Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Anda Asset Management Co.., Ltd..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Anda Asset Management Co.., Ltd...
Reported ownership and control details
Form ADV · Filing date 2026-06-25 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ANDA INVESTMENT PARTNERS CO., LTD.SHAREHOLDERForeign entity | ANDA ASSET MANAGEMENT CO., LTD. | 25% to less than 50%Code C | Yes | SHAREHOLDER07/2012 | Schedule APDF page 175 |
| 2 | KWON UK (NMN) CHOISHAREHOLDERIndividual | ANDA ASSET MANAGEMENT CO., LTD. | 50% to less than 75%Code D | Yes | SHAREHOLDER11/2011 | Schedule APDF page 175 |
| 3 | DANIEL WARREN PEREZREPRESENTATIVE DIRECTOR / CMOIndividual | ANDA ASSET MANAGEMENT CO., LTD. | Less than 5%Code NA | Yes | REPRESENTATIVE DIRECTOR / CMO04/2019 | Schedule APDF page 175 |
| 4 | GEUN CHANG CHOIREPRESENTATIVE DIRECTOR / COOIndividual | ANDA ASSET MANAGEMENT CO., LTD. | Less than 5%Code NA | Yes | REPRESENTATIVE DIRECTOR / COO03/2022 | Schedule APDF page 175 |
| 5 | DAE IL KIMCHIEF COMPLIANCE OFFICERIndividual | ANDA ASSET MANAGEMENT CO., LTD. | Less than 5%Code NA | No | CHIEF COMPLIANCE OFFICER03/2025 | Schedule APDF page 175 |
| 6 | DAE JOONG KIMREPRESENTATIVE DIRECTOR / CIOIndividual | ANDA ASSET MANAGEMENT CO., LTD. | Less than 5%Code NA | Yes | REPRESENTATIVE DIRECTOR / CIO02/2026 | Schedule APDF page 176 |
| 7 | KWON UK (NMN) CHOISHAREHOLDERIndividual | ANDA INVESTMENT PARTNERS CO., LTD. | 75% or moreCode E | Yes | SHAREHOLDER07/2007 | Schedule BPDF page 176 |
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 6/25/2026 8:54:43 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions1 Yes4 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?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?No
- 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 actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?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?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 3 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 1PDF pages 176–178
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)
THE FINANCIAL SUPERVISORY SERVICE ("FSS") AND THE FINANCIAL SERVICES COMMISSION ("FSC") IN KOREA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
WARNING ISSUED TO THE COMPANY AND ANDA'S OFFICERS AND EMPLOYEES WHO WERE IN CHARGE OF THE VALUATION
3.
Date Initiated (MM/DD/YYYY):
01/31/2020
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
CONVERTIBLE BOND
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE KOREAN FINANCIAL SUPERVISORY SERVICE ("FSS"), DURING THE COURSE OF A ROUTINE EXAM IN JUNE 2019, IDENTIFIED THREE SEPARATE
TECHNICAL RULE VIOLATION MATTERS FOR ANDA ASSET MANAGEMENT CO., LTD. ("ANDA"). SUBSEQUENTLY, ANDA HAS BEEN ASSESSED PENALTIES BY
THE FSS RELATING TO THESE TECHNICAL RULE VIOLATIONS AS OUTLINED IN MORE DETAIL BELOW. (1) ANDA WAS FINED FOR THE ESTABLISHMENT OF
AN ENTITY, ANDA GLOBAL, IN MARCH 2015, AND THE EXERCISING OF VOTING RIGHTS FOR THIS ENTITY, WITHOUT OBTAINING PRIOR APPROVAL FROM
THE FSC DUE TO AN INADVERTENT ADMINISTRATIVE OVERSIGHT. ANDA GLOBAL WAS AN ONSHORE COMPANY WHOLLY-OWNED BY ANDA AND WAS
