Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total AUM
Total Accounts
10Y AUM Change
Private Funds
Private funds reported by G. A. Repple & Company
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Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total Employees
Clients per Employee
10Y Employee Change
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
Each range applies to a separate reported relationship and should not be added together.
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
0%25%50%75%100%
G.A. REPPLE FINANCIAL GROUP, INC.Direct owner · Schedule AInterest in G. A. REPPLE & COMPANY
75%+
GLENN ALLEN REPPLEIndirect owner · Schedule BInterest in G.A. REPPLE FINANCIAL GROUP, INC.
75%+
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 G. A. Repple & Company.
Reported ownership and control details
Form ADV · Filing date 2026-03-30 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | G.A. REPPLE FINANCIAL GROUP, INC.PARENT CORPORATIONDomestic entity | G. A. REPPLE & COMPANY | 75% or moreCode E | Yes | PARENT CORPORATION11/1985 | Schedule APDF page 36 |
| 2 | GLENN ALLEN REPPLEPRESIDENT, GEN SEC PRINCIPALIndividual | G. A. REPPLE & COMPANY | Less than 5%Code NA | Yes | PRESIDENT, GEN SEC PRINCIPAL11/1985 | Schedule APDF page 36 |
| 3 | TIMOTHY GLENN MOYERCOOIndividual | G. A. REPPLE & COMPANY | Less than 5%Code NA | Yes | COO02/2020 | Schedule APDF page 36 |
| 4 | TIMOTHY GLENN MOYERCCOIndividual | G. A. REPPLE & COMPANY | Less than 5%Code NA | Yes | CCO02/2020 | Schedule APDF page 36 |
| 5 | GLENN ALLEN REPPLEMAJORITY STOCKHOLDERIndividual | G.A. REPPLE FINANCIAL GROUP, INC. | 75% or moreCode E | Yes | MAJORITY STOCKHOLDER09/2008 | Schedule BPDF page 37 |
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 3/30/2026 4:18:55 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.
RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
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 Yes
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- 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?Yes
- 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 actions3 Yes2 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?Yes
- 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?Yes
- 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 Yes
- 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?Yes
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 7 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 37–39
- Regulator name — filed text
- NASD DISTRICT 7 - ATLANTA, GA
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
NASD AUDIT IN AUGUST 2004 FOUND THAT FIRM MISSED INSPECING ONE OFFICE IN 2002 AND FIVE OFFICES IN 2003. HOWEVER, TWO OF THESE OFFICES WERE NOT OSJ'S AT THAT TIME AND ONE ISPECTION WAS POSTPONED DUE TO THE HOSPITALIZATION OF BRANCH MANAGER AND COULD NOT BE COMPLETED WITHIN THE SAME CALENDAR YEAR. THIS INSPECTION WAS COMPLETED WITHIN 40 DAYS AFTER THE ORIGINALLY SCHEDULED DATE. ALL REQUIRED INSPECTIONS FOR 2004 AND 2005 WERE COMPLETED. NASD FOUND CERTAIN REPRESENTATIVES WERE NOT REQUIRED TO ATTEND MAKE-UP MEETINGS IN 2002 AND IN 2003, AFTER MISSING THE PRIMARY COMPLIANCE SESSION. ALL REPRESENTATIVES HAVE ATTENDED THE REQUIRED COMPLIANCE MEETINGS IN 2004 AND 2005. ATTENDANCE FOR BOTH YEARS HAS BEEN DOCUMENTED IN GOOD ORDER.
Other filed details
Description of allegations — filed text
FIRM'S WSP CALL FOR ALL OSJ OFFICES TO BE INSPECTED ANNUALLY. FIRM MISSED INSPECTING OFFICES IN 2003& 2004. FIRM ALSO FAILED TO REQUIRE CERTAIN REPRESENTATIVES TO ATTEND AN ANNUAL COMPLIANCE SESSION.
Sanction detail — filed text
FIRM PAID FULL AMOUNT OF $5,000 FINE ON 1/13/2006.
