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 Alliance Partners 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 Alliance Partners LLC.
Reported ownership and control details
Form ADV · Filing date 2026-07-02 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | HUGH MICHAEL O'CONNORTREASURERIndividual | ALLIANCE PARTNERS LLC | Less than 5%Code NA | Yes | TREASURER01/2018 | Schedule APDF page 26 |
| 2 | FORBRIGHT BANKMEMBERDomestic entity | ALLIANCE PARTNERS LLC | 75% or moreCode E | Yes | MEMBER01/2018 | Schedule APDF page 26 |
| 3 | LORI HELLER BETTINGERCO-PRESIDENTIndividual | ALLIANCE PARTNERS LLC | Less than 5%Code NA | Yes | CO-PRESIDENT01/2020 | Schedule APDF page 26 |
| 4 | VINCENT TWOMEYCO-PRESIDENTIndividual | ALLIANCE PARTNERS LLC | Less than 5%Code NA | Yes | CO-PRESIDENT01/2020 | Schedule APDF page 26 |
| 5 | Derek A AndersonCHIEF COMPLIANCE OFFICERIndividual | ALLIANCE PARTNERS LLC | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER03/2025 | Schedule APDF page 26 |
| 6 | MICHAEL ANDREW HOUSLEYCHIEF FINANCIAL OFFICER, SECRETARYIndividual | ALLIANCE PARTNERS LLC | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER, SECRETARY02/2017 | Schedule APDF page 26 |
| 7 | FORBRIGHT, INC.SHAREHOLDERDomestic entity | FORBRIGHT BANK | 75% or moreCode E | Yes | SHAREHOLDER01/2018 | Schedule BPDF page 26 |
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 7/2/2026 3:26:58 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 actions2 Yes3 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions4 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 2 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1FORBRIGHT BANKPDF pages 27–29
- Advisory affiliate name — filed text
- FORBRIGHT BANK
- Regulator name — filed text
- FEDERAL DEPOSIT INSURANCE CORPORATION AND OFFICE OF THE COMMISSIONER OF FINAICAL REGULATION, STATE OF MARYLAND
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
ON DECEMBER 14, 2022 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.
Other filed details
Description of allegations — filed text
THE FDIC AND OCFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES OR VIOLATIONS OF LAW OR REGULATION RELATING TO, AMONG OTHER THINGS, TO DEFICIENCIES AND WEAKNESSES IN THE BANK'S ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM PROGRAMS.
Sanction detail — filed text
FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMPROVE, CONSISTENT WITH THE ROLE AND EXPERTISE EXPECTED FOR DIRECTORS OF BANKS OF COMPARABLE SIZE AND RISK, ITS SUPERVISION AND DIRECTION OF THE AML/CFT PROGRAM; (B) ENSURE THAT THE AML/CFT PROGRAM IS REASONABLY DESIGNED TO ASSURE AND MONITOR THE BANK'S COMPLIANCE WITH THE BSA AND PROVIDE CLEAR AND UP-TO-DATE GUIDANCE TO BANK STAFF; (C) SUBMIT A PROPOSED ENGAGEMENT LETTER OR CONTRACT FOR REVIEW AND NON-OBJECTION TO RETAIN A QUALIFIED FIRM ACCEPTABLE TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER TO CONDUCT A REVIEW OF ALL ACCOUNTS AND TRANSACTION ACTIVITY FOR THE SPECIFIED TIME PERIOD; (D) ENSURE THAT THE BANK COMPLIES WITH THE REQUIREMENTS OF THE LAWS AND REGULATIONS ADMINISTERED BY THE OFFICE OF FOREIGN ASSETS CONTROL AND THAT THE PROGRAM ESTABLISHED BY THE BANK ENABLES THE BANK TO COMPLY WITH THE OFAC REQUIREMENTS; (E) ESTABLISH A BOARD AML/CFT COMPLIANCE COMMITTEE WITH THE RESPONSIBILITY OF OVERSEEING THE BANK'S COMPLIANCE WITH THIS ORDER, THE BSA, AND THE AML/CFT PROGRAM; (F) ENSURE THAT ALL STEPS NECESSARY, CONSISTENT WITH OTHER PROVISIONS OF THIS ORDER AND SOUND BANKING PRACTICES, ARE TAKEN TO ELIMINATE AND CORRECT ANY VIOLATIONS OF LAW OR REGULATION CITED AND APPROPRIATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (G) FURNISH TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER; (H) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY.
