Firm profile

Lifemark Securities Corp.

ROCHESTER, NYCRD 16204Registration Status: ApprovedEffective since October 17, 2007SEC # 801-68438Latest ADV March 9, 2026

Lifemark Securities Corp. is an SEC registered investment adviser organized as a corporation with a primary office location in Rochester, NY. Its latest Form ADV filing, dated March 9, 2026, reports $425M in regulatory assets under management, 78 employees, 75 offices, and 1,053 accounts.

Assets Under Management
$425M
Employees
78
Offices
75 offices
Total Clients
1,053

Associated firm names

3 names listed
  • LIFEMARK SECURITIES
  • PROCORP SECURITIES INCORPORATED
  • LIFEMARK SECURITIES CORP.

Leadership

3 roles identified
CEOJames Joseph Prisco
CCOAlexandre Jr. Georgiev
CCOJames Joseph Prisco

Advisory services offered

3 types reported
Financial Planning Services
Portfolio management for individuals and small businesses
Selection of other advisers

Fee models offered

3 types reported
Asset based fees
Fixed fees
Hourly charges

Offices & Contact

Primary office

ROCHESTER, New York, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

New York

ROCHESTERPrimary office · EAST NORTHPORT · MT VERNON · COPIAGUE · UTICA

Arizona

SCOTTSDALE · CAREFREE

California

PITTSBURG

Colorado

CENTENNIAL

Connecticut

NAUGATUCK

Florida

JACKSONVILLE · CLEARWATER · NAPLES

Georgia

ALPHARETTA

Maine

BRUNSWICK

Michigan

LIVONIA

Missouri

HERMANN

New Jersey

LIVINGSTON

Pennsylvania

SHREWSBURY

Virginia

LEESBURG

20 office records listed · 75 total offices reported. 6 additional office addresses are undisclosed and are not mapped. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$425Mas of March 9, 2026
Discretionary100.0%
$425M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 93.6% of total clients.
Top client categories% of clientsClients
1
Individuals
93.6%
986
2
HNWI
6.4%
67

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$425M
Total Accounts1,053
10Y AUM Change+$386M (+977.6%)

Private Funds

Private funds reported by Lifemark Securities Corp.

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees78
Clients per Employee14:1
10Y Employee Change+52 (+200.0%)

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

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
VINCENT JR MICCICHEDirect owner · Schedule AInterest in LIFEMARK SECURITIES CORP.
25% to < 50%
ANDREW JOSEPH KALINOWSKIDirect owner · Schedule AInterest in LIFEMARK SECURITIES CORP.
25% to < 50%
JAMES JOSEPH PRISCODirect owner · Schedule AInterest in LIFEMARK SECURITIES CORP.
25% to < 50%
JAMES JOSEPH PRISCODirect owner · Schedule AInterest in LIFEMARK SECURITIES CORP.
25% to < 50%

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 Lifemark Securities Corp..

No indirect ownership information reported in the source’s Schedule B.

Reported ownership and control details

Form ADV · Filing date 2026-03-09 · Schedules A and B

5 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1VINCENT JR MICCICHETREASURER/ FINOP/PFO/POOIndividualLIFEMARK SECURITIES CORP.25% to less than 50%Code CYesTREASURER/ FINOP/PFO/POO02/2005Schedule APDF page 31
2ANDREW JOSEPH KALINOWSKIVP / BOARD MEMBER/SECRETARYIndividualLIFEMARK SECURITIES CORP.25% to less than 50%Code CYesVP / BOARD MEMBER/SECRETARY04/1983Schedule APDF page 31
3JAMES JOSEPH PRISCOPRESIDENT / BOARD MEMBERIndividualLIFEMARK SECURITIES CORP.25% to less than 50%Code CYesPRESIDENT / BOARD MEMBER02/2005Schedule APDF page 32
4ALEXANDRE JR. GEORGIEVCCO OF THE RIA / DIRECTOR OF OPERATIONSIndividualLIFEMARK SECURITIES CORP.Less than 5%Code NANoCCO OF THE RIA / DIRECTOR OF OPERATIONS03/2021Schedule APDF page 32
5JAMES JOSEPH PRISCOCHIEF EXECUTIVE OFFICER/ CHIEF COMPLIANCE OFFICERIndividualLIFEMARK SECURITIES CORP.25% to less than 50%Code CYesCHIEF EXECUTIVE OFFICER/ CHIEF COMPLIANCE OFFICER01/2022Schedule APDF page 32

