Lime Rock

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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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE; CEASE AND DESIST
3.
Date Initiated (MM/DD/YYYY): 
01/17/2017
 Exact
 Explanation
If not exact, provide explanation:
THE ORDER AND SETTLEMENT WAS ENTERED INTO ON JANUARY 17, 2017.
4.
Docket/Case Number:
3-17782
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
EQUITY IN PRIVATE COMPANIES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON JANUARY 17, 2017, THE U.S. SECURITIES AND EXCHANGE COMMISSION (THE "SEC") INSTITUTED ADMINISTRATIVE PROCEEDINGS AGAINST THE
REGISTRANT, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT OF 1940, AS AMENDED (THE "ADVISERS ACT"), FINDING THAT THE
REGISTRANT HAD VIOLATED ADVISERS ACT RULE 206(4)-5 WHEN AN EMPLOYEE MADE A $1,000 PERSONAL CONTRIBUTION TO THE CAMPAIGN OF A
CANDIDATE FOR PRESIDENT OF THE UNITED STATES, AND THEN GOVERNOR OF OHIO, WHILE THE REGISTRANT ADVISED A POOLED INVESTMENT
VEHICLE WHERE AN OHIO PUBLIC ENTITY WAS AN INVESTOR. THE SEC FOUND THAT AFTER THE CONTRIBUTION WAS MADE, ITS RETURN WAS SOUGHT
AND RECEIVED, AND NOTED THAT ADVISERS ACT RULE 206(4)-5 DOES NOT REQUIRE A SHOWING OF QUID PRO QUO OR ACTUAL INTENT TO INFLUENCE

AN ELECTED OFFICIAL OR CANDIDATE.
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):
01/17/2017
 Exact
 Explanation
If not exact, provide explanation:
THE ORDER AND SETTLEMENT WAS ENTERED INTO ON JANUARY 17, 2017.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 75,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
WITHOUT ADMITTING TO ANY ALLEGATIONS, THE REGISTRANT CONSENTED TO THE ISSUANCE OF AN ORDER ON JANUARY 17, 2017 AND PAID A
CIVIL MONETARY PENALTY OF $75,000.
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: 
CIVIL MONETARY PENALTY OF $75,000.
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 JANUARY 17, 2017, THE SEC INSTITUTED ADMINISTRATIVE PROCEEDINGS AGAINST THE REGISTRANT REGARDING A CAMPAIGN CONTRIBUTION BY AN
EMPLOYEE OF THE REGISTRANT MADE IN VIOLATION OF THE SEC'S RULES GOVERNING POLITICAL CONTRIBUTIONS BY INVESTMENT ADVISER
EMPLOYEES AND THE REGISTRANT'S OWN COMPLIANCE POLICIES. WITHOUT ADMITTING OR DENYING LIABILITY, THE REGISTRANT AGREED TO PAY
$75,000 TO RESOLVE THE MATTER. UPON BECOMING AWARE OF THE $1,000 CONTRIBUTION, THE RESPONDENT CAUSED THE EMPLOYEE TO OBTAIN ITS
RETURN AND VOLUNTARILY REPORTED THE MATTER TO THE SEC. THE ORDER SETTLING THIS MATTER FINDS THAT ADVISERS ACT RULE 206(4)-5 DOES
NOT REQUIRE A SHOWING OF QUID PRO QUO OR ACTUAL INTENT TO INFLUENCE AN ELECTED OFFICIAL OR CANDIDATE FOR PUBLIC OFFICE, AND THAT
THE SEC WAS NOT REQUIRED TO SHOW THAT THE REGISTRANT WAS AWARE OF THE ACTIONS RESULTING IN THE VIOLATION OF THE RULE. THE
REGISTRANT FOLLOWS RIGOROUS COMPLIANCE PROCEDURES, TAKES REASONABLE STEPS TO ENFORCE ITS POLICIES, AND TRAINS AND PERIODICALLY
REEDUCATES ITS EMPLOYEES OF THOSE POLICIES.