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: FORBRIGHT BANK (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) FEDERAL DEPOSIT INSURANCE CORPORATION AND OFFICE OF THE COMMISSIONER OF FINAICAL REGULATION, STATE OF MARYLAND 2. Principal Sanction: Other Other Sanctions: CONSENT 3. Date Initiated (MM/DD/YYYY): 12/14/2022 Exact Explanation If not exact, provide explanation: UPON FURTHER REVIEW, THE FIRM HAS REVISED ITS POSITION AND DETERMINED THAT THE CONSENT ORDER ENTERED INTO ON DECEMBER 14, 2022, BETWEEN FORBRIGHT BANK AND THE FDIC/OCFR OF MARYLAND IS DISCLOSABLE PURSUANT TO ITEMS 11.D(2) AND 11.D(4). THE FIRM'S INITIAL INTERPRETATION OF ITEMS 11.D(2) AND 11.D(4) WAS THAT THE CONSENT ORDER INVOLVING THE FIRM'S ADVISORY AFFILIATE WAS NOT MATERIAL TO THE FIRM'S INVESTMENT-RELATED ACTIVITIES. ACCORDINGLY, THE FIRM IS AMENDING ITS DISCLOSURES. 4. Docket/Case Number: FDIC-22-0152B 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Banking Products (Other than CD(s)) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FDIC AND OCFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN UNSAFE OR UNSOUND BANKING PRACTICES OR VIOLATIONS OF LAW OR REGULATION RELATING TO, AMONG OTHER THINGS, TO DEFICIENCIES AND WEAKNESSES IN THE BANK'S ANTI-MONEY LAUNDERING/COUNTERING THE FINANCING OF TERRORISM PROGRAMS. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 12/14/2022 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: STIPULATION AND CONSENT TO THE ISSUANCE OF A CONSENT ORDER. 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: FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMPROVE, CONSISTENT WITH THE ROLE AND EXPERTISE EXPECTED FOR DIRECTORS OF BANKS OF COMPARABLE SIZE AND RISK, ITS SUPERVISION AND DIRECTION OF THE AML/CFT PROGRAM; (B) ENSURE THAT THE AML/CFT PROGRAM IS REASONABLY DESIGNED TO ASSURE AND MONITOR THE BANK'S COMPLIANCE WITH THE BSA AND PROVIDE CLEAR AND UP-TO-DATE GUIDANCE TO BANK STAFF; (C) SUBMIT A PROPOSED ENGAGEMENT LETTER OR CONTRACT FOR REVIEW AND NON-OBJECTION TO RETAIN A QUALIFIED FIRM ACCEPTABLE TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER TO CONDUCT A REVIEW OF ALL ACCOUNTS AND TRANSACTION ACTIVITY FOR THE SPECIFIED TIME PERIOD; (D) ENSURE THAT THE BANK COMPLIES WITH THE REQUIREMENTS OF THE LAWS AND REGULATIONS ADMINISTERED BY THE OFFICE OF FOREIGN ASSETS CONTROL AND THAT THE PROGRAM ESTABLISHED BY THE BANK ENABLES THE BANK TO COMPLY WITH THE OFAC REQUIREMENTS; (E) ESTABLISH A BOARD AML/CFT COMPLIANCE COMMITTEE WITH THE RESPONSIBILITY OF OVERSEEING THE BANK'S COMPLIANCE WITH THIS ORDER, THE BSA, AND THE AML/CFT PROGRAM; (F) ENSURE THAT ALL STEPS NECESSARY, CONSISTENT WITH OTHER PROVISIONS OF THIS ORDER AND SOUND BANKING PRACTICES, ARE TAKEN TO ELIMINATE AND CORRECT ANY VIOLATIONS OF LAW OR REGULATION CITED AND APPROPRIATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (G) FURNISH TO THE DEPUTY REGIONAL DIRECTOR AND THE COMMISSIONER WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER; (H) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY. 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 DECEMBER 14, 2022 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.
regulatory · block 2FORBRIGHT BANKPDF pages 29–31
- Advisory affiliate name — filed text
- FORBRIGHT BANK
- Regulator name — filed text
- FEDERAL DEPOSIT INSURANCE CORPORATION AND OFFICE OF FINANCIAL REGULATION, STATE OF MARYLAND
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
ON MAY 3, 2024 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.