ESTABLISHED EXCLUSIVELY FOR THE PURPOSE OF HOLDING ANDA'S PROPRIETARY STAKE IN REAL ESTATE IN THE UNITED STATES. ANDA GLOBAL WAS
LIQUIDATED IN JANUARY 2020. SINCE ANDA GLOBAL WAS ESTABLISHED IN VIOLATION OF THE ACT ON THE STRUCTURAL IMPROVEMENT OF THE
FINANCIAL INDUSTRY ("ASIFI"), THE FSS IMPOSED AN ADMINISTRATIVE FINE ON ANDA IN THE AMOUNT OF KRW 16 MILLION (USD 13,000), TAKING
INTO ACCOUNT THE PROMPT AND IMMEDIATE REMEDY ACTIONS TAKEN BY ANDA ONCE ANDA REALIZED THE INADVERTENT MISTAKE. (2) ANDA
PROVIDED LOANS TO ITS OFFICERS AND EMPLOYEES TO PURCHASE SHARES IN ANDA, AS PART OF AN EMPLOYEE OWNERSHIP PROGRAM, HOWEVER
THE LOANS WERE IN EXCESS OF THE LEGAL LIMIT OF KRW 100 MILLION (USD 82,000), VIOLATING THE FINANCIAL INVESTMENT SERVICES AND
CAPITAL MARKETS ACT ("FSCMA"). THE FSS IMPOSED A MONETARY FINE IN THE AMOUNT OF KRW 56 MILLION (USD 47,000) AND ISSUED WARNINGS TO
ANDA AND ANDA'S FORMER REPRESENTATIVE DIRECTOR. THE IMPOSED FINE IS THE MINIMUM MONETARY PENALTY THAT THE FSS COULD APPLY UNDER
THE FSCMA GUIDELINES. (3) IN MAY 2019, ANDA DID NOT VALUE A CONVERTIBLE BOND HELD IN THREE PORTFOLIOS IT MANAGED IN A MANNER
CONSISTENT WITH THE FSCMA. THE VALUATION ERROR OCCURRED AS A RESULT OF ANDA WAITING UNTIL THE COURT ACCEPTED THE CONVERTIBLE
BOND ISSUER'S BANKRUPTCY FILING. UNDER THE FSCMA, ANDA SHOULD HAVE WROTE OFF THE DEBT AT THE TIME THE ISSUER FILED FOR
BANKRUPTCY, ONE WEEK EARLIER. ANDA REIMBURSED ALL INVESTORS WHO SUFFERED A FINANCIAL LOSS AS A RESULT OF THE ERROR, WHILE ANY
INVESTORS THAT BENEFITED FROM THE ERROR WERE PERMITTED TO KEEP THEIR GAINS. THE FSS ISSUED WARNINGS UPON ANDA'S OFFICERS AND
EMPLOYEES WHO WERE IN CHARGE OF THE VALUATION. THERE WAS NO MONETARY FINE ASSOCIATED WITH THIS BREACH.
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):
04/01/2020
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: $ 60,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
1. A WARNING TO ANDA AND ANDA'S FORMER REPRESENTATIVE DIRECTOR 2. A WARNINGS UPON ANDA'S OFFICER AND EMPLOYEE WHO WERE IN
CHARGE OF THE VALUATION
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 FSS IMPOSED A MONETARY FINE IN THE TOTAL AMOUNT OF KRW 72 MILLION (USD 60,000). ANDA PAID KRW 12.8 MILLION ON MARCH 11
AND KRW 56 MILLION ON MAY 29. THE REMAINING KRW 3.2 MILLION WAS WAIVED BY THE FSS AS A RESULT OF EARLY PAYMENT OF THE FINE BY
ANDA.
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).
UNDER KOREAN REGULATIONS, THE FSS PROPOSED PENALTIES ARE FINALIZED AFTER A FINAL REVIEW IS CONDUCTED BY THE FSC. THE FSC RENDERED
ITS FINAL DECISION ON APRIL 1, 2020. AFTER THE FSC RENDERED ITS DECISION, THE FSS ISSUED ANDA AND OFFICIAL NOTIFICATION OF THE
RESULTS OF THEIR EXAMINATION ON APRIL 7,2020.regulatory · block 2PDF pages 178–180
- Regulator name — filed text
- THE KOREA FINANCIAL INVESTMENT ASSOCIATION
- Monetary/Fine Amount — filed text
- $ 4,400.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
UNDER KOFIA REGULATION, SELF-REGULATORY COMMITTEE DECIDES THE AMOUNT OF FINE IMPOSED TO A FINANCIAL INVESTMENT FIRMS IN ACCORDANCE WITH FORMULA SET BY THE REGULATION. KOFIA RENDERED ITS FINAL DECISION ON JUNE 18, 2021.
