Tcfg Investment Advisors, LLC

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
164153
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TCFG WEALTH MANAGEMENT,
LLC
(For individuals, Last, First,
Middle)

CRD
Number:
166606
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TCFG INVESTMENT ADVISORS,
LLC
(For individuals, Last, First,
Middle)
CRD
Number:
2145874
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ROBERTS, RICHARD, JAMES
(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:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
THE SEC SEEKS FINDINGS THAT THE DEFENDANTS COMMITTED THESE VIOLATIONS, PERMANENT INJUNCTIONS AGAINST ALL DEFENDANTS,
DISGORGEMENT WITH PREJUDGMENT INTEREST AGAINST ALL DEFENDANTS, AND CIVIL PENALTIES AGAINST ALL DEFENDANTS.
3.
Date Initiated (MM/DD/YYYY): 
09/30/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CASE NO. 8:21-CV-1615
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC HAS ALLEGED THE FOLLOWING: FRAUDULENT MISCONDUCT AND BREACH OF FIDUCIARY DUTY BY RICHARD JAMES ROBERTS AND TCFG
INVESTMENT ADVISOR, LLC ("TCFG"). THE SEC ALSO ALLEGED ROBERTS USED HIS BROKERDEALER FIRM, TCFG WEALTH MANAGEMENT, LLC ("TCFG
WEALTH MANAGEMENT"), TO AID AND ABET THIS MISCONDUCT. THE ALLEGATIONS INCLUDE: BETWEEN IN OR ABOUT JANUARY 2014 AND IN OR ABOUT
APRIL 2020, ROBERTS AND TCFG MADE MATERIALLY FALSE AND MISLEADING STATEMENTS TO TCFG'S ADVISORY CLIENTS ("TCFG CLIENTS"). THE
DEFENDANTS DEFRAUDED THE TCFG CLIENTS BY FALSELY DISCLOSING THAT TCFG WEALTH MANAGEMENT "MAY" RECEIVE PORTIONS OF THE FEES
CHARGED TO TCFG ACCOUNTS BY ITS THIRD PARTY CLEARING AND CUSTODY FIRM ("CLEARING BROKER") WHEN, IN FACT, ROBERTS HAD DIRECTED
CLEARING BROKER TO CHARGE TCFG CLIENTS AN ADDITIONAL FEE MARKUP THAT WAS PAID TO TCFG WEALTH MANAGEMENT. ROBERTS AND TCFG
FURTHER KNEW, OR WERE RECKLESS AND NEGLIGENT FOR NOT KNOWING, THAT THE MARKED UP PORTION OF THE FEE WAS PASSED ON TO TCFG'S

CLIENTS APPROXIMATELY 60 PERCENT OF THE TIME. ROBERTS AND TCFG MADE OTHER MATERIALLY FALSE AND MISLEADING STATEMENTS TO TCFG'S
CLIENTS REGARDING THE FEE MARKUPS AND FAILED TO DISCLOSE ADEQUATELY THE CONFLICTS OF INTEREST THEY CREATED FOR DEFENDANTS.
ROBERTS USED HIS POSITIONS AS THE CHIEF OPERATING OFFICER, PRESIDENT, MANAGING MEMBER AND, AT TIMES, CHIEF COMPLIANCE OFFICER OF
TCFG WEALTH MANAGEMENT TO SUBSTANTIALLY ASSIST AND FURTHER THIS FRAUDULENT CONDUCT AND THE VIOLATIONS OF THE FIDUCIARY DUTIES
HE AND TCFG OWED TO TCFG'S CLIENTS. FURTHERMORE, AS THE CHIEF COMPLIANCE OFFICER OF TCFG, ROBERTS AIDED AND ABETTED TCFG'S
FAILURE TO IMPLEMENT THE WRITTEN POLICIES AND PROCEDURES THAT WERE REASONABLY DESIGNED TO PREVENT THE SORTS OF DISCLOSURE AND
CONFLICT OF INTEREST VIOLATIONS THAT AROSE FROM TCFG WEALTH MANAGEMENT CHARGING AND RECEIVING THESE FEE MARKUPS FROM TCFG
CLIENTS. THE SEC ALLEGES THAT BY ENGAGING IN THIS CONDUCT: (1) DEFENDANTS ROBERTS AND TCFG VIOLATED SECTIONS 206(1) AND 206(2) OF
THE ADVISERS ACT; (2) DEFENDANT TCFG VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; (3) DEFENDANT
ROBERTS, PURSUANT TO SECTION 209(F) OF THE ADVISERS ACT, AIDED AND ABETTED TCFG'S VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT
AND RULE 206(4)-7 THEREUNDER; AND (4) TCFG WEALTH MANAGEMENT, PURSUANT TO SECTION 209(F) OF THE ADVISERS ACT, AIDED AND ABETTED
ROBERTS' AND TCFG'S VIOLATIONS OF SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT.