Other filed details
Description of allegations — filed text
THE FDIC AND OFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN (I) UNSAFE AND UNSOUND BANKING PRACTICES RELATING TO, AMONG OTHER THINGS, DEFICIENCIES AND WEAKNESSES IN THE SUPERVISION AND DIRECTION OF MANAGEMENT BY THE BANK'S BOARD OF DIRECTORS; MANAGEMENT PERFORMANCE; RISK MANAGEMENT; CAPITAL PLANNING; LIQUIDITY AND FUNDS MANAGEMENT; AND INTEREST RATE RISK; (II) VIOLATIONS OF LAW OR REGULATIONS, INCLUDING SECTION 22(H) OF THE FEDERAL RESERVE ACT AS IMPLEMENTED BY 12 C.F.R. § 215, AND MARYLAND ANNOTATED CODE, FINANCIAL INSTITUTIONS ARTICLE 2 § 3403(B); AND (III) NONCONFORMANCE WITH THE INTERAGENCY GUIDELINES ESTABLISHING STANDARDS FOR SAFETY AND SOUNDNESS, APPENDIX A TO 12 C.F.R. PART 364 WITH RESPECT TO THE BANK'S INTERNAL CONTROLS AND INFORMATION SYSTEMS, AND INTEREST RATE EXPOSURE.
Sanction detail — filed text
FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMMEDIATELY INCREASE, COMMENSURATED WITH THE SIZE OF THE BANK AND THE NATURE, SCOPE, COMPLEXITY, AND RISK OF BANK ACTIVITIES, ITS SUPERVISION AND DIRECTION OF BANK MANAGEMENT, AND ITS OVERSIGHT AND MONITORING OF THE BANK'S FINANCIAL CONDITION, RISK PROFILE, OPERATIONS; (B) ENSURE THAT THE BANK'S FUNDS MANAGEMENT PROGRAM, RELATED POLICIES & PROCEDURES, AND THE LIQUIDITY ANALYSIS IS REVISED TO ADEQUATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (C) REVISE ITS CAPITAL PLANNING AND MONITORING FRAMEWORK AND SUBMIT IT TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (D) ENSURE IT ADDRESSES THE DEFICIENCIES AND WEAKNESSES RELATED TO INTEREST RATE RISK MANAGEMENT; (E) ENSURE THAT THE BANK DOES NOT DECLARE OR PAY ANY CASH DIVIDENDS OR OTHER CAPITAL DISTRIBUTIONS WITHOUT THE PRIOR NON-OBJECTION OF THE DRD AND THE COMMISSIONER; (F) ENSURE THAT THE BANK'S TOTAL ASSETS, DO NOT INCREASE BY MORE THAN 5% DURING ANY CALENDAR QUARTER AND DO NOT INCREASE BY MORE THAN 10% ANNUALLY; (G) SUBMIT A WRITTEN PLAN DETAILING HOW THE BOARD WILL ENSURE THE REQUIREMENTS OF THIS ORDER ARE MET IN A TIMELY MANNER TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (H) TO FURNISH WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER TO THE DRD AND THE COMMISSIONER; (I) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY.