Other filed details
Description of allegations — filed text
ON FEBRUARY 9, 2021, ANDA ASSET MANAGEMENT CO. LTD. ("ANDA") APPLIED FOR BOOK-BUILDING FOR XIILAB (189330 KS EQUITY) THROUGH THE UNDERWRITER, IBK SECURITIES CO., LTD. THE PORTFOLIO MANAGERS OF ANDA KOSDAQ VENTURE FUNDS ("THE FUNDS") DECIDED NOT TO COMMIT TO A LOCK-UP PERIOD, HOWEVER, DUE TO AN ADMINISTRATIVE ERROR ON THE BOOK BUILDING APPLICATION FORM THE FUNDS COMMITTED TO A 1 MONTH LOCK-UP PERIOD FROM FEBRUARY 24, 2021 TO MARCH 23, 2021 AND THE FUNDS WERE ALLOCATED AN AGGREGATE OF 503 XIILAB SHARES. XIILAB SHARES WERE LISTED ON THE KOSDAQ MARKET ON FEBRUARY 24, 2021 AND ON THE SAME DAY THE FUNDS SOLD ALL THE ALLOCATED XIILAB SHARES, BREACHING THE LOCK-UP PERIOD AND IN VIOLATION OF SECTION 17.2 OF THE KOREA FINANCIAL INVESTMENT ASSOCIATION ("KOFIA")'S REGULATIONS ON SECURITIES UNDERWRITING BUSINESS. ON MARCH 18, 2021, THE UNDERWRITER NOTIFIED ANDA THE FUNDS BREACHED THE LOCK- UP PERIOD. AFTER CONSULTING WITH ANDA'S CHIEF COMPLIANCE OFFICER AND OUTSIDE COUNSEL, ON MARCH 19, 2021, ANDA RE-PURCHASED THE SAME NUMBER OF SHARES SOLD BY EACH FUND. THE REPURCHASE PRICE WAS LOWER THAN THE FEBRUARY 24 SALE PRICE. THE BREACH WAS REPORTED ON MARCH 26, 2021 TO KOFIA. KOFIA HELD A SELF-REGULATORY COMMITTEE MEETING ON JUNE 17, 2021 AND ON JUNE 18, 2021 IMPOSED ON ANDA A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400), TAKING INTO ACCOUNT THE PROMPT AND IMMEDIATE REMEDY ACTIONS TAKEN BY ANDA ONCE ANDA REALIZED THE INADVERTENT MISTAKE. ANDA PAID KRW 5 MILLION (USD 4,400) ON JUNE 23, 2021. THE AMOUNT OF THE FINE IS ONE OF THE LOWER AMOUNTS OF THE MONETARY PENALTIES KOFIA COULD APPLY UNDER ITS REGULATIONS. THE FUNDS AND, ULTIMATELY, ITS UNDERLYING INVESTORS, INCURRED NO FINANCIAL LOSS FROM THE ADMINISTRATIVE ERROR AND KOFIA DID NOT CLAW BACK THE GAINS THE FUNDS EARNED FROM THE ERROR.
Sanction detail — filed text
ON JUNE 18, 2021 ANDA WAS IMPOSED OF A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400). ANDA PAID KRW 5 MILLION (USD 4,400) ON JUNE 23, 2021.
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)
THE KOREA FINANCIAL INVESTMENT ASSOCIATION
2.
Principal Sanction:
Other
Other Sanctions:
ANDA WAS IMPOSED OF A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400).
3.
Date Initiated (MM/DD/YYYY):
03/18/2021
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON FEBRUARY 9, 2021, ANDA ASSET MANAGEMENT CO. LTD. ("ANDA") APPLIED FOR BOOK-BUILDING FOR XIILAB (189330 KS EQUITY) THROUGH THE
UNDERWRITER, IBK SECURITIES CO., LTD. THE PORTFOLIO MANAGERS OF ANDA KOSDAQ VENTURE FUNDS ("THE FUNDS") DECIDED NOT TO COMMIT TO
A LOCK-UP PERIOD, HOWEVER, DUE TO AN ADMINISTRATIVE ERROR ON THE BOOK BUILDING APPLICATION FORM THE FUNDS COMMITTED TO A 1
MONTH LOCK-UP PERIOD FROM FEBRUARY 24, 2021 TO MARCH 23, 2021 AND THE FUNDS WERE ALLOCATED AN AGGREGATE OF 503 XIILAB SHARES.