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 3/9/2026 4:05:13 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.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
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 actions3 Yes2 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?Yes
  • 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?Yes
  • 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?Yes
DOther regulatory actions3 Yes2 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?Yes
  • 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 actions3 Yes1 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?Yes
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • 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?Yes
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 proceedings1 Yes3 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?Yes
  • 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 10 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 1DERBIN, JOHN, MICHAELPDF pages 32–35
Advisory affiliate name — filed text
DERBIN, JOHN, MICHAEL
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 2,500.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, DERBIN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPERSONATED A CUSTOMER ON A TELEPHONE CALL TO A FINANCIAL SERVICES COMPANY. THE FINDINGS STATED THAT DERBIN'S CUSTOMER WANTED TO TRANSFER HER RETIREMENT PLAN FROM ONE FUND PROVIDER TO ANOTHER. DERBIN ATTEMPTED A THREE-WAY TELEPHONE CALL WITH THE EXISTING FUND PROVIDER, THE CUSTOMER AND HIMSELF FOR THE SOLE PURPOSE OF DETERMINING THE TYPE OF RETIREMENT ACCOUNT THE CUSTOMER HAD. THE CUSTOMER, HOWEVER, DID NOT ANSWER DERBIN'S ATTEMPTED THREE-WAY CALL. ON THE ENSUING PHONE CALL BETWEEN DERBIN AND THE FUND PROVIDER, DERBIN IDENTIFIED HIMSELF AS THE CUSTOMER. DERBIN PROVIDED THE FUND PROVIDER WITH THE CUSTOMER'S DATE OF BIRTH, SOCIAL SECURITY NUMBER, MAIDEN NAME, AND ACCOUNT NUMBER TO CONVINCE THE FUND PROVIDER THAT HE WAS THE CUSTOMER. HE THEN ASKED THE FUND PROVIDER TO TELL HIM WHAT TYPE OF RETIREMENT PLAN THE CUSTOMER OWNED. THE FUND PROVIDER DID NOT PROVIDE THIS INFORMATION, AND INSTEAD REQUESTED A CALL BACK NUMBER FROM DERBIN, WHICH HE DECLINED TO PROVIDE. THE FUND PROVIDER REFUSED TO PROVIDE DERBIN WITH THE INFORMATION AND ALERTED HIS MEMBER FIRM. WHEN THE FIRM CONFRONTED DERBIN, HE TWICE FALSELY STATED THAT HE BELIEVED THE CUSTOMER WAS ON THE LINE WHEN THE CALL WAS MADE TO THE FUND PROVIDER.
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, DERBIN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPERSONATED A CUSTOMER ON A TELEPHONE CALL TO A FINANCIAL SERVICES COMPANY. THE FINDINGS STATED THAT DERBIN'S CUSTOMER WANTED TO TRANSFER HER RETIREMENT PLAN FROM ONE FUND PROVIDER TO ANOTHER. DERBIN ATTEMPTED A THREE-WAY TELEPHONE CALL WITH THE EXISTING FUND PROVIDER, THE CUSTOMER AND HIMSELF FOR THE SOLE PURPOSE OF DETERMINING THE TYPE OF RETIREMENT ACCOUNT THE CUSTOMER HAD. THE CUSTOMER, HOWEVER, DID NOT ANSWER DERBIN'S ATTEMPTED THREE-WAY CALL. ON THE ENSUING PHONE CALL BETWEEN DERBIN AND THE FUND PROVIDER, DERBIN IDENTIFIED HIMSELF AS THE CUSTOMER. DERBIN PROVIDED THE FUND PROVIDER WITH THE CUSTOMER'S DATE OF BIRTH, SOCIAL SECURITY NUMBER, MAIDEN NAME, AND ACCOUNT NUMBER TO CONVINCE THE FUND PROVIDER THAT HE WAS THE CUSTOMER. HE THEN ASKED THE FUND PROVIDER TO TELL HIM WHAT TYPE OF RETIREMENT PLAN THE CUSTOMER OWNED. THE FUND PROVIDER DID NOT PROVIDE THIS INFORMATION, AND INSTEAD REQUESTED A CALL BACK NUMBER FROM DERBIN, WHICH HE DECLINED TO PROVIDE. THE FUND PROVIDER REFUSED TO PROVIDE DERBIN WITH THE INFORMATION AND ALERTED HIS MEMBER FIRM. WHEN THE FIRM CONFRONTED DERBIN, HE TWICE FALSELY STATED THAT HE BELIEVED THE CUSTOMER WAS ON THE LINE WHEN THE CALL WAS MADE TO THE FUND PROVIDER.

