Paramount Group Real Estate Advisor LLC

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:
161324
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
PARAMOUNT GROUP REAL
ESTATE ADVISOR 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) 
U.S. SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST CENSURE
3.
Date Initiated (MM/DD/YYYY): 
07/06/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
INVESTMENT ADVISERS ACT OF 1940 RELEASE NO. 4726 (JULY 6, 2017)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REAL ESTATE PRIVATE EQUITY FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ALLEGED THAT PARAMOUNT GROUP REAL ESTATE ADVISOR LLC ("PARAMOUNT") CAUSED PARAMOUNT GROUP REAL ESTATE FUND III, L.P.
("FUND III") TO SELL ONE OF ITS INVESTMENTS IN REAL PROPERTY, A PARKING GARAGE, TO PARAMOUNT GROUP RESIDENTIAL DEVELOPMENT FUND,
L.P. ("RDF"). IN CONNECTION WITH THE TRANSACTION, THE SEC ALLEGED THAT PARAMOUNT FAILED TO CAUSE RDF TO REIMBURSE FUND III FOR
CERTAIN DEVELOPMENT EXPENSES FUND III HAD INCURRED BEFORE THE SALE, DESPITE PARAMOUNT'S COMMITMENT TO FUND III'S INVESTOR
ADVISORY COMMITTEE ("FUND III IAC") AT THE TIME THE FUND III IAC APPROVED THE SALE THAT THE REIMBURSEMENT WOULD BE MADE. FOLLOWING
THE APPRAISAL PROCESS, PARAMOUNT DECIDED NOT TO CAUSE RDF TO REIMBURSE FUND III FOR THE DEVELOPMENT EXPENSES FUND III INCURRED
IN AN EFFORT TO GET THE GARAGE UPZONED BEFORE THE SALE. IN PARAMOUNT'S VIEW, THE FINAL PRICE RDF PAID TO FUND III ALREADY REFLECTED
THE INCREASED VALUE THAT WOULD RESULT FROM THE UPZONING, AND RELATED EXPENSES, BECAUSE ONE OF THE TWO APPRAISALS ULTIMATELY

USED TO CALCULATE THE PURCHASE PRICE EFFECTIVELY ASSUMED THE UPZONING WOULD BE ACHIEVED. THE SEC ALLEGED THAT PARAMOUNT
IMPROPERLY FAILED TO SEEK APPROVAL FROM THE FUND III IAC, OR THE FUND III LIMITED PARTNERS, TO ELIMINATE THE REIMBURSEMENT
REQUIREMENT AS A CONDITION OF THE SALE, AND FAILED TO DISCLOSE ITS DECISION TO THE FUND III IAC OR THE FUND III LIMITED PARTNERS THAT
NO SUCH REIMBURSEMENT WOULD BE MADE. AT THE TIME OF THE SALE, PARAMOUNT SERVED AS INVESTMENT ADVISER TO BOTH FUND III AND RDF, OF
WHICH PARAMOUNT AND ITS AFFILIATES OWNED 3% AND 26.7%, RESPECTIVELY. BASED ON THE FOREGOING CONDUCT, THE SEC ALLEGED THAT
PARAMOUNT VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT, AND RULE 206(4)-8 THEREUNDER.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
07/06/2017
 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: $ 250,000.00
 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: 
PARAMOUNT WAS ORDERED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $250,000, WHICH PARAMOUNT HAS PAID.
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 APRIL 25, 2017, PARAMOUNT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") IN CONNECTION WITH AN ADMINISTRATIVE PROCEEDING
PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940. THE OFFER WAS PRESENTED TO THE SEC AND THE SEC
DETERMINED TO ACCEPT IT. SOLELY FOR THE PURPOSE OF PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE SEC, OR TO WHICH THE SEC IS A
PARTY, PARAMOUNT AGREED TO CONSENT TO AN ORDER IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER (THE "ORDER") WITHOUT
ADMITTING OR DENYING THE MATTERS SET FORTH THEREIN (OTHER THAN THOSE RELATING TO THE JURISDICTION OF THE SEC OVER IT AND THE
SUBJECT MATTER OF THE ACTION). THE ORDER, WHICH WAS ENTERED ON JULY 6, 2017, RESOLVED THE SEC'S ALLEGATIONS THAT ARE DESCRIBED
ABOVE UNDER ITEM 7.