Transamerica Financial Advisors, 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
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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY, INC. ("FINRA")
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
01/20/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2012034686802
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):
FINRA ALLEGED THAT TRANSAMERICA FINANCIAL ADVISORS, INC. VIOLATED FINRA RULES 1122 AND 2010 BY FILING AN INACCURATE FORM U5 AND A
MISLEADING AND INACCURATE AMENDED FORM U5 WITH FINRA.
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):
01/20/2015
 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: $ 50,000.00
 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: 
THE FIRM IS CENSURED AND FINED $50,000.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FILED WITH
FINRA AN INACCURATE FORM U5 ON BEHALF OF A FORMER REGISTERED REPRESENTATIVE THAT FAILED TO DISCLOSE THAT THE REPRESENTATIVE HAD
BEEN CHARGED WITH A FELONY PRIOR TO HER TERMINATION. THE FINDINGS STATED THAT THE REPRESENTATIVE WAS CHARGED WITH A FELONY
DURING THE PERIOD OF HER EMPLOYMENT AND REGISTRATION WITH THE FIRM, AND THE FIRM WAS AWARE OF THIS INFORMATION DURING HER
EMPLOYMENT. THE FINDINGS ALSO STATED THAT THE FIRM FILED WITH FINRA AN INACCURATE AND MISLEADING AMENDED FORM U5 FOR THE SAME
REPRESENTATIVE THAT STATED THAT SHE HAD NOT BEEN CHARGED WITH A FELONY PRIOR TO HER TERMINATION AND THAT SHE HAD NOT DISCLOSED
HER ARREST AT THE TIME OF HER RESIGNATION.

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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/27/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014042291801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
NON-TRADED REAL ESTATE INVESTMENT TRUSTS (REITS) AND BUSINESS DEVELOPMENT COMPANIES (BDCS)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
IDENTIFY AND APPLY VOLUME DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF NON-TRADED REAL ESTATE INVESTMENT TRUSTS (REITS)
AND BUSINESS DEVELOPMENT COMPANIES (BDCS), RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $51,000.
ALSO, THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY SYSTEM AND WRITTEN
SUPERVISORY PROCEDURES WITH RESPECT TO THE SALE OF NON-TRADED REITS AND BDCS. THE FIRM DID NOT HAVE PROCEDURES IN PLACE
REASONABLY DESIGNED TO IDENTIFY ACCOUNTS THAT WOULD BE ELIGIBLE FOR VOLUME DISCOUNTS. THE FIRM RELIED ON ITS ASSOCIATED PERSONS
TO ENSURE ITS CUSTOMERS RECEIVED THE VOLUME DISCOUNTS TO WHICH THEY WERE ENTITLED, BUT FAILED TO PROVIDE ADEQUATE GUIDELINES,
INSTRUCTIONS OR POLICIES FOR ITS ASSOCIATED PERSONS AND SUPERVISORS TO FOLLOW TO DETERMINE WHETHER A CUSTOMER'S PURCHASE
QUALIFIED FOR A VOLUME DISCOUNT AND TO ENSURE THAT THE CUSTOMER WAS MADE AWARE OF THE AVAILABLE DISCOUNT.

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):
07/27/2015
 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: $ 85,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
RESTITUTION IN THE AMOUNT OF $51,066.08 (PLUS INTEREST)
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 FIRM WAS CENSURED, FINED $85,000, AND ORDERED TO PAY RESTITUTION IN THE AMOUNT OF $51,066.08 (PLUS INTEREST) TO
CUSTOMERS.
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).
IN ADDITION TO THE CENSURE, FINE AND RESTITUTION, THE FIRM WAS ORDERED TO CERTIFY THAT IT HAS CORRECTED ITS SYSTEMS AND
PROCEDURES WITH RESPECT TO THE SALE OF NON-TRADED REAL ESTATE INVESTMENT TRUSTS (REITS) AND BUSINESS DEVELOPMENT COMPANIES
(BDCS). ALSO, THE FIRM IS REQUIRED TO REVIEW ALL NON-TRADED REIT AND BDC SALES IT MADE DURING THE RELEVANT PERIOD, AND CERTIFY THAT
IT HAS IDENTIFIED ALL TRANSACTIONS FOR WHICH A CUSTOMER DID NOT RECEIVE THE VOLUME DISCOUNT FOR WHICH IT WAS ELIGIBLE.

