Vcp Financial 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:
4799909
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SHABAT, TAMIR
(For individuals, Last, First,
Middle)
CRD
Number:
2882204
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ORLANDO, JOSEPH, JOHN
(For individuals, Last, First,
Middle)
CRD
Number:
308509
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
VESSEL CAPITAL ADVISORS,
LLC
(For individuals, Last, First,

Middle)
CRD
Number:
4191462
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SPIEGEL, DANIEL
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/14/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-22409
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INVESTMENTS IN PRIVATE FUNDS
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 PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE
AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS
ACT OF 1940 ("ADVISERS ACT") AGAINST VCP FINANCIAL LLC ("RESPONDENT"). IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS,
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. SOLELY FOR THE
PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TO WHICH THE COMMISSION
IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'S JURISDICTION OVER IT AND THE
SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTS TO THE ENTRY OF THIS ORDER INSTITUTING
ADMINISTRATIVE AND CEASE-ANDDESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940,
MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER ("ORDER"), AS SET FORTH BELOW. ON THE BASIS OF THIS
ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS 1 THAT: BETWEEN AT LEAST MARCH 2021 AND OCTOBER 2024 (THE "RELEVANT PERIOD"),
VCP FINANCIAL, A REGISTERED INVESTMENT ADVISER, FAILED TO MANAGE A CONFLICT OF INTEREST IN A MANNER CONSISTENT WITH ITS
REPRESENTATIONS IN ITS FIRM BROCHURES. IN PARTICULAR, VCP FINANCIAL DISCLOSED THAT IT HAD A FINANCIAL CONFLICT OF INTEREST WHEN
RECOMMENDING INVESTMENTS OFFERED BY PRIVATE FUNDS MANAGED BY AN AFFILIATED ENTITY UNDER COMMON OWNERSHIP AND CONTROL WITH
VCP FINANCIAL (THE "AFFILIATED MANAGER"). VCP FINANCIAL DISCLOSED THAT IT WOULD MANAGE THE CONFLICT OF INTEREST BY, AMONG OTHER
THINGS, REASONABLY ENSURING ALL CLIENTS' ACCOUNTS WERE INVESTED IN ACCORDANCE WITH CLIENT APPROVED INVESTMENT POLICY

STATEMENTS AND ADOPTING POLICIES AND PROCEDURES TO REASONABLY ENSURE THAT INVESTMENTS AND RECOMMENDATIONS WERE IN THE BEST
INTEREST OF CLIENTS. RATHER THAN FOLLOW THESE DESCRIBED PROCEDURES, HOWEVER, VCP FINANCIAL REQUIRED ITS CLIENTS WHO INVESTED IN
THE FUNDS MANAGED BY THE AFFILIATED MANAGER TO ACKNOWLEDGE THAT VCP FINANCIAL WAS DISCLAIMING ITS ROLE IN THEIR INVESTMENT
DECISION AND THAT VCP FINANCIAL WAS NOT ACTING AS THEIR INVESTMENT ADVISER IN CONNECTION WITH THEIR INVESTMENT IN THOSE FUNDS.
THESE STATEMENTS CONTRADICTED VCP FINANCIAL'S FIRM BROCHURE AND FURTHER COULD LEAD A CLIENT TO BELIEVE INCORRECTLY THAT THE
CLIENT HAD WAIVED A NONWAIVABLE CAUSE OF ACTION AGAINST VCP FINANCIAL THAT WAS PROVIDED BY STATE OR FEDERAL LAW. AS A RESULT,
VCP FINANCIAL VIOLATED SECTION 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):
01/14/2025
 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: 
THE FIRM IS ORDERED TO CEASE AND DESIST; IS CENSURED; AND SHALL, WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY
PENALTY IN THE AMOUNT OF $100,000 TO THE SEC.
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).
AS A RESULT OF THIS CONDUCT, VCP FINANCIAL WILLFULLY VIOLATED SECTION 206(2) OF THE ADVISERS ACT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLICINTEREST TO POE THE SANCTIONS AGREED TO IN VCP FINANCIAL'S OFFER. ACCORDINGLY,
PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, IT IS HEREBY ORDERED THAT VCP FINANCIAL CEASE AND DESIST FROM
COMMITTING OR CASUING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(2) OF THE ADVISERS ACT; IS CENSURED; AND SHALL,
WITHIN 14 DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $100,000 TO THE SEC.