% or moreCode EYesOWNER10/2014Schedule BPDF page 59
14KESTRA ADVISOR SERVICES HOLDINGS A, INCOWNERDomestic entityKESTRA ADVISOR SERVICES HOLDINGS B, INC75% or moreCode EYesOWNER10/2014Schedule BPDF page 59
15KINGFISHER HOLDING B, INC.OWNERDomestic entityKESTRA ADVISOR SERVICES HOLDINGS A, INC75% or moreCode EYesOWNER06/2019Schedule BPDF page 59
16KINGFISHER HOLDING A, INC.OWNERDomestic entityKINGFISHER HOLDING B, INC.75% or moreCode EYesOWNER06/2019Schedule BPDF page 59
17KINGFISHER TOPCO HOLDINGS, LPOWNERDomestic entityKESTRA ADVISOR SERVICES HOLDINGS A, INC75% or moreCode EYesOWNER02/2025Schedule BPDF page 59
18OHCP VI ENZO AGGREGATOR, L.P.OWNERDomestic entityKINGFISHER TOPCO HOLDINGS, LP25% to less than 50%Code CYesOWNER02/2025Schedule BPDF page 59
19KINGFISHER TOPCO HOLDINGS GP, LLCGENERAL PARTNERDomestic entityKINGFISHER HOLDING A, INC.Percentage not specifiedCode FYesGENERAL PARTNER02/2025Schedule BPDF page 59
20T-IX KRAKEN CO-INVEST, LPOWNERDomestic entityKINGFISHER TOPCO HOLDINGS, LP25% to less than 50%Code CYesOWNER02/2025Schedule BPDF page 59

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 9/22/2026 2:57:44 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
AFelonies1 Yes1 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?Yes
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?Yes
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory 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 actions2 Yes2 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?Yes
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 9 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.

criminal · block 1PDF pages 59–60
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.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
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. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.

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:
1423436
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
KENZIK, GREGORY, JAMES
(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.
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.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
criminal · block 2PDF pages 60–62
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.A. or
11.B. of Form ADV.

Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
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. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
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:
5770357
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Hamilton, Christopher, Scott
(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.
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.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if

sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.)
regulatory · block 1PDF pages 62–63
Regulator name — filed text
THE UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 50,000.00
How was matter resolved — filed text
Decision

Action status / disposition — filed text

WITHOUT ADMITTING OR DENYING THE UNDERLYING ALLEGATIONS, KESTRA PWS AGREED TO ACCEPT A CEASE AND DESIST ORDER, A CENSURE, AND PAY A FINE OF $50,000.
Other filed details

Description of allegations — filed text

ON JULY 11, 2016, KESTRA PWS AGREED TO PAY THE U.S. SECURITIES AND EXCHANGE COMMISSION AN ADMINISTRATIVE FINE OF $50,000 FOR FAILING TO DISCLOSE IN A TIMELY FASHION AN ALLEGED CONFLICT OF INTEREST ARISING FROM THE FIRM'S RECEIPT OF LOANS FROM A THIRD PARTY KESTRA PWS HAD ENGAGED TO PROVIDE BROKERAGE AND CUSTODIAL SERVICES TO ITS CLIENTS.

Sanction detail — filed text

KESTRA PWS AGREED TO PAY A FINE OF $50,000 WITHIN 14 DAYS OF RESOLUTION DATE.
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 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
07/18/2016
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-17349
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 JULY 11, 2016, KESTRA PWS AGREED TO PAY THE U.S. SECURITIES AND EXCHANGE COMMISSION AN ADMINISTRATIVE FINE OF $50,000 FOR
FAILING TO DISCLOSE IN A TIMELY FASHION AN ALLEGED CONFLICT OF INTEREST ARISING FROM THE FIRM'S RECEIPT OF LOANS FROM A THIRD PARTY
KESTRA PWS HAD ENGAGED TO PROVIDE BROKERAGE AND CUSTODIAL SERVICES TO ITS CLIENTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
07/18/2016
 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: $ 50,000.00
 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: 
KESTRA PWS AGREED TO PAY A FINE OF $50,000 WITHIN 14 DAYS OF RESOLUTION DATE.
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).
WITHOUT ADMITTING OR DENYING THE UNDERLYING ALLEGATIONS, KESTRA PWS AGREED TO ACCEPT A CEASE AND DESIST ORDER, A CENSURE, AND
PAY A FINE OF $50,000.
regulatory · block 2PDF pages 63–65
Regulator name — filed text
THE SECURITIES AND EXCHANGE COMMISSION
How was matter resolved — filed text
Order

Action status / disposition — filed text

WITHOUT ADMITTING OR DENYING THE UNDERLYING FINDINGS, KESTRA PWS OFFERED TO ACCEPT A CENSURE, AN ORDER TO CEASE AND DESIST FROM SUCH ACTIVITY, AND PAY ELIGIBLE CUSTOMERS AN ESTIMATED $502,703.66 IN DISGORGEMENT AND $46,299.36 IN INTEREST.
Other filed details

Description of allegations — filed text

THE RECOMMENDATION OF MUTUAL FUND SHARE CLASSES GENERATING COMPENSATION TO KESTRA PWS'S AFFILIATED BROKER-DEALER WITHOUT ADEQUATE DISCLOSURE OF SUCH COMPENSATION AND THE ADDITIONAL EXPENSES ASSOCIATED WITH THE SHARE CLASSES.