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:
8217
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TRANSAMERICA CAPITAL, INC.
(For individuals, Last, First,
Middle)
CRD
Number:
114537
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
AEGON ASSET MANAGEMENT
US
(For individuals, Last, First,
Middle)
CRD
Number:
107376
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TRANSAMERICA ASSET
MANAGEMENT, INC.
(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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE DISGORGEMENT PREJUDGEMENT INTEREST CIVIL AND ADMINSTRATIVE PENALTY(IES)/FINE(S)
3.
Date Initiated (MM/DD/YYYY): 
08/27/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-18681
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other

Other Product Types: 
QUANTITATIVE INVESTMENT MODELS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON AUGUST 27,2018, THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") INSTITUTED A SETTLED PUBLIC ADMINSTRATIVE AND CEASE-
AND-DESIST PROCEEDING AGAINST AEGON USA INVESTMENT MANAGEMENT, LLC ("AUIM"), TRANSAMERICA ASSET MANAGEMENT, INC., TRANSAMERICA
CAPITAL, INC., AND TRANSMERICA FINANCIAL ADVISORS, INC. ("TFA") AS TO TFA, THE COMMISSION FOUND THAT BETWEEN JULY 2011 AND JUNE 2015,
TFA VIOLATED THE FEDERAL SECURITIES LAWS AND RULES THEREUNDER WHILE SELLING CERTAIN SEPARATELY MANAGED ACCOUNT 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:
Settled
11. Resolution Date (MM/DD/YYYY):
08/27/2018
 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: $ 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: 
PURSUANT TO THE TERMS OF THE ORDER, TFA HAS PAID A TOTAL OF $2,785,000 INTO A SETTLEMENT FUND, WHICH AMOUNT INCLUDES A
PENALTY OF $800,000, DISGORGEMENT OF $1,700,000 AND PRE-JUDGMENT INTEREST OF $258,000
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 AUGUST 27, 2018 THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ISSUED A SETTLED ORDER INSTITUTING ADMINSTRATIVE AND
CEASE-AND-DESIST PROCEEDSINGS AGAINST AEGON USA INVESTMENT MANAGEMENT, LLC (AUIM), TRANSAMERICA ASSET MANAGEMENT, INC.,
TRANSAMERICA CAPITAL INC. AND TRANSAMERICA FINANCIAL ADVISORS, INC. (TFA) AS TO TFA, THE COMMISSION FOUND THAT BETWEEN JULY 2011
AND JUNE 2015, TFA VIOLATED THE FEDERAL SECURITIES LAWS AND RULES THEREUNDER WHILE SELLING CERTAIN SEPARATELY MANAGED ACCOUNT
PROGRAMS. WITHOUT ADMITTING OR DENYING THE FINDINGS IN THE ORDER, TFA CONSENTED TO A CENSURE AND AGREED TO PAY DISGORGEMENT,
PRE-JUDGMENT INTEREST AND A CIVIL PENALTY.