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) NASD DISTRICT 7 - ATLANTA, GA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: FINE $5,000 3. Date Initiated (MM/DD/YYYY): 01/06/2006 Exact Explanation If not exact, provide explanation: DATE OF AWC LETTER EFFECTIVE ON ACCEPTANCE BY NASD. 4. Docket/Case Number: EXAM # E07040160, AWC# E072004016003 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): FIRM'S WSP CALL FOR ALL OSJ OFFICES TO BE INSPECTED ANNUALLY. FIRM MISSED INSPECTING OFFICES IN 2003& 2004. FIRM ALSO FAILED TO REQUIRE CERTAIN REPRESENTATIVES TO ATTEND AN ANNUAL COMPLIANCE SESSION. 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): 02/08/2006 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: $ 5,000.00 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: FIRM PAID FULL AMOUNT OF $5,000 FINE ON 1/13/2006. 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). NASD AUDIT IN AUGUST 2004 FOUND THAT FIRM MISSED INSPECING ONE OFFICE IN 2002 AND FIVE OFFICES IN 2003. HOWEVER, TWO OF THESE OFFICES WERE NOT OSJ'S AT THAT TIME AND ONE ISPECTION WAS POSTPONED DUE TO THE HOSPITALIZATION OF BRANCH MANAGER AND COULD NOT BE COMPLETED WITHIN THE SAME CALENDAR YEAR. THIS INSPECTION WAS COMPLETED WITHIN 40 DAYS AFTER THE ORIGINALLY SCHEDULED DATE. ALL REQUIRED INSPECTIONS FOR 2004 AND 2005 WERE COMPLETED. NASD FOUND CERTAIN REPRESENTATIVES WERE NOT REQUIRED TO ATTEND MAKE-UP MEETINGS IN 2002 AND IN 2003, AFTER MISSING THE PRIMARY COMPLIANCE SESSION. ALL REPRESENTATIVES HAVE ATTENDED THE REQUIRED COMPLIANCE MEETINGS IN 2004 AND 2005. ATTENDANCE FOR BOTH YEARS HAS BEEN DOCUMENTED IN GOOD ORDER.
regulatory · block 2PDF pages 39–41
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 25,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FIRM EMPLOYS INDEPENDENT CONTRACTOR REPRESENTATIVES. FIRM ATTEMPTED TO COMPLY BY ENGAGING THIRD PARTY EMAIL MONITORING VENDOR. DUE TO COMPLICATIONS IN CONVERTING UNIQUE EMAILS TO MONITORED SYSTEM THE PROJECT TOOK LONGER THAN PROJECTED AND WAS ONLY 90% COMPLETED AT THE TIME OF THE 2006 AUDIT. PROJECT WAS 100% COMPLETED WITHIN 30 DAYS AFTER AUDIT.
Other filed details
Description of allegations — filed text
FINRA ALLEGES THAT THE FIRM'S SYSTEM OF EMAIL MONITORING AND STORAGE DID NOT COMPLY WITH SEC RULE 17A-4 AND THAT WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO ASSURE COMPLIANCE.
Sanction detail — filed text
FIRM PAID $25,000 FINE ON 9/25/2007. AWC ACCEPTED 10/22/2007.
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) FINRA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 03/27/2007 Exact Explanation If not exact, provide explanation: TELEPHONE NOTICE OF ENFORCEMENT OF ISSUE FROM AUGUST 2006 BD AUDIT. 4. Docket/Case Number: EXAMINATION# 2006003701201 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): N/A 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): FINRA ALLEGES THAT THE FIRM'S SYSTEM OF EMAIL MONITORING AND STORAGE DID NOT COMPLY WITH SEC RULE 17A-4 AND THAT WRITTEN SUPERVISORY PROCEDURES WERE INADEQUATE TO ASSURE 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): 10/22/2007 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: $ 25,000.00 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: FIRM PAID $25,000 FINE ON 9/25/2007. AWC ACCEPTED 10/22/2007. 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). FIRM EMPLOYS INDEPENDENT CONTRACTOR REPRESENTATIVES. FIRM ATTEMPTED TO COMPLY BY ENGAGING THIRD PARTY EMAIL MONITORING VENDOR. DUE TO COMPLICATIONS IN CONVERTING UNIQUE EMAILS TO MONITORED SYSTEM THE PROJECT TOOK LONGER THAN PROJECTED AND WAS ONLY 90% COMPLETED AT THE TIME OF THE 2006 AUDIT. PROJECT WAS 100% COMPLETED WITHIN 30 DAYS AFTER AUDIT.
regulatory · block 3PDF pages 41–42
- Regulator name — filed text
- MASSACHUSETTS SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 25,000.00
- How was matter resolved — filed text
- Order
Other filed details
Description of allegations — filed text
ALLEGES G.A. REPPLE FAILED TO REASONABLY SUPERVISE ITS AGENT, ALAN SIEGEL, IN CONNECTION WITH FALSE INFORMATION POSTED TO HIS WEBSITE
Sanction detail — filed text
FIRM PAID $25,000 WITH CHECK DATED 9/26/2018.