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: FORBRIGHT BANK (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) FEDERAL DEPOSIT INSURANCE CORPORATION AND OFFICE OF FINANCIAL REGULATION, STATE OF MARYLAND 2. Principal Sanction: Other Other Sanctions: CONSENT 3. Date Initiated (MM/DD/YYYY): 05/03/2024 Exact Explanation If not exact, provide explanation: THE FIRM CONDUCTED A THOROUGH REVIEW TO ENSURE THE ACCURACY AND COMPLETENESS OF ITS ASSESSMENT BEFORE DETERMINING THAT THE CONSENT ORDER INVOLVING THE FIRM'S ADVISORY AFFILIATE, FORBRIGHT BANK, AND THE FDIC/OFR OF MARYLAND IS DISCLOSABLE CONCERNING THE FIRM'S INVESTMENT-RELATED ACTIVITIES. ACCORDINGLY, THE FIRM IS ADDING A DISCLOSURE REPORTING PAGE SPECIFICALLY FOR THIS CONSENT ORDER. 4. Docket/Case Number: FDIC-23-0125B 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Debt - Corporate Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FDIC AND OFR DETERMINED, AND FORBRIGHT BANK NEITHER ADMITS NOR DENIES, THAT THE BANK HAS ENGAGED IN (I) UNSAFE AND UNSOUND BANKING PRACTICES RELATING TO, AMONG OTHER THINGS, DEFICIENCIES AND WEAKNESSES IN THE SUPERVISION AND DIRECTION OF MANAGEMENT BY THE BANK'S BOARD OF DIRECTORS; MANAGEMENT PERFORMANCE; RISK MANAGEMENT; CAPITAL PLANNING; LIQUIDITY AND FUNDS MANAGEMENT; AND INTEREST RATE RISK; (II) VIOLATIONS OF LAW OR REGULATIONS, INCLUDING SECTION 22(H) OF THE FEDERAL RESERVE ACT AS IMPLEMENTED BY 12 C.F.R. § 215, AND MARYLAND ANNOTATED CODE, FINANCIAL INSTITUTIONS ARTICLE 2 § 3403(B); AND (III) NONCONFORMANCE WITH THE INTERAGENCY GUIDELINES ESTABLISHING STANDARDS FOR SAFETY AND SOUNDNESS, APPENDIX A TO 12 C.F.R. PART 364 WITH RESPECT TO THE BANK'S INTERNAL CONTROLS AND INFORMATION SYSTEMS, AND INTEREST RATE EXPOSURE. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 05/03/2024 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: STIPULATION AND CONSENT TO THE ISSUANCE OF THE CONSENT ORDER 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: FORBRIGHT BANK HAS CONSENTED, WITHOUT ADMITTING OR DENYING ANY CHARGES OF UNSAFE OR UNSOUND BANKING PRACTICES, TO (A) IMMEDIATELY INCREASE, COMMENSURATED WITH THE SIZE OF THE BANK AND THE NATURE, SCOPE, COMPLEXITY, AND RISK OF BANK ACTIVITIES, ITS SUPERVISION AND DIRECTION OF BANK MANAGEMENT, AND ITS OVERSIGHT AND MONITORING OF THE BANK'S FINANCIAL CONDITION, RISK PROFILE, OPERATIONS; (B) ENSURE THAT THE BANK'S FUNDS MANAGEMENT PROGRAM, RELATED POLICIES & PROCEDURES, AND THE LIQUIDITY ANALYSIS IS REVISED TO ADEQUATELY ADDRESS THE DEFICIENCIES AND WEAKNESSES IDENTIFIED; (C) REVISE ITS CAPITAL PLANNING AND MONITORING FRAMEWORK AND SUBMIT IT TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (D) ENSURE IT ADDRESSES THE DEFICIENCIES AND WEAKNESSES RELATED TO INTEREST RATE RISK MANAGEMENT; (E) ENSURE THAT THE BANK DOES NOT DECLARE OR PAY ANY CASH DIVIDENDS OR OTHER CAPITAL DISTRIBUTIONS WITHOUT THE PRIOR NON-OBJECTION OF THE DRD AND THE COMMISSIONER; (F) ENSURE THAT THE BANK'S TOTAL ASSETS, DO NOT INCREASE BY MORE THAN 5% DURING ANY CALENDAR QUARTER AND DO NOT INCREASE BY MORE THAN 10% ANNUALLY; (G) SUBMIT A WRITTEN PLAN DETAILING HOW THE BOARD WILL ENSURE THE REQUIREMENTS OF THIS ORDER ARE MET IN A TIMELY MANNER TO THE DRD AND THE COMMISSIONER FOR REVIEW AND COMMENT; (H) TO FURNISH WRITTEN PROGRESS REPORTS DETAILING THE FORM, MANNER, AND RESULTS OF ANY ACTIONS TAKEN TO SECURE COMPLIANCE WITH THIS ORDER TO THE DRD AND THE COMMISSIONER; (I) PROVIDE EITHER A COPY OF THIS ORDER OR AN ACCURATE AND COMPLETE DESCRIPTION OF ALL MATERIAL ASPECTS OF THE ORDER TO THE BOARD OF DIRECTORS OF ITS PARENT HOLDING COMPANY. 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 MAY 3, 2024 FORBRIGHT ENTERED INTO A CONSENT AGREEMENT TO CONDUCT A REVIEW OF ITS SUPERVISORY SYSTEMS AND PROCEDURES IN SPECIFIC AREAS IDENTIFIED IN THE CONSENT ORDER. FORBRIGHT NEITHER ADMITTED NOR DENIED THE FINDINGS AND CONSENTED TO THEM AS DESCRIBED.
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