Sanction detail — filed text

IF SUSPENDED OR BARRED, PROVIDE: SANCTION TYPE: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION (LENGTH OF TIME): 10 BUSINESS DAYS START DATE (MM/DD/YYYY): 06/21/2022 END DATE (MM/DD/YYYY): 07/05/2022
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:
3183322
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
DERBIN, JOHN, MICHAEL
(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) 
FINRA
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/24/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2021072595001

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
LIFEMARK SECURITIES CORP.
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, DERBIN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPERSONATED
A CUSTOMER ON A TELEPHONE CALL TO A FINANCIAL SERVICES COMPANY. THE FINDINGS STATED THAT DERBIN'S CUSTOMER WANTED TO TRANSFER
HER RETIREMENT PLAN FROM ONE FUND PROVIDER TO ANOTHER. DERBIN ATTEMPTED A THREE-WAY TELEPHONE CALL WITH THE EXISTING FUND
PROVIDER, THE CUSTOMER AND HIMSELF FOR THE SOLE PURPOSE OF DETERMINING THE TYPE OF RETIREMENT ACCOUNT THE CUSTOMER HAD. THE
CUSTOMER, HOWEVER, DID NOT ANSWER DERBIN'S ATTEMPTED THREE-WAY CALL. ON THE ENSUING PHONE CALL BETWEEN DERBIN AND THE FUND
PROVIDER, DERBIN IDENTIFIED HIMSELF AS THE CUSTOMER. DERBIN PROVIDED THE FUND PROVIDER WITH THE CUSTOMER'S DATE OF BIRTH, SOCIAL
SECURITY NUMBER, MAIDEN NAME, AND ACCOUNT NUMBER TO CONVINCE THE FUND PROVIDER THAT HE WAS THE CUSTOMER. HE THEN ASKED THE
FUND PROVIDER TO TELL HIM WHAT TYPE OF RETIREMENT PLAN THE CUSTOMER OWNED. THE FUND PROVIDER DID NOT PROVIDE THIS INFORMATION,
AND INSTEAD REQUESTED A CALL BACK NUMBER FROM DERBIN, WHICH HE DECLINED TO PROVIDE. THE FUND PROVIDER REFUSED TO PROVIDE
DERBIN WITH THE INFORMATION AND ALERTED HIS MEMBER FIRM. WHEN THE FIRM CONFRONTED DERBIN, HE TWICE FALSELY STATED THAT HE
BELIEVED THE CUSTOMER WAS ON THE LINE WHEN THE CALL WAS MADE TO THE FUND PROVIDER.
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):
05/24/2022
 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: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
IN DETERMINING THE APPROPRIATE SANCTIONS IN THIS MATTER, FINRA CONSIDERED, AMONG OTHER FACTORS, THAT DERBIN'S MEMBER FIRM
SANCTIONED HIM FOR HIS MISCONDUCT, WHICH INCLUDED IMPOSING A $5,000 FINE, A 30 CALENDAR-DAY SUSPENSION, AND A FORFEITURE OF
