Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Private Advisor Group, LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
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
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
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 Private Advisor Group, LLC.
Reported ownership and control details
Form ADV · Filing date 2026-09-30 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | JOHN PATRIC HYLANDEXECUTIVE CHAIRIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | EXECUTIVE CHAIR12/2010 | Schedule APDF page 180 |
| 2 | PATRICK JAMES SULLIVANEXECUTIVE CHAIRIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | EXECUTIVE CHAIR12/2010 | Schedule APDF page 180 |
| 3 | JAMES DANIEL SULLIVANMANAGING DIRECTORIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | MANAGING DIRECTOR06/2014 | Schedule APDF page 180 |
| 4 | JAMES J PERHACSMANAGING DIRECTOR, CHIEF OPERATING OFFICERIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | MANAGING DIRECTOR, CHIEF OPERATING OFFICER06/2014 | Schedule APDF page 180 |
| 5 | JAMES ALAN HOOKSCHIEF COMPLIANCE OFFICER, MANAGING DIRECTORIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER, MANAGING DIRECTOR07/2019 | Schedule APDF page 181 |
| 6 | PAG HOLDINGS, LLCOWNER, MANAGING MEMBERDomestic entity | PRIVATE ADVISOR GROUP, LLC | 75% or moreCode E | Yes | OWNER, MANAGING MEMBER01/2020 | Schedule APDF page 181 |
| 7 | FRANKLIN R SMITHCHIEF EXECUTIVE OFFICERIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | CHIEF EXECUTIVE OFFICER01/2023 | Schedule APDF page 181 |
| 8 | ROBERT JOSEPH MOOREEXECUTIVE CHAIRIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | EXECUTIVE CHAIR12/2020 | Schedule APDF page 181 |
| 9 | ADAM J SCHORRCHIEF FINANCIAL OFFICERIndividual | PRIVATE ADVISOR GROUP, LLC | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER03/2023 | Schedule APDF page 181 |
| 10 | PATRICK JAMES SULLIVANOWNERIndividual | PAG LEGACY PARTNERS LLC | 25% to less than 50%Code C | Yes | OWNER01/2020 | Schedule BPDF page 181 |
| 11 | JOHN PATRIC HYLANDOWNERIndividual | PAG LEGACY PARTNERS LLC | 25% to less than 50%Code C | Yes | OWNER01/2020 | Schedule BPDF page 181 |
| 12 | PAG PARTNERSHIP HOLDCO LLCOWNERDomestic entity | PAG HOLDINGS, LLC | 75% or moreCode E | Yes | OWNER12/2021 | Schedule BPDF page 181 |
| 13 | PAG LEGACY PARTNERS LLCOWNERDomestic entity | PAG PARTNERSHIP HOLDCO LLC | 75% or moreCode E | Yes | OWNER12/2021 | Schedule BPDF page 181 |
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 9/24/2026 5:16:27 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.
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 actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory 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 4 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 182–183
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: 1161180 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BREAULT, DAVID (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 1OPP, MARK, ADAMPDF pages 183–185
- Advisory affiliate name — filed text
- OPP, MARK, ADAM
- Regulator name — filed text
- MINNESOTA DEPARTMENT OF COMMERCE
- Monetary/Fine Amount — filed text
- $ 3,500.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT THE REGISTERED REPRESENTATIVE CLAIMED CREDIT FOR CE CREDIT HOURS THAT WERE NOT ACTUALLY COMPLETED IN ORDER TO CONTINUE INSURANCE PRODUCER LICENSURE WITH THE DEPARTMENT OF COMMERCE IN VIOLATION OF MINNESOTA STAT. SECTIONS 45.027, SUBD. 7(A)(1) & (2) AND 60K.56, SUBD.8A (2008).
Other filed details
Description of allegations — filed text
THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT THE REGISTERED REPRESENTATIVE CLAIMED CREDIT FOR CE CREDIT HOURS THAT WERE NOT ACTUALLY COMPLETED IN ORDER TO CONTINUE INSURANCE PRODUCER LICENSURE WITH THE DEPARTMENT OF COMMERCE IN VIOLATION OF MINNESOTA STAT. SECTIONS 45.027, SUBD. 7(A)(1) & (2) AND 60K.56, SUBD.8A (2008).