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE; DISGORGEMENT; PREJUDGMENT INTEREST.
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-19053
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
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):
THE SEC ALLEGED THAT TFA FAILED TO ADEQUATELY DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO A) ITS
RECEIPT OF 12B-1 FEES AND/OR B) ITS SELECTION OF MUTUAL FUNDS SHARE CLASSES THAT PAY SUCH FEES. TFA SELF-REPORTED THIS MATTER TO
THE SEC PURSUANT TO THE SEC DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
03/11/2019
 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:
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: 
PURSUANT TO THE TERMS OF THE ORDER, TFA HAS PAID A TOTAL OF $6,023,072.68 INTO A DISTRIBUTION FUND FOR PAYMENT TO INVESTORS.
THIS AMOUNT INCLUDES $5,364,292.04 IN DISGORGEMENT AND $658,780.64 IN PREJUDGMENT INTEREST.
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 MARCH 11, 2019, THE SECURITIES AND EXCHANGE COMMISSION ("SEC") SIGNED AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-
DESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING
REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER") RELATING TO TFA'S DISCLOSURE OF ITS MUTUAL FUND SHARE CLASS SELECTION
PRACTICES AND THE 12B-1 FEES TFA AND ITS ASSOCIATED PERSONS RECEIVED. SPECIFICALLY, THE SEC ALLEGED THAT TFA FAILED TO ADEQUATELY
DISCLOSE IN ITS FORM ADV OR ELSEWHERE THE CONFLICTS OF INTEREST RELATED TO A) ITS RECEIPT OF 12B-1 FEES AND/OR B) ITS SELECTION OF
MUTUAL FUNDS SHARE CLASSES THAT PAY SUCH FEES. TFA SELF-REPORTED THIS MATTER TO THE SEC PURSUANT TO THE SEC DIVISION OF
ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. TFA HAS SETTLED THIS MATTER WITH THE SEC. THE FIRM AGREED TO A CENSURE,
TO PAY DISGORGEMENT OF $5,364,292.04 PLUS $658,780.64 IN INTEREST, AND TO CEASE AND DESIST FROM VIOLATING CERTAIN SECURITIES LAWS
AND REGULATIONS. THE DISGORGEMENT AND INTEREST WILL BE PAID TO A DISTRIBUTION FUND ("FUND") FOR PAYMENT TO INVESTORS WHO
PURCHASED OR HELD 12B-1 FEE PAYING SHARE CLASS MUTUAL FUNDS IN ADVISORY ACCOUNTS WHEN A LOWER-COST SHARE CLASS OF THE SAME
FUND WAS AVAILABLE TO THE CLIENT. THE ORDER STATES THAT THESE INVESTORS ARE TO RECEIVE FROM THE FUND THE 12B-1 FEES ATTRIBUTABLE
TO THE INVESTOR DURING THE RELEVANT PERIOD, PLUS INTEREST, SUBJECT TO A DE MINIMIS THRESHOLD.

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) 
FINRA
2.
Principal Sanction:
Censure
Other Sanctions: 
FINE, RESTITUTION.
3.
Date Initiated (MM/DD/YYYY): 
12/21/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015048250401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Annuity(ies) - Variable
Other Product Types: 
MUTUAL FUNDS, 529 PLANS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REASONABLY SUPERVISE ITS REGISTERED REPRESENTATIVES' VARIABLE ANNUITY RECOMMENDATIONS AND MADE DISCLOSURES THAT CONTAINED
MATERIALLY INACCURATE INFORMATION OR OMITTED MATERIAL INFORMATION. THE FIRM FAILED TO PROVIDE ADEQUATE TRAINING TO ITS
REPRESENTATIVES REGARDING HOW TO COMPLETE DISCLOSURE FORMS THAT WERE REQUIRED WHEN RECOMMENDING A VARIABLE ANNUITY
EXCHANGE AND FAILED TO PROVIDE ADEQUATE TRAINING TO SUPERVISORS REGARDING HOW THEY SHOULD VERIFY THE INFORMATION ON THE
DISCLOSURE FORMS OR HOW THEY SHOULD USE THAT INFORMATION TO CONDUCT A MEANINGFUL COMPARISON OF OLD AND NEW VARIABLE
ANNUITIES. AS A RESULT, CERTAIN FIRM PRINCIPALS APPROVED VARIABLE ANNUITY EXCHANGES BASED ON DISCLOSURE FORMS THAT CONTAINED
INACCURATE OR MISSING INFORMATION, WHICH EACH HAD THE EFFECT OF MAKING THE EXCHANGE APPEAR TO BE MORE FAVORABLE THAN WAS THE
ACTUAL CASE. IN CERTAIN INSTANCES, THESE MISSTATEMENTS OR OMISSIONS PREVENTED THE FIRM'S REVIEWING PRINCIPALS FROM HAVING A
REASONABLE BASIS TO APPROVE THESE TRANSACTIONS. THE FIRM FAILED TO REASONABLY SURVEIL REPRESENTATIVES' RATES OF VARIABLE ANNUITY
EXCHANGES. THE FIRM FAILED TO REASONABLY SUPERVISE REPRESENTATIVES' VARIABLE ANNUITY SHARE-CLASS RECOMMENDATIONS AND FAILED TO
PROVIDE REASONABLE TRAINING AND GUIDANCE TO ITS REPRESENTATIVES ON THE FEATURES, FEES, AND SURRENDER CHARGES OF THE VARIOUS
SHARE CLASSES. AS A RESULT, CERTAIN REPRESENTATIVES LACKED THE INFORMATION NECESSARY TO COMPARE SHARE CLASSES IN MAKING