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):
07/17/2023
 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:
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: 
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY
OR INDIRECTLY, WHILE ACTING AS AN INVESTMENT ADVISER, SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT")
[15 U.S.C. §§ 80B­6(2)] BY USING THE MAILS OR ANY MEANS OR INSTRUMENTALITY OF INTERSTATE COMMERCE TO ENGAGE IN ANY
TRANSACTION, PRACTICE, OR COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT UPON ANY CLIENT OR PROSPECTIVE CLIENT. II.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS PERMANENTLY RESTRAINED AND ENJOINED FROM ANY VIOLATION OF
SECTION 206(4) OF THE ADVISER ACT [15 U.S.C. § 80B­6(4)] AND RULE 206(4)­7 PROMULGATED THEREUNDER [17 C.F.R. § 275.206(4)­7], BY
KNOWINGLY OR RECKLESSLY PROVIDING SUBSTANTIAL ASSISTANCE TO A REGISTERED INVESTMENT ADVISERS' FAILURE TO ADOPT AND
IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATION OF THE ADVISERS ACT AND THE RULES
THEREUNDER. III. IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS JOINTLY AND SEVERALLY LIABLE WITH
DEFENDANTS RICHARD JAMES ROBERTS AND TCFG WEALTH MANAGEMENT, LLC FOR DISGORGEMENT OF $287,752.97, REPRESENTING NET
PROFITS GAINED AS A RESULT OF THE CONDUCT ALLEGED IN THE COMPLAINT, TOGETHER WITH PREJUDGMENT INTEREST THEREON IN THE
AMOUNT OF $18,899.30, AND INDIVIDUALLY ORDERED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $100,000 PURSUANT TO SECTION 209(E) OF
THE ADVISERS ACT [15 U.S.C. § 80B­9(E)]. DEFENDANT SHALL SATISFY THIS OBLIGATION BY PAYING THE DISGORGEMENT OF $306,652.27 AND
THE CIVIL PENALTY OF $100,000 TO THE SECURITIES AND EXCHANGE COMMISSION WITHIN 30 DAYS AFTER ENTRY OF THIS FINAL JUDGMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON SEPTEMBER 30, 2021, THE SECURITIES AND EXCHANGE COMMISSION FILED A COMPLAINT IN THE CENTRAL DISTRICT OF CALIFORNIA, CASE NO.
