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 Isc Advisors, Inc..
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 Isc Advisors, Inc...
Reported ownership and control details
Form ADV · Filing date 2026-07-09 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ISC GROUP, INC.OWNERDomestic entity | ISC ADVISORS, INC. | 75% or moreCode E | Yes | OWNER12/2012 | Schedule APDF page 34 |
| 2 | SCOTT ALLEN HAYESPRESIDENT & CEOIndividual | ISC ADVISORS, INC. | 50% to less than 75%Code D | Yes | PRESIDENT & CEO12/2012 | Schedule APDF page 34 |
| 3 | DONALD WILLIAM STERLINGFINANCIAL OPERATIONS PRINCIPALIndividual | ISC ADVISORS, INC. | Less than 5%Code NA | Yes | FINANCIAL OPERATIONS PRINCIPAL12/2012 | Schedule APDF page 34 |
| 4 | SHARON ELAINE BERRYCOMPLIANCE OFFICERIndividual | ISC ADVISORS, INC. | Less than 5%Code NA | No | COMPLIANCE OFFICER12/2021 | Schedule APDF page 34 |
| 5 | ANDREYA STARLITE WEADONCOMPLIANCE OFFICERIndividual | ISC ADVISORS, INC. | Less than 5%Code NA | No | COMPLIANCE OFFICER03/2013 | Schedule APDF page 34 |
| 6 | MARCUS COLE MCCAINCHIEF COMPLIANCE OFFICERIndividual | ISC ADVISORS, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER07/2026 | Schedule APDF page 34 |
| 7 | SCOTT ALLEN HAYESMEMBERIndividual | ISC INVESTMENT MANAGEMENT, LLC | 50% to less than 75%Code D | Yes | MEMBER12/2012 | Schedule BPDF page 34 |
| 8 | ISC INVESTMENT MANAGEMENT, LLCOWNERDomestic entity | ISC GROUP, INC. | 75% or moreCode E | Yes | OWNER12/2012 | Schedule BPDF page 35 |
| 9 | DERRILL CHAD BRANTLEYMEMBERIndividual | ISC INVESTMENT MANAGEMENT, LLC | 25% to less than 50%Code C | No | MEMBER12/2012 | Schedule BPDF page 35 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 7/9/2026 9:07:19 AM
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 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 actions5 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?No
- 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?No
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?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 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 1DAHSE, ROBERT, LANEPDF pages 35–37
- Advisory affiliate name — filed text
- DAHSE, ROBERT, LANE
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: 4511017 This advisory affiliate is a Firm an Individual Registered: Yes No Name: DAHSE, ROBERT, LANE (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 2PDF pages 37–38
- Regulator name — filed text
- THE SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 180,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.
Other filed details
Description of allegations — filed text
THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES.
Sanction detail — filed text
ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER.
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 SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: CENSURED. ORDERED TO PAY DISGORGEMENT AND PREJUDGEMENT INTEREST. 3. Date Initiated (MM/DD/YYYY): 12/04/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: FILE NO. 3-20461 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Mutual Fund(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES. 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): 08/13/2021 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: $ 180,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. 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 SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.
regulatory · block 3PDF pages 38–40
- Regulator name — filed text
- THE SECURITIES AND EXCHNAGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 180,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.
Other filed details
Description of allegations — filed text
THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES.
Sanction detail — filed text
ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER.
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 SECURITIES AND EXCHNAGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: CENSURED. ORDERED TO PAY DISGORGEMENT AND PREJUDGMENT INTEREST. 3. Date Initiated (MM/DD/YYYY): 12/04/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: FILE NO. 3-20461 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Mutual Fund(s) Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE FIRM ALLEGEDLY BREACHED OUR DUTY TO SEEK BEST EXECUTION, BY CAUSING CERTAIN ADVISORY CLIENTS TO INVEST IN FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN SHARE CLASSES OF THE SAME FUNDS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS WERE AVAILABLE. WE ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER IN CONNECTION WITH OUR MUTUAL FUND SHARE CLASS SELECTION PRACTICES. WE ALSO ALLEGEDLY BREACHED OUR FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH THE RECEIPT OF REVENUE SHARING FROM ITS CLEARING BROKER FOR OUR CLIENTS' FUNDS IN UNINVESTED CASH, WHICH INCLUDED INVESTMENTS IN MONEY MARKET MUTUAL FUNDS AND A BANK INSURED DEPOSIT PROGRAM ALONG WITH FREE CASH BALANCES. 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): 08/13/2021 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: $ 180,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: ADVISER PAID DISGORGEMENT OF $438,018.45 AND PREJUDGEMENT INTEREST OF $98,326.84 AND SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 PROMULGATED THEREUNDER. 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 SEC ALLEGED THAT WE FAILED TO ADEQUATELY DISCLOSE THE CONFLICT OF INTEREST ARISING FROM OUR SELECTION OF MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES. THESE FEES BENEFITTED US FINANCIALLY. THE ORDER ALSO ALLEGED THAT WE FAILED TO MAINTAIN POLICIES AND PROCEDURES ADEQUATE TO PREVENT THE VIOLATIONS. THE ORDER ALLEGED THAT WE VIOLATED THE ANTIFRAUD PROVISIONS OF THE INVESTMENT ADVISERS ACT OF 1940. WITHOUT ADMITTING OR ADMITTING THE ALLEGATIONS OR FINDING, WE CONSENTED TO THE ORDER.
* 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.