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 Pccp, 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 Pccp, LLC.
Reported ownership and control details
Form ADV · Filing date 2026-09-16 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | CGKL I, LLCMEMBERDomestic entity | PCCP, LLC | 25% to less than 50%Code C | Yes | MEMBER05/1998 | Schedule APDF page 241 |
| 2 | ESC-PCCP HOLDINGS, LLCMEMBERDomestic entity | PCCP, LLC | 10% to less than 25%Code B | No | MEMBER12/2007 | Schedule APDF page 241 |
| 3 | AARON ARTHUR GIOVARAPARTNERIndividual | PCCP, LLC | 10% to less than 25%Code B | Yes | PARTNER05/1998 | Schedule APDF page 241 |
| 4 | DONALD HENRY KUEMMELERSENIOR MANAGING PARTNERIndividual | PCCP, LLC | 10% to less than 25%Code B | Yes | SENIOR MANAGING PARTNER05/1998 | Schedule APDF page 241 |
| 5 | WILLIAM RUFUS LINDSAYSENIOR MANAGING PARTNERIndividual | PCCP, LLC | 10% to less than 25%Code B | Yes | SENIOR MANAGING PARTNER05/1998 | Schedule APDF page 241 |
| 6 | BRYAN SHELBY THORNTONMANAGING PARTNERIndividual | PCCP, LLC | Less than 5%Code NA | Yes | MANAGING PARTNER06/2020 | Schedule APDF page 241 |
| 7 | STEPHEN PAUL TOWLEPARTNER, CHIEF FINANCIAL OFFICERIndividual | PCCP, LLC | Less than 5%Code NA | No | PARTNER, CHIEF FINANCIAL OFFICER08/2013 | Schedule APDF page 241 |
| 8 | PCCP CLASS D, LLCMEMBERDomestic entity | PCCP, LLC | 5% to less than 10%Code A | No | MEMBER01/2014 | Schedule APDF page 241 |
| 9 | LAUREN ENG YOUNG NGONGANGPARTNER, CHIEF RISK OFFICER & CHIEF COMPLIANCE OFFICERIndividual | PCCP, LLC | Less than 5%Code NA | No | PARTNER, CHIEF RISK OFFICER & CHIEF COMPLIANCE OFFICER05/2016 | Schedule APDF page 241 |
| 10 | REEF MANAGER, LLCELECTED MANAGERDomestic entity | PCCP, LLC | Less than 5%Code NA | Yes | ELECTED MANAGER12/2017 | Schedule APDF page 241 |
| 11 | AMP CAPITAL INVESTORS US REAL ESTATE, LLCMEMBERDomestic entity | PCCP, LLC | 10% to less than 25%Code B | No | MEMBER12/2017 | Schedule APDF page 241 |
| 12 | PETER JOSEPH SPAZIANIMANAGING DIRECTOR, GENERAL COUNSELIndividual | PCCP, LLC | Less than 5%Code NA | No | MANAGING DIRECTOR, GENERAL COUNSEL06/2022 | Schedule APDF page 241 |
| 13 | PCCP CLASS F, LLCMEMBERDomestic entity | PCCP, LLC | 5% to less than 10%Code A | No | MEMBER04/2018 | Schedule APDF page 241 |
| 14 | CALIFORNIA STATE TEACHERS RETIREMENT SYSTEMMEMBERDomestic entity | ESC-PCCP HOLDINGS, LLC | 75% or moreCode E | No | MEMBER12/2007 | Schedule BPDF page 242 |
| 15 | ULHORN-THORNTON FAMILY TRUSTMEMBERDomestic entity | PCCP CLASS D, LLC | 25% to less than 50%Code C | No | MEMBER01/2014 | Schedule BPDF page 242 |
| 16 | BRYAN SHELBY THORNTONTRUSTEEIndividual | ULHORN-THORNTON FAMILY TRUST | 50% to less than 75%Code D | Yes | TRUSTEE01/2014 | Schedule BPDF page 242 |
| 17 | WILLIAM RUFUS LINDSAYMANAGERIndividual | CGKL I, LLC | 25% to less than 50%Code C | Yes | MANAGER05/1998 | Schedule BPDF page 242 |
| 18 | EMILY IRENE KRISTIN ULHORNTRUSTEEIndividual | ULHORN-THORNTON FAMILY TRUST | 50% to less than 75%Code D | No | TRUSTEE04/2013 | Schedule BPDF page 242 |
| 19 | CGKL I, LLCMEMBERDomestic entity | REEF MANAGER, LLC | 75% or moreCode E | Yes | MEMBER12/2017 | Schedule BPDF page 242 |
| 20 | AMP CAPITAL INVESTORS INTERNATIONAL HOLDINGS LIMITEDMEMBERForeign entity | AMP CAPITAL INVESTORS US REAL ESTATE, LLC | 75% or moreCode E | No | MEMBER12/2017 | Schedule BPDF page 242 |
| 21 | COLLIMATE CAPITAL PTY LIMITEDSHAREHOLDERForeign entity | AMP CAPITAL INVESTORS INTERNATIONAL HOLDINGS LIMITED | 75% or moreCode E | No | SHAREHOLDER05/2005 | Schedule BPDF page 242 |
| 22 | AMP GROUP HOLDINGS LIMITEDSHAREHOLDERForeign entity | COLLIMATE CAPITAL PTY LIMITED | 75% or moreCode E | No | SHAREHOLDER11/1997 | Schedule BPDF page 242 |
| 23 | AMP LIMITEDSHAREHOLDERForeign entity | AMP GROUP HOLDINGS LIMITED | 75% or moreCode E | No | SHAREHOLDER11/1997 | Schedule BPDF page 242 |
| 24 | DCLJ PARTNERS, LLCMEMBERDomestic entity | CGKL I, LLC | 25% to less than 50%Code C | No | MEMBER10/2018 | Schedule BPDF page 242 |
| 25 | DONALD HENRY KUEMMELERMEMBERIndividual | DCLJ PARTNERS, LLC | 75% or moreCode E | Yes | MEMBER11/2008 | Schedule BPDF page 242 |
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 9/16/2026 9:11:48 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.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 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?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions1 Yes4 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?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 2 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PACIFICCAL DEBT IV, LLCPDF pages 271–273
- Advisory affiliate name — filed text
- PACIFICCAL DEBT IV, LLC
- Regulator name — filed text
- DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CONSENT ORDER IS FINAL AND EFFECTIVE AS OF JUNE 6, 2023.