Sanction detail — filed text
REGISTERED REPRESENTATIVE WAS GIVEN 90 DAYS TO REQUALIFY AND COMPLETED THE REQUIRED CE CREDITS PRIOR TO THE EXECUTION OF THE CONSENT 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: 2502705 This advisory affiliate is a Firm an Individual Registered: Yes No Name: OPP, MARK, ADAM (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) MINNESOTA DEPARTMENT OF COMMERCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST, REQUALIFICATION 3. Date Initiated (MM/DD/YYYY): 05/02/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 14166/TF 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MERRILL LYNCH, PIERCE, FENNER & SMITH, INC. 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT THE REGISTERED REPRESENTATIVE CLAIMED CREDIT FOR CE CREDIT HOURS THAT WERE NOT ACTUALLY COMPLETED IN ORDER TO CONTINUE INSURANCE PRODUCER LICENSURE WITH THE DEPARTMENT OF COMMERCE IN VIOLATION OF MINNESOTA STAT. SECTIONS 45.027, SUBD. 7(A)(1) & (2) AND 60K.56, SUBD.8A (2008). 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: Consent 11. Resolution Date (MM/DD/YYYY): 05/02/2011 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: $ 3,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: REQUALIFICATION 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: REGISTERED REPRESENTATIVE WAS GIVEN 90 DAYS TO REQUALIFY AND COMPLETED THE REQUIRED CE CREDITS PRIOR TO THE EXECUTION OF THE CONSENT 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). THE MINNESOTA DEPARTMENT OF COMMERCE ALLEGED THAT THE REGISTERED REPRESENTATIVE CLAIMED CREDIT FOR CE CREDIT HOURS THAT WERE NOT ACTUALLY COMPLETED IN ORDER TO CONTINUE INSURANCE PRODUCER LICENSURE WITH THE DEPARTMENT OF COMMERCE IN VIOLATION OF MINNESOTA STAT. SECTIONS 45.027, SUBD. 7(A)(1) & (2) AND 60K.56, SUBD.8A (2008).
regulatory · block 2PDF pages 185–186
- Regulator name — filed text
- PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES
- Monetary/Fine Amount — filed text
- $ 20,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
REPRESENTATIVE MOVED HIS OFFICE AND FIRM FAILED TO TRANSFER REGISTRATION TO NEW STATE.
Other filed details
Description of allegations — filed text
FIRM EMPLOYED ONE INVESTMENT ADVISER REPRESENTATIVE IN STATE WHO WAS NOT REGISTERED WITH STATE.
Sanction detail — filed text
ADMINISTRATIVE ASSESSMENT OF $20000 WAS PAID ON 5.2.2017
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) PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/02/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 170018 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): FIRM EMPLOYED ONE INVESTMENT ADVISER REPRESENTATIVE IN STATE WHO WAS NOT REGISTERED WITH STATE. 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: Consent 11. Resolution Date (MM/DD/YYYY): 05/02/2017 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: $ 20,000.00 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: ADMINISTRATIVE ASSESSMENT OF $20000 WAS PAID ON 5.2.2017 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). REPRESENTATIVE MOVED HIS OFFICE AND FIRM FAILED TO TRANSFER REGISTRATION TO NEW STATE.