21-CV-1615 (THE "ACTION"), ALLEGING THAT PRIOR TO MAY 1, 2020, RICHARD JAMES ROBERTS, TCFG INVESTMENT ADVISORS, LLC, AND TCFG WEALTH
MANAGEMENT, LLC (COLLECTIVELY, THE "TCFG DEFENDANTS"), VIOLATED CERTAIN PROVISIONS OF THE FEDERAL SECURITIES LAWS, INCLUDING THE
ANTI-FRAUD PROVISIONS. THE SEC'S PRESS RELEASE SUMMARIZING ITS ALLEGATIONS IS SET FORTH AT
HTTPS://WWW.SEC.GOV/LITIGATION/LITRELEASES/LR-25238. IN SHORT, THE SEC CONTENDED THAT THE TCFG DEFENDANTS, "FROM JUNE 2014
THROUGH APRIL 2020, ? BREACHED THEIR FIDUCIARY DUTY TO ADVISORY CLIENTS [BECAUSE THEY] DISCLOSED THAT TCFG WEALTH "MAY" RECEIVE
PORTIONS OF THE FEES CHARGED TO TCFG ACCOUNTS BY ITS UNAFFILIATED CLEARING AND CUSTODY FIRM WHEN, IN FACT, ROBERTS HAD DIRECTED
THAT FIRM TO CHARGE TCFG CLIENTS SIGNIFICANT MARKUP FEES THAT WERE PAID TO TCFG WEALTH. THE COMPLAINT ALLEGES THAT TCFG AND
ROBERTS LATER DISCLOSED THE EXISTENCE OF MARKUPS, BUT CONTINUED TO MISLEAD TCFG CLIENTS BY CLAIMING THAT IT WAS ONLY IMPOSED "IN
SOME LIMITED INSTANCES." ROBERTS AND TCFG ALLEGEDLY KNEW, OR WERE RECKLESS AND NEGLIGENT FOR NOT KNOWING, THAT THE CLEARING
AND CUSTODY FIRM'S TICKET CHARGES WERE INSTEAD MARKED UP APPROXIMATELY 60 PERCENT OF THE TIME. THE COMPLAINT FURTHER ALLEGES

THAT TCFG - FOR WHICH ROBERTS SERVED AS CHIEF COMPLIANCE OFFICER - FAILED TO IMPLEMENT WRITTEN POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT THE SORTS OF DISCLOSURE AND CONFLICT OF INTEREST VIOLATIONS THAT AROSE FROM THESE PRACTICES.
ACCORDING TO THE COMPLAINT, ROBERTS USED TCFG WEALTH TO AID AND ABET TCFG'S AND ROBERTS'S VIOLATIONS." ID. THE SEC SPECIFIES IN ITS
RELEASE THAT "[T]HE COMPLAINT CHARGES TCFG AND ROBERTS WITH VIOLATING THE ANTIFRAUD PROVISIONS OF SECTIONS 206(1) AND 206(2) OF
THE INVESTMENT ADVISERS ACT OF 1940, AND CHARGES TCFG WEALTH WITH AIDING AND ABETTING THOSE VIOLATIONS. THE COMPLAINT ALSO
CHARGES TCFG WITH VIOLATING ADVISERS ACT SECTION 206(4) AND RULE 206(4)-7 THEREUNDER, AND ROBERTS WITH AIDING AND ABETTING THOSE
VIOLATIONS. THE COMPLAINT SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT WITH PREJUDGMENT INTEREST, AND CIVIL PENALTIES." THE TCFG
DEFENDANTS HAVE RESOLVED THE MATTER WITH THE SEC WITHOUT ADMITTING OR DENYING THE UNDERLYING FACTUAL ALLEGATIONS OUTLINED IN
THE COMPLAINT. AS PART OF THE RESOLUTION, THE TCFG DEFENDANTS AGREED TO BE ENJOINED FROM FURTHER VIOLATIONS OF SECTIONS 206(2) OF
THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") [15 U.S.C. §§ 80B­6(2)], 206(4) OF THE ADVISER ACT [15 U.S.C. § 80B­6(4)] AND RULE
206(4)­7 PROMULGATED THEREUNDER R [17 C.F.R. § 275.206(4)­7], AND SECTION 209(E) OF THE INVESTMENT ADVISERS ACT [15 U.S.C. § 80B­9(E)]
OF THE AND PAY DISGORGEMENT OF $287,752.97, PREJUDGMENT INTEREST OF $18,899.30, AND THAT EACH OF THE TCFG DEFENDANTS WOULD PAY A
CIVIL PENALTY OF $100,000. THE TCFG DEFENDANTS HAVE FULLY PAID THE MONETARY JUDGMENTS TO WHICH THEY STIPULATED. THE SEC HAS NOT
ALLEGED THAT ANY OF THE TCFG DEFENDANTS HAVE VIOLATED ANY LAWS, INCLUDING ANY FEDERAL SECURITIES LAWS, SINCE MAY 1, 2020. THE
SPECIFIC TERMS OF THE PARTIES' CONSENSUAL RESOLUTION ARE SET FORTH IN THE JUDGMENTS ENTERED AGAINST EACH DEFENDANT ENTERED IN
THE PUBLIC RECORD AND IN CONSENTS TO WHICH THE PARTIES AGREED.