Other filed details
Description of allegations — filed text
THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA ("DFPI") ALLEGED THAT THE ADVISORY AFFILIATE DID NOT TRANSITION MANAGEMENT OF ITS CALIFORNIA FINANCING LAW ("CFL") LICENSES TO THE NATIONWIDE MULTISTATE LICENSING SYSTEM AND REGISTRY ("NMLS") BY THE REQUIRED DEADLINE.
Sanction detail — filed text
THE CONSENT ORDER IMPOSES AN ADMINISTRATIVE PENALTY OF $2,500 TO BE MADE PAYABLE TO THE DFPI. THE FULL AMOUNT OF THE PENALTY IS PAYABLE BY THE ADVISORY AFFILIATE. THE PENALTY WAS PAID ON MAY 30, 2023.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
PACIFICCAL DEBT IV, 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)
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DESIST AND REFRAIN
3.
Date Initiated (MM/DD/YYYY):
05/01/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Other
Other Product Types:
DEBT - COMMERCIAL REAL ESTATE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA ("DFPI") ALLEGED THAT THE ADVISORY AFFILIATE DID
NOT TRANSITION MANAGEMENT OF ITS CALIFORNIA FINANCING LAW ("CFL") LICENSES TO THE NATIONWIDE MULTISTATE LICENSING SYSTEM AND
REGISTRY ("NMLS") BY THE REQUIRED DEADLINE.
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:
N/A
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):
06/06/2023
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: $ 2,500.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
DESIST AND REFRAIN
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:
THE CONSENT ORDER IMPOSES AN ADMINISTRATIVE PENALTY OF $2,500 TO BE MADE PAYABLE TO THE DFPI. THE FULL AMOUNT OF THE PENALTY
IS PAYABLE BY THE ADVISORY AFFILIATE. THE PENALTY WAS PAID ON MAY 30, 2023.
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 CONSENT ORDER IS FINAL AND EFFECTIVE AS OF JUNE 6, 2023.regulatory · block 2PCCP PATRIOT DEBT VENTURE I, LLCPDF pages 273–275
- Advisory affiliate name — filed text
- PCCP PATRIOT DEBT VENTURE I, LLC
- Regulator name — filed text
- DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA
- Monetary/Fine Amount — filed text
- $ 2,500.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CONSENT ORDER IS FINAL AND EFFECTIVE AS OF JUNE 6, 2023.
Other filed details
Description of allegations — filed text
THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA ("DFPI") ALLEGED THAT THE ADVISORY AFFILIATE DID NOT TRANSITION MANAGEMENT OF ITS CALIFORNIA FINANCING LAW ("CFL") LICENSES TO THE NATIONWIDE MULTISTATE LICENSING SYSTEM AND REGISTRY ("NMLS") BY THE REQUIRED DEADLINE.
Sanction detail — filed text
THE CONSENT ORDER IMPOSES AN ADMINISTRATIVE PENALTY OF $2,500 TO BE MADE PAYABLE TO THE DFPI. THE FULL AMOUNT OF THE PENALTY IS PAYABLE BY THE ADVISORY AFFILIATE. THE PENALTY WAS PAID ON MAY 30, 2023.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
PCCP PATRIOT DEBT VENTURE
I, 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)
DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
DESIST AND REFRAIN
3.
Date Initiated (MM/DD/YYYY):
05/01/2023
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Other
Other Product Types:
DEBT - COMMERCIAL REAL ESTATE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT OF FINANCIAL PROTECTION AND INNOVATION OF THE STATE OF CALIFORNIA ("DFPI") ALLEGED THAT THE ADVISORY AFFILIATE DID
NOT TRANSITION MANAGEMENT OF ITS CALIFORNIA FINANCING LAW ("CFL") LICENSES TO THE NATIONWIDE MULTISTATE LICENSING SYSTEM AND
REGISTRY ("NMLS") BY THE REQUIRED DEADLINE.
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:
N/A
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):
06/06/2023
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: $ 2,500.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
DESIST AND REFRAIN
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:
THE CONSENT ORDER IMPOSES AN ADMINISTRATIVE PENALTY OF $2,500 TO BE MADE PAYABLE TO THE DFPI. THE FULL AMOUNT OF THE PENALTY
IS PAYABLE BY THE ADVISORY AFFILIATE. THE PENALTY WAS PAID ON MAY 30, 2023.
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 CONSENT ORDER IS FINAL AND EFFECTIVE AS OF JUNE 6, 2023.* 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.