Sanction detail — filed text

$502,703.66 IN DISGORGEMENT AND $46,299.36 IN 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
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:
Cease and Desist
Other Sanctions: 
CENSURE AND DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY): 
06/12/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19089
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 RECOMMENDATION OF MUTUAL FUND SHARE CLASSES GENERATING COMPENSATION TO KESTRA PWS'S AFFILIATED BROKER-DEALER WITHOUT

ADEQUATE DISCLOSURE OF SUCH COMPENSATION AND THE ADDITIONAL EXPENSES ASSOCIATED WITH THE SHARE CLASSES.
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):
03/11/2019
 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: 
$502,703.66 IN DISGORGEMENT AND $46,299.36 IN 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).
WITHOUT ADMITTING OR DENYING THE UNDERLYING FINDINGS, KESTRA PWS OFFERED TO ACCEPT A CENSURE, AN ORDER TO CEASE AND DESIST FROM
SUCH ACTIVITY, AND PAY ELIGIBLE CUSTOMERS AN ESTIMATED $502,703.66 IN DISGORGEMENT AND $46,299.36 IN INTEREST.
regulatory · block 3KESTRA ADVISORY SERVICES, LLCPDF pages 65–67
Advisory affiliate name — filed text
KESTRA ADVISORY SERVICES, LLC
Regulator name — filed text
THE U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
Monetary/Fine Amount — filed text
$ 1,500,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TOACCEPT. RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAYDISGORGEMENT OF $7,229,802, PREJUDGMENT INTEREST OF $1,273,370, AND A CIVIL PENALTY OF$1,500,000; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
Other filed details

Description of allegations — filed text

THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,INSTITUTED PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940("ADVISERS ACT") AGAINST KESTRA ADVISORY SERVICES, LLC ("KESTRA AS" OR "RESPONDENT"). THE COMMISSION FINDS THAT KESTRA AS, A REGISTERED INVESTMENT ADVISER, BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS BY FAILING TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING TWO TYPES OF COMPENSATION PAID TO ITS PREDECESSOR FIRM AND AFFILIATED BROKER. FIRST, SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED REVENUE SHARING PAYMENTS FROM AN UNAFFILIATED CLEARING BROKER ("CLEARING BROKER") AS ARESULT OF KESTRA AS'S ADVISORY CLIENTS' INVESTMENTS IN CERTAIN MUTUAL FUNDS. CERTAIN OF THE MUTUAL FUNDS THAT PAID REVENUE SHARING WERE MORE EXPENSIVE THAN LOWER-COST OPTIONS AVAILABLE TO CLIENTS, INCLUDING INSTANCES WHEN THERE WERE LOWER-COST SHARE CLASSES OF THE SAME MUTUAL FUNDS AVAILABLE TO CLIENTS THAT DID NOT RESULT IN ANY REVENUE SHARING. SECOND, SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED COMPENSATION RESULTING FROM TRANSACTION FEES CHARGED ON MUTUAL FUND TRADES AND NON-TRANSACTION FEES FOR CERTAINSERVICES PROVIDED TO KESTRA AS'S ADVISORY CLIENTS, WHICH WERE GREATER THAN THE AMOUNT CHARGED TO THE AFFILIATED BROKER BY THE CLEARING BROKER FOR THOSE TRADES AND SERVICES(COLLECTIVELY, "FEE MARKUPS"). KESTRA AS ALSO BREACHED ITS DUTY TO SEEK BEST EXECUTION BYCAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS THAT PAID REVENUESHARING WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO THE CLIENTS THAT PRESENTED AMORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THETIME OF THE TRANSACTIONS. KESTRA AS FAILED TO ADOPT AND IMPLEMENT WRITTENCOMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION, FEE MARKUP PRACTICES, AND BEST EXECUTION.