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:
166606
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TCFG INVESTMENT ADVISORS,
LLC
(For individuals, Last, First,
Middle)
CRD
Number:
2145874
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ROBERTS, RICHARD, JAMES
(For individuals, Last, First,
Middle)
CRD
Number:
164153
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No

Name:
TCFG WEALTH MANAGEMENT,
LLC
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.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.) 
SEC FILED CIVIL COMPLAINT
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
BAR, DISGORGEMENT WITH PRE-JUDGEMENT INTEREST, AND PERMANENT INJUNCTIONS
3.
Filing Date of Court Action (MM/DD/YYYY):
09/30/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
NO PRODUCT
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): 
FEDERAL COURT DOCKET NUMBER- 21-CV-1615
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): 
THE SEC ALLEGED: BETWEEN IN OR ABOUT JANUARY 2014 AND IN OR ABOUT APRIL 2020, ROBERTS AND TCFG MADE MATERIALLY FALSE AND
MISLEADING STATEMENTS TO TCFG'S ADVISORY CLIENTS ("TCFG CLIENTS"). THE DEFENDANTS DEFRAUDED THE TCFG CLIENTS BY FALSELY DISCLOSING
THAT TCFG WEALTH MANAGEMENT "MAY" RECEIVE PORTIONS OF THE FEES CHARGED TO TCFG ACCOUNTS BY ITS THIRD PARTY CLEARING AND CUSTODY
FIRM ("CLEARING BROKER") WHEN, IN FACT, ROBERTS HAD DIRECTED CLEARING BROKER TO CHARGE TCFG CLIENTS AN ADDITIONAL FEE MARKUP THAT
WAS PAID TO TCFG WEALTH MANAGEMENT. ROBERTS AND TCFG FURTHER KNEW, OR WERE RECKLESS AND NEGLIGENT FOR NOT KNOWING, THAT THE
MARKED UP PORTION OF THE FEE WAS PASSED ON TO TCFG'S CLIENTS APPROXIMATELY 60 PERCENT OF THE TIME. ROBERTS AND TCFG MADE OTHER
MATERIALLY FALSE AND MISLEADING STATEMENTS TO TCFG'S CLIENTS REGARDING THE FEE MARKUPS AND FAILED TO DISCLOSE ADEQUATELY THE
CONFLICTS OF INTEREST THEY CREATED FOR DEFENDANTS. ROBERTS USED HIS POSITIONS AS THE CHIEF OPERATING OFFICER, PRESIDENT,
MANAGING MEMBER AND, AT TIMES, CHIEF COMPLIANCE OFFICER OF TCFG WEALTH MANAGEMENT TO SUBSTANTIALLY ASSIST AND FURTHER THIS
FRAUDULENT CONDUCT AND THE VIOLATIONS OF THE FIDUCIARY DUTIES HE AND TCFG OWED TO TCFG'S CLIENTS. FURTHERMORE, AS THE CHIEF
COMPLIANCE OFFICER OF TCFG, ROBERTS AIDED AND ABETTED TCFG'S FAILURE TO IMPLEMENT THE WRITTEN POLICIES AND PROCEDURES THAT WERE
REASONABLY DESIGNED TO PREVENT THE SORTS OF DISCLOSURE AND CONFLICT OF INTEREST VIOLATIONS THAT AROSE FROM TCFG WEALTH
MANAGEMENT CHARGING AND RECEIVING THESE FEE MARKUPS FROM TCFG CLIENTS. THE SEC ALLEGED: BY ENGAGING IN THIS CONDUCT: (1)
DEFENDANTS ROBERTS AND TCFG VIOLATED SECTIONS 206(1) AND 206(2) OF THE ADVISERS ACT; (2) DEFENDANT TCFG VIOLATED SECTION 206(4) OF
THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; (3) DEFENDANT ROBERTS, PURSUANT TO SECTION 209(F) OF THE ADVISERS ACT, AIDED AND
ABETTED TCFG'S VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; AND (4) TCFG WEALTH MANAGEMENT,
PURSUANT TO SECTION 209(F) OF THE ADVISERS ACT, AIDED AND ABETTED ROBERTS' AND TCFG'S VIOLATIONS OF SECTIONS 206(1) AND 206(2) OF
THE ADVISERS ACT.