ALL COMMISSIONS MADE DURING THE SUSPENSION PERIOD. THE FIRM ALSO REQUIRED DERBIN TO COMPLETE TRAINING CONCERNING THE
PROTECTION OF CLIENT INFORMATION AND ETHICAL CONSIDERATIONS FOR REGISTERED REPRESENTATIVES.
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: 
IF SUSPENDED OR BARRED, PROVIDE: SANCTION TYPE: SUSPENSION REGISTRATION CAPACITIES AFFECTED (E.G., GENERAL SECURITIES
PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ALL CAPACITIES, ETC.): ALL CAPACITIES DURATION (LENGTH OF TIME): 10 BUSINESS DAYS
START DATE (MM/DD/YYYY): 06/21/2022 END DATE (MM/DD/YYYY): 07/05/2022
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, DERBIN CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE IMPERSONATED
A CUSTOMER ON A TELEPHONE CALL TO A FINANCIAL SERVICES COMPANY. THE FINDINGS STATED THAT DERBIN'S CUSTOMER WANTED TO TRANSFER
HER RETIREMENT PLAN FROM ONE FUND PROVIDER TO ANOTHER. DERBIN ATTEMPTED A THREE-WAY TELEPHONE CALL WITH THE EXISTING FUND
PROVIDER, THE CUSTOMER AND HIMSELF FOR THE SOLE PURPOSE OF DETERMINING THE TYPE OF RETIREMENT ACCOUNT THE CUSTOMER HAD. THE
CUSTOMER, HOWEVER, DID NOT ANSWER DERBIN'S ATTEMPTED THREE-WAY CALL. ON THE ENSUING PHONE CALL BETWEEN DERBIN AND THE FUND
PROVIDER, DERBIN IDENTIFIED HIMSELF AS THE CUSTOMER. DERBIN PROVIDED THE FUND PROVIDER WITH THE CUSTOMER'S DATE OF BIRTH, SOCIAL
SECURITY NUMBER, MAIDEN NAME, AND ACCOUNT NUMBER TO CONVINCE THE FUND PROVIDER THAT HE WAS THE CUSTOMER. HE THEN ASKED THE
FUND PROVIDER TO TELL HIM WHAT TYPE OF RETIREMENT PLAN THE CUSTOMER OWNED. THE FUND PROVIDER DID NOT PROVIDE THIS INFORMATION,
AND INSTEAD REQUESTED A CALL BACK NUMBER FROM DERBIN, WHICH HE DECLINED TO PROVIDE. THE FUND PROVIDER REFUSED TO PROVIDE
DERBIN WITH THE INFORMATION AND ALERTED HIS MEMBER FIRM. WHEN THE FIRM CONFRONTED DERBIN, HE TWICE FALSELY STATED THAT HE

BELIEVED THE CUSTOMER WAS ON THE LINE WHEN THE CALL WAS MADE TO THE FUND PROVIDER.
regulatory · block 2ZIMNOCH, NATALIA, MPDF pages 35–36
Advisory affiliate name — filed text
ZIMNOCH, NATALIA, M
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:
6653881
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ZIMNOCH, NATALIA, M
(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) 
2.
Principal Sanction:
Other Sanctions: 

3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 3JOHNSON, LEVI, WILLIAMPDF pages 36–38
Advisory affiliate name — filed text
JOHNSON, LEVI, WILLIAM
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.