Sanction detail — filed text

RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $7,229,802, PREJUDGMENTINTEREST OF $1,273,370, AND A CIVIL PENALTY OF $1,500,000; AND SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE ORDER.
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:
283330
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
KESTRA ADVISORY SERVICES,
LLC
(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 U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/09/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20390
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 SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,INSTITUTED PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS
ACT OF 1940("ADVISERS ACT") AGAINST KESTRA ADVISORY SERVICES, LLC ("KESTRA AS" OR "RESPONDENT"). THE COMMISSION FINDS THAT KESTRA
AS, A REGISTERED INVESTMENT ADVISER, BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS BY FAILING TO PROVIDE FULL AND FAIR DISCLOSURE
REGARDING TWO TYPES OF COMPENSATION PAID TO ITS PREDECESSOR FIRM AND AFFILIATED BROKER. FIRST, SINCE AT LEAST JANUARY 2014, THE
AFFILIATED BROKER RECEIVED REVENUE SHARING PAYMENTS FROM AN UNAFFILIATED CLEARING BROKER ("CLEARING BROKER") AS ARESULT OF
KESTRA AS'S ADVISORY CLIENTS' INVESTMENTS IN CERTAIN MUTUAL FUNDS. CERTAIN OF THE MUTUAL FUNDS THAT PAID REVENUE SHARING WERE
MORE EXPENSIVE THAN LOWER-COST OPTIONS AVAILABLE TO CLIENTS, INCLUDING INSTANCES WHEN THERE WERE LOWER-COST SHARE CLASSES OF
THE SAME MUTUAL FUNDS AVAILABLE TO CLIENTS THAT DID NOT RESULT IN ANY REVENUE SHARING. SECOND, SINCE AT LEAST JANUARY 2014, THE
AFFILIATED BROKER RECEIVED COMPENSATION RESULTING FROM TRANSACTION FEES CHARGED ON MUTUAL FUND TRADES AND NON-TRANSACTION
FEES FOR CERTAINSERVICES PROVIDED TO KESTRA AS'S ADVISORY CLIENTS, WHICH WERE GREATER THAN THE AMOUNT CHARGED TO THE AFFILIATED
BROKER BY THE CLEARING BROKER FOR THOSE TRADES AND SERVICES(COLLECTIVELY, "FEE MARKUPS"). KESTRA AS ALSO BREACHED ITS DUTY TO
SEEK BEST EXECUTION BYCAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS THAT PAID REVENUESHARING WHEN
SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO THE CLIENTS THAT PRESENTED AMORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE

PARTICULAR CIRCUMSTANCES IN PLACE AT THETIME OF THE TRANSACTIONS. KESTRA AS FAILED TO ADOPT AND IMPLEMENT WRITTENCOMPLIANCE
POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION
WITH ITS MUTUAL FUND SHARE CLASS SELECTION, FEE MARKUP PRACTICES, AND BEST EXECUTION.
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):
07/09/2021
 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: $ 1,500,000.00
 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: 
RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2)
AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $7,229,802,
PREJUDGMENTINTEREST OF $1,273,370, AND A CIVIL PENALTY OF $1,500,000; AND SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN
THE ORDER.
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 SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TOACCEPT. RESPONDENT WILLFULLY VIOLATED
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND
DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND
RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAYDISGORGEMENT OF $7,229,802, PREJUDGMENT INTEREST OF $1,273,370, AND A
CIVIL PENALTY OF$1,500,000; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
regulatory · block 4PDF pages 67–69
Regulator name — filed text
THE U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
Monetary/Fine Amount — filed text
$ 60,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE206(4)-7 THEREUNDER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4)OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAYDISGORGEMENT OF $208,187, PREJUDGMENT INTEREST OF $31,382, AND A CIVIL PENALTY OF $60,000; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
Other filed details

Description of allegations — filed text

THE COMMISSION FINDS THAT KESTRA PWS, A REGISTERED INVESTMENT ADVISER, BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS BY FAILING TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING TWO TYPES OF COMPENSATION PAID TO ITS PREDECESSOR FIRM AND AFFILIATED BROKER. FIRST, SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED REVENUE SHARING PAYMENTS FROM AN UNAFFILIATED CLEARING BROKER ("CLEARING BROKER") AS ARESULT OF KESTRA PWS'S ADVISORY CLIENTS' INVESTMENTS IN CERTAIN MUTUAL FUNDS. CERTAIN OF THE MUTUAL FUNDS THAT PAID REVENUE SHARING WERE MORE EXPENSIVE THAN LOWER-COST OPTIONS AVAILABLE TO CLIENTS, INCLUDING INSTANCES WHEN THERE WERE LOWER-COST SHARE CLASSES OF THE SAME MUTUAL FUNDS AVAILABLE TO CLIENTS THAT DID NOT RESULT IN ANY REVENUE SHARING. SECOND, SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED COMPENSATION RESULTING FROM TRANSACTION FEES CHARGED ON MUTUAL FUND TRADES AND NON-TRANSACTION FEES FOR CERTAIN SERVICES PROVIDED TO KESTRA PWS'S ADVISORY CLIENTS, WHICH WERE GREATER THAN THE AMOUNT CHARGED TO THE AFFILIATED BROKER BY THE CLEARING BROKER FOR THOSE TRADES AND SERVICES(COLLECTIVELY, "FEE MARKUPS"). KESTRA PWS ALSO BREACHED ITS DUTY TO SEEK BEST EXECUTION BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS THAT PAID REVENUESHARING WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO THE CLIENTS THAT PRESENTED AMORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THETIME OF THE TRANSACTIONS. KESTRA PWS FAILED TO ADOPT AND IMPLEMENT WRITTENCOMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION, FEE MARKUP PRACTICES, AND BEST EXECUTION.

