360 Financial

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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, CIVIL MONETARY PENALTY
3.
Date Initiated (MM/DD/YYYY): 
03/09/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-18214
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):
THIS MATTER INVOLVES THE FAILURE OF 360 FINANCIAL - A REGISTERED INVESTMENT ADVISER - TO DISCLOSE TO CLIENTS THAT IT RECEIVED A
FORGIVABLE LOAN OF $446,356 FROM A BROKER-DEALER (THE "BROKER-DEALER") AND A SEPARATE NON-FORGIVABLE LOAN FROM A BROKER THAT
PROVIDES CLEARING AND CUSTODY SERVICES FOR 360 FINANCIAL'S ADVISORY CLIENTS. 360 FINANCIAL DID NOT DISCLOSE THE LOAN OR THE
CONFLICT OF INTEREST ARISING FROM THIS COMPENSATION IN COMMISSION FILINGS OR OTHERWISE TO CLIENTS. BY FAILING TO DISCLOSE ITS
CONFLICT OF INTEREST COMPLETELY AND ACCURATELY, THE ADVISER VIOLATED SECTION 206(2) OF THE ADVISERS ACT. THE ADVISER ALSO VIOLATED
SECTION 207 OF THE ADVISERS ACT BY OMITTING MATERIAL FACTS FROM ITS COMMISSION FILINGS CONCERNING ITS RELATIONSHIP WITH THE
BROKER-DEALER.
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):
09/26/2017
 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: $ 40,000.00
 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: 
360 FINANCIAL SHALL, WITHIN FOURTEEN (14) DAYS OF THE ENTRY OF THIS ORDER, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $40,000
TO THE SECURITIES AND EXCHANGE COMMISSION FOR TRANSFER TO THE GENERAL FUND OF THE UNITED STATES TREASURY, SUBJECT TO
EXCHANGE ACT SECTION 21F(G)(3). IF TIMELY PAYMENT IS NOT MADE, ADDITIONAL INTEREST SHALL ACCRUE PURSUANT TO 31 U.S.C. §3717.
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 EXCHANGE COMMISSION (SEC) ISSUED AN ORDER AGAINST 360 FINANCIAL ON 09/26/2017 FOR FAILING TO DISCLOSE THAT ITS
OWNER RECEIVED A FORGIVABLE LOAN OF $446,356 AND A SEPARATE NON-FORGIVABLE LOAN ($127,530) FROM A BROKER-DEALER, WHICH
PROVIDES CLEARING AND CUSTODY SERVICES FOR 360 FINANCIAL'S ADVISORY CLIENTS. THE SEC FOUND THAT 360 FINANCIAL VIOLATED SECTION
206(2) OF THE ADVISERS ACT BY FAILING TO DISCLOSE ITS CONFLICT OF INTEREST COMPLETELY AND ACCURATELY AND SECTION 207 OF THE
ADVISERS ACT BY OMITTING MATERIAL FACTS CONCERNING ITS RELATIONSHIP WITH THE BROKER-DEALER. 360 FINANCIAL HAS BEEN ORDERED TO
CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS
ACT, CENSURED, AND ORDERED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $40,000 TO THE SEC.