XIILAB SHARES WERE LISTED ON THE KOSDAQ MARKET ON FEBRUARY 24, 2021 AND ON THE SAME DAY THE FUNDS SOLD ALL THE ALLOCATED XIILAB
SHARES, BREACHING THE LOCK-UP PERIOD AND IN VIOLATION OF SECTION 17.2 OF THE KOREA FINANCIAL INVESTMENT ASSOCIATION ("KOFIA")'S
REGULATIONS ON SECURITIES UNDERWRITING BUSINESS. ON MARCH 18, 2021, THE UNDERWRITER NOTIFIED ANDA THE FUNDS BREACHED THE LOCK-
UP PERIOD. AFTER CONSULTING WITH ANDA'S CHIEF COMPLIANCE OFFICER AND OUTSIDE COUNSEL, ON MARCH 19, 2021, ANDA RE-PURCHASED THE
SAME NUMBER OF SHARES SOLD BY EACH FUND. THE REPURCHASE PRICE WAS LOWER THAN THE FEBRUARY 24 SALE PRICE. THE BREACH WAS
REPORTED ON MARCH 26, 2021 TO KOFIA. KOFIA HELD A SELF-REGULATORY COMMITTEE MEETING ON JUNE 17, 2021 AND ON JUNE 18, 2021 IMPOSED
ON ANDA A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400), TAKING INTO ACCOUNT THE PROMPT AND IMMEDIATE REMEDY ACTIONS
TAKEN BY ANDA ONCE ANDA REALIZED THE INADVERTENT MISTAKE. ANDA PAID KRW 5 MILLION (USD 4,400) ON JUNE 23, 2021. THE AMOUNT OF THE
FINE IS ONE OF THE LOWER AMOUNTS OF THE MONETARY PENALTIES KOFIA COULD APPLY UNDER ITS REGULATIONS. THE FUNDS AND, ULTIMATELY,
ITS UNDERLYING INVESTORS, INCURRED NO FINANCIAL LOSS FROM THE ADMINISTRATIVE ERROR AND KOFIA DID NOT CLAW BACK THE GAINS THE
FUNDS EARNED FROM THE ERROR.
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):
06/18/2021
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: $ 4,400.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
N/A
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:
ON JUNE 18, 2021 ANDA WAS IMPOSED OF A MONETARY FINE IN THE AMOUNT OF KRW 5 MILLION (USD 4,400). ANDA PAID KRW 5 MILLION (USD
4,400) ON JUNE 23, 2021.
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).
UNDER KOFIA REGULATION, SELF-REGULATORY COMMITTEE DECIDES THE AMOUNT OF FINE IMPOSED TO A FINANCIAL INVESTMENT FIRMS IN
ACCORDANCE WITH FORMULA SET BY THE REGULATION. KOFIA RENDERED ITS FINAL DECISION ON JUNE 18, 2021.regulatory · block 3PDF pages 180–182
- Regulator name — filed text
- THE FINANCIAL SERVICES COMMISSION ("FSC") AND THE SECURITIES AND FUTURES COMMISSION ("SFC") IN KOREA
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE SECURITIES AND FUTURES COMMISSION HELD A HEARING ON JULY 3, 2024, AT WHICH THE COMMISSION IMPOSED AN ADMINISTRATIVE FINE ON ANDA. ANDA PAID THE FINE ON JULY 8, 2024.