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:
Consent
12. Resolution Date (MM/DD/YYYY): 
07/17/2023
 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: $ 100,000.00
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:
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS PERMANENTLY RESTRAINED AND ENJOINED FROM VIOLATING, DIRECTLY
OR INDIRECTLY, WHILE ACTING AS AN INVESTMENT ADVISER, SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT")
[15 U.S.C. §§ 80B­6(2)] BY USING THE MAILS OR ANY MEANS OR INSTRUMENTALITY OF INTERSTATE COMMERCE TO ENGAGE IN ANY
TRANSACTION, PRACTICE, OR COURSE OF BUSINESS WHICH OPERATES AS A FRAUD OR DECEIT UPON ANY CLIENT OR PROSPECTIVE CLIENT. II.
IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS PERMANENTLY RESTRAINED AND ENJOINED FROM ANY VIOLATION OF
SECTION 206(4) OF THE ADVISER ACT [15 U.S.C. § 80B­6(4)] AND RULE 206(4)­7 PROMULGATED THEREUNDER [17 C.F.R. § 275.206(4)­7], BY
KNOWINGLY OR RECKLESSLY PROVIDING SUBSTANTIAL ASSISTANCE TO A REGISTERED INVESTMENT ADVISERS' FAILURE TO ADOPT AND
IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATION OF THE ADVISERS ACT AND THE RULES
THEREUNDER. III. IT IS HEREBY FURTHER ORDERED, ADJUDGED, AND DECREED THAT DEFENDANT IS JOINTLY AND SEVERALLY LIABLE WITH
DEFENDANTS RICHARD JAMES ROBERTS AND TCFG WEALTH MANAGEMENT, LLC FOR DISGORGEMENT OF $287,752.97, REPRESENTING NET
PROFITS GAINED AS A RESULT OF THE CONDUCT ALLEGED IN THE COMPLAINT, TOGETHER WITH PREJUDGMENT INTEREST THEREON IN THE
AMOUNT OF $18,899.30, AND INDIVIDUALLY ORDERED TO PAY A CIVIL PENALTY IN THE AMOUNT OF $100,000 PURSUANT TO SECTION 209(E) OF
THE ADVISERS ACT [15 U.S.C. § 80B­9(E)]. DEFENDANT SHALL SATISFY THIS OBLIGATION BY PAYING THE DISGORGEMENT OF $306,652.27 AND
THE CIVIL PENALTY OF $100,000 TO THE SECURITIES AND EXCHANGE COMMISSION WITHIN 30 DAYS AFTER ENTRY OF THIS FINAL JUDGMENT.
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). 
ON SEPTEMBER 30, 2021, THE SECURITIES AND EXCHANGE COMMISSION FILED A COMPLAINT IN THE CENTRAL DISTRICT OF CALIFORNIA, CASE NO.
21-CV-1615 (THE "ACTION"), ALLEGING THAT PRIOR TO MAY 1, 2020, RICHARD JAMES ROBERTS, TCFG INVESTMENT ADVISORS, LLC, AND TCFG WEALTH
MANAGEMENT, LLC (COLLECTIVELY, THE "TCFG DEFENDANTS"), VIOLATED CERTAIN PROVISIONS OF THE FEDERAL SECURITIES LAWS, INCLUDING THE
ANTI-FRAUD PROVISIONS. THE SEC'S PRESS RELEASE SUMMARIZING ITS ALLEGATIONS IS SET FORTH AT
HTTPS://WWW.SEC.GOV/LITIGATION/LITRELEASES/LR-25238. IN SHORT, THE SEC CONTENDED THAT THE TCFG DEFENDANTS, "FROM JUNE 2014
THROUGH APRIL 2020, ? BREACHED THEIR FIDUCIARY DUTY TO ADVISORY CLIENTS [BECAUSE THEY] DISCLOSED THAT TCFG WEALTH "MAY" RECEIVE
PORTIONS OF THE FEES CHARGED TO TCFG ACCOUNTS BY ITS UNAFFILIATED CLEARING AND CUSTODY FIRM WHEN, IN FACT, ROBERTS HAD DIRECTED
THAT FIRM TO CHARGE TCFG CLIENTS SIGNIFICANT MARKUP FEES THAT WERE PAID TO TCFG WEALTH. THE COMPLAINT ALLEGES THAT TCFG AND
ROBERTS LATER DISCLOSED THE EXISTENCE OF MARKUPS, BUT CONTINUED TO MISLEAD TCFG CLIENTS BY CLAIMING THAT IT WAS ONLY IMPOSED "IN
SOME LIMITED INSTANCES." ROBERTS AND TCFG ALLEGEDLY KNEW, OR WERE RECKLESS AND NEGLIGENT FOR NOT KNOWING, THAT THE CLEARING
AND CUSTODY FIRM'S TICKET CHARGES WERE INSTEAD MARKED UP APPROXIMATELY 60 PERCENT OF THE TIME. THE COMPLAINT FURTHER ALLEGES
THAT TCFG - FOR WHICH ROBERTS SERVED AS CHIEF COMPLIANCE OFFICER - FAILED TO IMPLEMENT WRITTEN POLICIES AND PROCEDURES
REASONABLY DESIGNED TO PREVENT THE SORTS OF DISCLOSURE AND CONFLICT OF INTEREST VIOLATIONS THAT AROSE FROM THESE PRACTICES.