Sanction detail — filed text

RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $208,187, PREJUDGMENTINTEREST OF $31,382, AND A CIVIL PENALTY OF $60,000; AND SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE ORDER.
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 U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/09/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-20391
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 COMMISSION FINDS THAT KESTRA PWS, A REGISTERED INVESTMENT ADVISER, BREACHED ITS FIDUCIARY DUTY TO ADVISORY CLIENTS BY FAILING
TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING TWO TYPES OF COMPENSATION PAID TO ITS PREDECESSOR FIRM AND AFFILIATED BROKER.
FIRST, SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED REVENUE SHARING PAYMENTS FROM AN UNAFFILIATED CLEARING BROKER
("CLEARING BROKER") AS ARESULT OF KESTRA PWS'S ADVISORY CLIENTS' INVESTMENTS IN CERTAIN MUTUAL FUNDS. CERTAIN OF THE MUTUAL FUNDS
THAT PAID REVENUE SHARING WERE MORE EXPENSIVE THAN LOWER-COST OPTIONS AVAILABLE TO CLIENTS, INCLUDING INSTANCES WHEN THERE
WERE LOWER-COST SHARE CLASSES OF THE SAME MUTUAL FUNDS AVAILABLE TO CLIENTS THAT DID NOT RESULT IN ANY REVENUE SHARING. SECOND,
SINCE AT LEAST JANUARY 2014, THE AFFILIATED BROKER RECEIVED COMPENSATION RESULTING FROM TRANSACTION FEES CHARGED ON MUTUAL FUND
TRADES AND NON-TRANSACTION FEES FOR CERTAIN SERVICES PROVIDED TO KESTRA PWS'S ADVISORY CLIENTS, WHICH WERE GREATER THAN THE
AMOUNT CHARGED TO THE AFFILIATED BROKER BY THE CLEARING BROKER FOR THOSE TRADES AND SERVICES(COLLECTIVELY, "FEE MARKUPS").
KESTRA PWS ALSO BREACHED ITS DUTY TO SEEK BEST EXECUTION BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF
MUTUAL FUNDS THAT PAID REVENUESHARING WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO THE CLIENTS THAT PRESENTED AMORE
FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THETIME OF THE TRANSACTIONS. KESTRA PWS FAILED
TO ADOPT AND IMPLEMENT WRITTENCOMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS

ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION, FEE MARKUP PRACTICES, AND BEST
EXECUTION.
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):
07/09/2021
 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: $ 60,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT INTEREST ON DISGORGEMENT AND 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: 
RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 206(2)
AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7PROMULGATED THEREUNDER; IS CENSURED; SHALL PAY DISGORGEMENT OF $208,187,
PREJUDGMENTINTEREST OF $31,382, AND A CIVIL PENALTY OF $60,000; AND SHALL COMPLY WITH THEUNDERTAKINGS ENUMERATED IN THE
ORDER.
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 SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. RESPONDENT WILLFULLY VIOLATED
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE206(4)-7 THEREUNDER. ACCORDINGLY, IT IS ORDERED THAT RESPONDENT CEASE AND
DESIST FROMCOMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4)OF THE ADVISERS ACT AND
RULE 206(4)-7 PROMULGATED THEREUNDER; IS CENSURED; SHALL PAYDISGORGEMENT OF $208,187, PREJUDGMENT INTEREST OF $31,382, AND A
CIVIL PENALTY OF $60,000; AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE ORDER.
Show 3 more source blocks
regulatory · block 5KESTRA ADVISORY SERVICES, LLCPDF pages 69–71
Advisory affiliate name — filed text
KESTRA ADVISORY SERVICES, LLC
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:
283330
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
KESTRA ADVISORY SERVICES,
LLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 6FAUST, LYNN, COOPERPDF pages 71–73
Advisory affiliate name — filed text
FAUST, LYNN, COOPER
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:
729012
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FAUST, LYNN, COOPER
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the

adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion

of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
regulatory · block 7MARMION JR., JOHN, JR.,JOHNPDF pages 73–74
Advisory affiliate name — filed text
MARMION JR., JOHN, JR.,JOHN
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:
1139175
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MARMION JR., JOHN, JR.,JOHN
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 

2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

* 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.