regulatory · block 3PDF pages 186–188
- Regulator name — filed text
- UNITES STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 5,800,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON JULY 21, 2022, PURSUANT TO A SETTLEMENT, IN WHICH THE REGISTRANT NEITHER ADMITTED OR DENIED TO THE FINDINGS, THE SEC ISSUED AN ADMINISTRATIVE ORDER ("THE ORDER") THAT FOUND, AMONG OTHER THINGS, THE REGISTRANT FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING THE CONFLICTS ASSOCIATED WITH SHARE CLASSES WITH NO TRANSACTION FEES, OR NTF SHARES, IN WRAP ACCOUNTS. THE ORDER FOUND THAT THE REGISTRANT DID NOT FULFILL ITS DUTY OF CARE AND OTHER OBLIGATIONS IN CONNECTION WITH THE CONFLICT. THE ORDER ALSO FOUND THAT THE REGISTRANT HAD NOT ADOPTED AND IMPLEMENTED WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SELECTION PRACTICES IN ITS WRAP PROGRAM AND THE RELATED DISCLOSURES OF ITS ASSOCIATED CONFLICTS OF INTEREST. THE ORDER INCLUDES FINDINGS THAT REGISTRANT VIOLATED SECTION 206(2) OF THE ADVISERS ACT, AS WELL AS SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THESE ARE NOT SCIENTER-BASED VIOLATIONS. AS PART OF THE SETTLEMENT, THE REGISTRANT AGREED TO PAY A CIVIL PENALTY OF $5.8 MILLION, TO BE DISBURSED TO AFFECTED INVESTORS, ALONG WITH OTHER UNDERTAKINGS. AS FURTHER HIGHLIGHTED IN THE ORDER, IN 2017 THE REGISTRANT PROACTIVELY INSTITUTED A POLICY AS A REMEDIAL MEASURE THAT MITIGATED THE CONFLICT.
Other filed details
Description of allegations — filed text
REGISTRANT ALLEGEDLY FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING THE CONFLICTS ASSOCIATED WITH SHARE CLASSES WITH NO TRANSACTION FEES, OR NTF SHARES, IN WRAP ACCOUNTS, AND ALLEGEDLY DID NOT FULFILL ITS DUTY OF CARE AND OTHER OBLIGATIONS IN CONNECTION WITH THE CONFLICT.
Sanction detail — filed text
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; CENSURED; PAY A CIVIL PENALTY OF $5,800,000,
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITES STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3.
Date Initiated (MM/DD/YYYY):
06/10/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
HO-13906
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):
REGISTRANT ALLEGEDLY FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING THE CONFLICTS ASSOCIATED WITH SHARE CLASSES WITH NO
TRANSACTION FEES, OR NTF SHARES, IN WRAP ACCOUNTS, AND ALLEGEDLY DID NOT FULFILL ITS DUTY OF CARE AND OTHER OBLIGATIONS IN
CONNECTION WITH THE CONFLICT.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
07/21/2022
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 5,800,000.00
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:
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; CENSURED; PAY A CIVIL PENALTY OF $5,800,000,
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 21, 2022, PURSUANT TO A SETTLEMENT, IN WHICH THE REGISTRANT NEITHER ADMITTED OR DENIED TO THE FINDINGS, THE SEC ISSUED AN
ADMINISTRATIVE ORDER ("THE ORDER") THAT FOUND, AMONG OTHER THINGS, THE REGISTRANT FAILED TO PROVIDE FULL AND FAIR DISCLOSURE
REGARDING THE CONFLICTS ASSOCIATED WITH SHARE CLASSES WITH NO TRANSACTION FEES, OR NTF SHARES, IN WRAP ACCOUNTS. THE ORDER
FOUND THAT THE REGISTRANT DID NOT FULFILL ITS DUTY OF CARE AND OTHER OBLIGATIONS IN CONNECTION WITH THE CONFLICT. THE ORDER ALSO
FOUND THAT THE REGISTRANT HAD NOT ADOPTED AND IMPLEMENTED WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO
PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SELECTION PRACTICES IN ITS
WRAP PROGRAM AND THE RELATED DISCLOSURES OF ITS ASSOCIATED CONFLICTS OF INTEREST. THE ORDER INCLUDES FINDINGS THAT REGISTRANT
VIOLATED SECTION 206(2) OF THE ADVISERS ACT, AS WELL AS SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. THESE ARE
NOT SCIENTER-BASED VIOLATIONS. AS PART OF THE SETTLEMENT, THE REGISTRANT AGREED TO PAY A CIVIL PENALTY OF $5.8 MILLION, TO BE
DISBURSED TO AFFECTED INVESTORS, ALONG WITH OTHER UNDERTAKINGS. AS FURTHER HIGHLIGHTED IN THE ORDER, IN 2017 THE REGISTRANT
PROACTIVELY INSTITUTED A POLICY AS A REMEDIAL MEASURE THAT MITIGATED THE CONFLICT.* 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.