ACCORDING TO THE COMPLAINT, ROBERTS USED TCFG WEALTH TO AID AND ABET TCFG'S AND ROBERTS'S VIOLATIONS." ID. THE SEC SPECIFIES IN ITS
RELEASE THAT "[T]HE COMPLAINT CHARGES TCFG AND ROBERTS WITH VIOLATING THE ANTIFRAUD PROVISIONS OF SECTIONS 206(1) AND 206(2) OF
THE INVESTMENT ADVISERS ACT OF 1940, AND CHARGES TCFG WEALTH WITH AIDING AND ABETTING THOSE VIOLATIONS. THE COMPLAINT ALSO
CHARGES TCFG WITH VIOLATING ADVISERS ACT SECTION 206(4) AND RULE 206(4)-7 THEREUNDER, AND ROBERTS WITH AIDING AND ABETTING THOSE
VIOLATIONS. THE COMPLAINT SEEKS PERMANENT INJUNCTIONS, DISGORGEMENT WITH PREJUDGMENT INTEREST, AND CIVIL PENALTIES." THE TCFG
DEFENDANTS HAVE RESOLVED THE MATTER WITH THE SEC WITHOUT ADMITTING OR DENYING THE UNDERLYING FACTUAL ALLEGATIONS OUTLINED IN
THE COMPLAINT. AS PART OF THE RESOLUTION, THE TCFG DEFENDANTS AGREED TO BE ENJOINED FROM FURTHER VIOLATIONS OF SECTIONS 206(2) OF
THE INVESTMENT ADVISERS ACT OF 1940 ("ADVISERS ACT") [15 U.S.C. §§ 80B­6(2)], 206(4) OF THE ADVISER ACT [15 U.S.C. § 80B­6(4)] AND RULE
206(4)­7 PROMULGATED THEREUNDER R [17 C.F.R. § 275.206(4)­7], AND SECTION 209(E) OF THE INVESTMENT ADVISERS ACT [15 U.S.C. § 80B­9(E)]
OF THE AND PAY DISGORGEMENT OF $287,752.97, PREJUDGMENT INTEREST OF $18,899.30, AND THAT EACH OF THE TCFG DEFENDANTS WOULD PAY A

CIVIL PENALTY OF $100,000. THE TCFG DEFENDANTS HAVE FULLY PAID THE MONETARY JUDGMENTS TO WHICH THEY STIPULATED. THE SEC HAS NOT
ALLEGED THAT ANY OF THE TCFG DEFENDANTS HAVE VIOLATED ANY LAWS, INCLUDING ANY FEDERAL SECURITIES LAWS, SINCE MAY 1, 2020. THE
SPECIFIC TERMS OF THE PARTIES' CONSENSUAL RESOLUTION ARE SET FORTH IN THE JUDGMENTS ENTERED AGAINST EACH DEFENDANT ENTERED IN
THE PUBLIC RECORD AND IN CONSENTS TO WHICH THE PARTIES AGREED.