Other filed details
Description of allegations — filed text
ANDA RECEIVED AN INSPECTION LETTER FROM THE FINANCIAL SUPERVISORY SERVICE ON DECEMBER 20, 2023. THE INQUIRY CENTERED ON ANDA'S REPORTING OBLIGATIONS TO THE FSC AND THE EXCHANGE UNDER ARTICLE 180-2 (REPORT OF SHORT-SELLING BALANCE) OF THE FINANCIAL INVESTMENT SERVICES AND CAPITAL MARKETS ACT. ANDA REPORTS OUR SHORT BALANCE TO BOTH THE FSC AND THE EXCHANGE EVERY TWO DAYS SINCE 2015. OVER THE PAST TEN YEARS, OCCASIONALLY ANDA FAILED TO FILE THE REPORTS ON A TIMELY BASIS DUE TO ADMINISTRATIVE ERRORS. AFTER FSS REIMPLEMENTED THE SHORT SALE BAN ON NOVEMBER 8, 2023, IT COMMENCED AN INDUSTRY-WIDE INVESTIGATION INTO ADHERENCE TO SHORT SELLING DISCLOSURE REQUIREMENTS BY BROKERS AND HEDGE FUNDS. THE SECURITIES AND FUTURES COMMISSION HELD A HEARING ON JULY 3, 2024, AT WHICH THE COMMISSION IMPOSED AN ADMINISTRATIVE FINE ON ANDA IN THE AMOUNT OF KRW 138 MILLION (USD 100,000) FOR ANDA'S FAILURE TO TIMELY FILE SHORT BALANCE REPORTS ON A HANDFUL OF OCCASIONS. ANDA PAID THE FINE ON JULY 8, 2024. ANDA'S RELEVANT FUNDS AND ITS UNDERLYING INVESTORS INCURRED NO FINANCIAL LOSS FROM THE FINE. FOLLOWING AN INTERNAL REVIEW, ANDA NOW REPORTS TO THE FSC AND THE EXCHANGE DAILY TO ENSURE COMPLIANCE.
Sanction detail — filed text
ANDA WAS IMPOSED OF AN ADMINISTRATIVE FINE IN THE AMOUNT OF KRW 138 MILLION (USD 100,000). ANDA PAID THE FINE ON JULY 8, 2024.
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)
THE FINANCIAL SERVICES COMMISSION ("FSC") AND THE SECURITIES AND FUTURES COMMISSION ("SFC") IN KOREA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
ANDA WAS IMPOSED OF AN ADMINISTRATIVE FINE IN THE AMOUNT OF KRW 138 MILLION (USD 100,000)
3.
Date Initiated (MM/DD/YYYY):
07/03/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
N/A
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ANDA RECEIVED AN INSPECTION LETTER FROM THE FINANCIAL SUPERVISORY SERVICE ON DECEMBER 20, 2023. THE INQUIRY CENTERED ON ANDA'S
REPORTING OBLIGATIONS TO THE FSC AND THE EXCHANGE UNDER ARTICLE 180-2 (REPORT OF SHORT-SELLING BALANCE) OF THE FINANCIAL
INVESTMENT SERVICES AND CAPITAL MARKETS ACT. ANDA REPORTS OUR SHORT BALANCE TO BOTH THE FSC AND THE EXCHANGE EVERY TWO DAYS
SINCE 2015. OVER THE PAST TEN YEARS, OCCASIONALLY ANDA FAILED TO FILE THE REPORTS ON A TIMELY BASIS DUE TO ADMINISTRATIVE ERRORS.
AFTER FSS REIMPLEMENTED THE SHORT SALE BAN ON NOVEMBER 8, 2023, IT COMMENCED AN INDUSTRY-WIDE INVESTIGATION INTO ADHERENCE TO
SHORT SELLING DISCLOSURE REQUIREMENTS BY BROKERS AND HEDGE FUNDS. THE SECURITIES AND FUTURES COMMISSION HELD A HEARING ON JULY
3, 2024, AT WHICH THE COMMISSION IMPOSED AN ADMINISTRATIVE FINE ON ANDA IN THE AMOUNT OF KRW 138 MILLION (USD 100,000) FOR ANDA'S
FAILURE TO TIMELY FILE SHORT BALANCE REPORTS ON A HANDFUL OF OCCASIONS. ANDA PAID THE FINE ON JULY 8, 2024. ANDA'S RELEVANT FUNDS
AND ITS UNDERLYING INVESTORS INCURRED NO FINANCIAL LOSS FROM THE FINE. FOLLOWING AN INTERNAL REVIEW, ANDA NOW REPORTS TO THE
FSC AND THE EXCHANGE DAILY TO ENSURE COMPLIANCE.
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):
07/08/2024
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: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
N/A
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:
ANDA WAS IMPOSED OF AN ADMINISTRATIVE FINE IN THE AMOUNT OF KRW 138 MILLION (USD 100,000). ANDA PAID THE FINE ON JULY 8, 2024.
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 SECURITIES AND FUTURES COMMISSION HELD A HEARING ON JULY 3, 2024, AT WHICH THE COMMISSION IMPOSED AN ADMINISTRATIVE FINE ON
ANDA. ANDA PAID THE FINE ON JULY 8, 2024.* 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.