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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:
1539986
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JOHNSON, LEVI, WILLIAM
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 4WOLTERSTORFF, GEOFFREY, MICHAELPDF pages 38–40
Advisory affiliate name — filed text
WOLTERSTORFF, GEOFFREY, MICHAEL
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:
2711805
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WOLTERSTORFF, GEOFFREY,
MICHAEL
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 5BORN, DEVIN, ASHLEYPDF pages 40–41
Advisory affiliate name — filed text
BORN, DEVIN, ASHLEY
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:
2275635
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BORN, DEVIN, ASHLEY
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 6MCEACHRAN, JOHN, ROBERTPDF pages 41–43
Advisory affiliate name — filed text
MCEACHRAN, JOHN, ROBERT
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:
4668918
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MCEACHRAN, JOHN, ROBERT
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
Show 4 more source blocks
regulatory · block 7WOLTERSTORFF, GEOFFREY, MICHAELPDF pages 43–45
Advisory affiliate name — filed text
WOLTERSTORFF, GEOFFREY, MICHAEL
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:
2711805
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WOLTERSTORFF, GEOFFREY,
MICHAEL
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 8MINTER, MICHAEL, GEOFFREYPDF pages 45–46
Advisory affiliate name — filed text
MINTER, MICHAEL, GEOFFREY
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:
2989575
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MINTER, MICHAEL, GEOFFREY
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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).
regulatory · block 9PDF pages 46–48
Regulator name — filed text
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Monetary/Fine Amount — filed text
$ 85,000.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

THE FIRM SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED. BETWEEN JULY 2020 AND JANUARY 2022, THE FIRM, A DUALLY REGISTERED BROKER-DEALER AND INVESTMENT ADVISER, THROUGH ONE OF ITS REGISTERED REPRESENTATIVES, FAILED TO COMPLY WITH PORTIONS OF REGULATION BEST INTEREST. THE FIRM, ACTING THROUGH ITS REGISTERED REPRESENTATIVE, RECOMMENDED AN INVESTMENT TO FIVE RETAIL CUSTOMERS WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, AND SKILL TO UNDERSTAND THE POTENTIAL RISKS, REWARDS AND COSTS ASSOCIATED WITH THE RECOMMENDATIONS. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER.
Other filed details

Description of allegations — filed text

THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,INSTITUTED AGAINST LIFEMARK SECURITIES CORP. ("LIFEMARK" OR "RESPONDENT"). THE COMMISSION FINDSTHAT BETWEEN JULY 2020 AND JANUARY 2022, THE FIRM AND ONE OF ITS REGISTERED REPRESENTATIVESFAILED TO COMPLY WITH REGULATION BEST INTEREST'S CARE OBLIGATION, EXCHANGE ACT RULE 15L-1(A)(2)(II), WHEN THE REGISTERED REPRESENTATIVE RECOMMENDED A CERTAIN CORPORATE BOND KNOWN AS AN LBOND TO RETAIL CUSTOMERS WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, AND SKILL TOUNDERSTAND THE POTENTIAL RISKS, REWARDS AND COSTS ASSOCIATED WITH THEIR RECOMMENDATIONS(THE "REASONABLE BASIS" PRONG OF THE CARE OBLIGATION). EXCHANGE ACT RULE 15L-1(A)(2)(II)(A). INDECEMBER 2021, THE FIRM, ACTING THROUGH ITS REGISTERED REPRESENTATIVE, ALSO FAILED TO COMPLYWITH REGULATION BEST INTEREST'S CARE OBLIGATION, EXCHANGE ACT RULE 15L-1(A)(2)(II), WHEN THEYRECOMMENDED L BONDS TO A RETAIL CUSTOMER WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, ANDSKILL TO HAVE A REASONABLE BASIS TO BELIEVE THE RECOMMENDATION WAS IN THAT PARTICULARCUSTOMER'S BEST INTEREST (THE "CUSTOMER SPECIFIC" PRONG OF THE CARE OBLIGATION). EXCHANGE ACTRULE 15L-1(A)(2)(II)(B). AS A RESULT OF ITS CONDUCT, THE FIRM FAILED TO COMPLY WITH REGULATION BESTINTEREST'S CARE OBLIGATION, EXCHANGE ACT RULE 15L-1(A)(2)(II), AND WILLFULLY VIOLATED REGULATIONBEST INTEREST'S GENERAL OBLIGATION, EXCHANGE ACT RULE 15L-1(A) (1).