SUITABILITY DETERMINATIONS. SIMILARLY, THE FIRM FAILED TO PROVIDE ADEQUATE TRAINING OR GUIDANCE TO ITS SUPERVISORS REGARDING
VARIABLE ANNUITY SHARE CLASSES. CONSEQUENTLY, SUPERVISORS DID NOT IDENTIFY COMMON RED FLAGS, INCLUDING SALES OF C- AND L-SHARE
CONTRACTS TO CUSTOMERS WITH NO SHORT-TERM LIQUIDITY NEEDS OR TO CUSTOMERS WHO INDICATED A LONG-TERM INVESTMENT HORIZON, AND
REPRESENTATIVES WHO RECOMMENDED THAT CUSTOMERS COMBINE A C-SHARE OR L-SHARE PURCHASE WITH A LONG-TERM LIVING BENEFIT RIDER.
THE FIRM ALSO LACKED A REASONABLY DESIGNED SYSTEM TO DETECT RED FLAGS OF INAPPROPRIATE SHARE-CLASS RECOMMENDATIONS. EVEN WHEN
THE FIRM BECAME AWARE OF RED FLAGS REGARDING REPRESENTATIVES' VARIABLE ANNUITY SHARE-CLASS RECOMMENDATIONS, IT FAILED TO TAKE
APPROPRIATE ACTION. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE MUTUAL FUND SALES TO ENSURE THAT
ELIGIBLE CUSTOMERS WHO PURCHASED MUTUAL FUND SHARES RECEIVED THE BENEFIT OF APPLICABLE SALES CHARGE WAIVERS. THE FIRM RELIED
ON ITS REPRESENTATIVES TO DETERMINE THE APPLICABILITY OF SALES CHARGE WAIVERS TO CUSTOMERS' MUTUAL FUND PURCHASES, BUT IT FAILED
TO PROVIDE GUIDANCE TO THE REPRESENTATIVES TO ASSIST THEM IN MAKING THIS DETERMINATION AND FAILED TO ESTABLISH A SYSTEM TO VERIFY
WHETHER WAIVERS WERE PROPERLY APPLIED. AS A RESULT, THE FIRM FAILED TO APPLY SALES CHARGE WAIVERS TO CERTAIN MUTUAL FUND
PURCHASES MADE BY ELIGIBLE CUSTOMERS. THESE SALES CAUSED CUSTOMERS TO PAY HIGHER FEES THAN THEY WERE ACTUALLY REQUIRED TO PAY.
THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND FAILED TO ESTABLISH, MAINTAIN,
AND ENFORCE WRITTEN PROCEDURES REASONABLY DESIGNED TO SUPERVISE THE SUITABILITY OF 529 SAVINGS PLAN SHARE-CLASS
RECOMMENDATIONS. THE FIRM DID NOT PROVIDE ADEQUATE GUIDANCE TO REPRESENTATIVES REGARDING THE IMPORTANCE OF CONSIDERING
SHARE-CLASS DIFFERENCES WHEN RECOMMENDING 529 PLANS AND DID NOT PROVIDE SUPERVISORS WITH THE INFORMATION NECESSARY TO
PROPERLY EVALUATE THE SUITABILITY OF THE RECOMMENDATIONS.
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):
12/21/2020
 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: $ 4,400,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
INTEREST ON A PORTION OF RESTITUTION.
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 FIRM WAS CENSURED, FINED $4,400,000 AND ORDERED TO PAY $4,354,160 IN RESTITUTION TO CUSTOMERS, OF WHICH $321,167 ALSO
REQUIRES PAYMENT OF INTEREST.
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).