Sanction detail — filed text

THE FIRM WAS CENSURED, SHALL PAY $4,410.18 IN DISGORGEMENT, $705.30 IN PREJUDGMENT INTEREST,A CIVIL MONEY PENALTY OF $85,000 TO THE SEC, AND SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 15L-1(A) (1) OF THE EXCHANGE ACT.
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
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: 
3.
Date Initiated (MM/DD/YYYY): 
07/29/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21984
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 SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE,INSTITUTED AGAINST LIFEMARK SECURITIES CORP. ("LIFEMARK" OR "RESPONDENT"). THE
COMMISSION FINDSTHAT BETWEEN JULY 2020 AND JANUARY 2022, THE FIRM AND ONE OF ITS REGISTERED REPRESENTATIVESFAILED TO COMPLY WITH
REGULATION BEST INTEREST'S CARE OBLIGATION, EXCHANGE ACT RULE 15L-1(A)(2)(II), WHEN THE REGISTERED REPRESENTATIVE RECOMMENDED A
CERTAIN CORPORATE BOND KNOWN AS AN LBOND TO RETAIL CUSTOMERS WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, AND SKILL
TOUNDERSTAND THE POTENTIAL RISKS, REWARDS AND COSTS ASSOCIATED WITH THEIR RECOMMENDATIONS(THE "REASONABLE BASIS" PRONG OF
THE CARE OBLIGATION). EXCHANGE ACT RULE 15L-1(A)(2)(II)(A). INDECEMBER 2021, THE FIRM, ACTING THROUGH ITS REGISTERED REPRESENTATIVE,
ALSO FAILED TO COMPLYWITH REGULATION BEST INTEREST'S CARE OBLIGATION, EXCHANGE ACT RULE 15L-1(A)(2)(II), WHEN THEYRECOMMENDED L
BONDS TO A RETAIL CUSTOMER WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, ANDSKILL TO HAVE A REASONABLE BASIS TO BELIEVE THE
RECOMMENDATION WAS IN THAT PARTICULARCUSTOMER'S BEST INTEREST (THE "CUSTOMER SPECIFIC" PRONG OF THE CARE OBLIGATION). EXCHANGE
ACTRULE 15L-1(A)(2)(II)(B). AS A RESULT OF ITS CONDUCT, THE FIRM FAILED TO COMPLY WITH REGULATION BESTINTEREST'S CARE OBLIGATION,
EXCHANGE ACT RULE 15L-1(A)(2)(II), AND WILLFULLY VIOLATED REGULATIONBEST INTEREST'S GENERAL OBLIGATION, EXCHANGE ACT RULE 15L-1(A)
(1).
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):
07/29/2024
 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: $ 85,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PREJUDGMENT 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, SHALL PAY $4,410.18 IN DISGORGEMENT, $705.30 IN PREJUDGMENT INTEREST,A CIVIL MONEY PENALTY OF $85,000
TO THE SEC, AND SHALL CEASE AND DESIST FROM COMMITTING ORCAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF RULE 15L-1(A)
(1) OF THE EXCHANGE ACT.
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 FIRM SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE SEC ACCEPTED. BETWEEN JULY 2020 AND JANUARY 2022, THE FIRM, A DUALLY
REGISTERED BROKER-DEALER AND INVESTMENT ADVISER, THROUGH ONE OF ITS REGISTERED REPRESENTATIVES, FAILED TO COMPLY WITH PORTIONS
OF REGULATION BEST INTEREST. THE FIRM, ACTING THROUGH ITS REGISTERED REPRESENTATIVE, RECOMMENDED AN INVESTMENT TO FIVE RETAIL
CUSTOMERS WITHOUT EXERCISING REASONABLE DILIGENCE, CARE, AND SKILL TO UNDERSTAND THE POTENTIAL RISKS, REWARDS AND COSTS
ASSOCIATED WITH THE RECOMMENDATIONS. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST
TO IMPOSE THE SANCTIONS AGREED TO IN THE FIRM'S OFFER.
civil judicial · block 1PDF pages 48–50
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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.

Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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:
4086791
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MORETZ, GARRETT, WAYNE
(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.H.
(1)(a), 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.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
2.
Principal Relief Sought:
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other Product Types: 

5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
C.
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:
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided).

* 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.