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) MASSACHUSETTS SECURITIES DIVISION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 07/24/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E-2018-0003 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): ALLEGES G.A. REPPLE FAILED TO REASONABLY SUPERVISE ITS AGENT, ALAN SIEGEL, IN CONNECTION WITH FALSE INFORMATION POSTED TO HIS WEBSITE 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): 09/21/2018 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: $ 25,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: FIRM WILL CEASE AND DESIST FURTHER VIOLATION OF THE ACT AND REGULATIONS IN THE COMMONWEALTH. FIRM WILL CONDUCT HEIGHTENED SUPERVISION OF ALAN SIEGEL FIRM WILL HIRE INDEPENDENT COMPLIANCE CONSULTANT TO ADVISE ON POLICIES AND PROCEDURES REGARDING ADVERTISING AND COMMUNICATIONS 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: FIRM PAID $25,000 WITH CHECK DATED 9/26/2018. 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 4PDF pages 42–44
- Regulator name — filed text
- DELAWARE INSURANCE DEPARTMENT
- Monetary/Fine Amount — filed text
- $ 250.00
- How was matter resolved — filed text
- Stipulation and Consent
Other filed details
Description of allegations — filed text
G.A. REPPLE & COMPANY FAILED TO REPORT TO THE INSURANCE COMMISSIONER ANY ADMINISTRATIVE ACTION TAKEN AGAINST IT IN ANOTHER JURISDICTION OR BY ANOTHER GOVERNMENTAL AGENCY WITHIN 30 DAYS OF FINAL DISPOSITION AS REQUIRED BY 18 DEL.C. &1719(A).
Sanction detail — filed text
G.A. REPPLE & COMPANY'S PRODUCER LICENSE SUSPENDED FOR A PERIOD OF ONE YEAR. DELAWARE INSURANCE DEPARTMENT AGREED TO WAIVE THE SUSPENSION PERIOD UPON PAYMENT OF A FINE OF $250.00. G.A. REPPLE & COMPANY PAID DELAWARE INSURANCE DEPARTMENT $250.00 WITH A CHECK DATED 9/13/10.
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) DELAWARE INSURANCE DEPARTMENT 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: G.A. REPPLE & COMPANY'S PRODUCER LICENSE SHALL BE SUSPENDED FOR A PERIOD OF ONE YEAR. DELAWARE INSURANCE DEPARTMENT AGREES TO WAIVE THE SUSPENSION PERIOD UPON PAYMENT OF A FINE OF $250.00. 3. Date Initiated (MM/DD/YYYY): 09/08/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 1436-2010 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): G.A. REPPLE & COMPANY FAILED TO REPORT TO THE INSURANCE COMMISSIONER ANY ADMINISTRATIVE ACTION TAKEN AGAINST IT IN ANOTHER JURISDICTION OR BY ANOTHER GOVERNMENTAL AGENCY WITHIN 30 DAYS OF FINAL DISPOSITION AS REQUIRED BY 18 DEL.C. &1719(A). 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 10/27/2010 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: $ 250.00 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: G.A. REPPLE & COMPANY'S PRODUCER LICENSE SUSPENDED FOR A PERIOD OF ONE YEAR. DELAWARE INSURANCE DEPARTMENT AGREED TO WAIVE THE SUSPENSION PERIOD UPON PAYMENT OF A FINE OF $250.00. G.A. REPPLE & COMPANY PAID DELAWARE INSURANCE DEPARTMENT $250.00 WITH A CHECK DATED 9/13/10. 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 5REPPLE, GLENN ALLENPDF pages 44–46
- Advisory affiliate name — filed text
- REPPLE, GLENN ALLEN
- Regulator name — filed text
- NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
- Monetary/Fine Amount — filed text
- $ 3,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Other filed details
Description of allegations — filed text
IN 2011, G.A. REPPLE & COMPANY AND GLENN REPPLE PROVIDED MATERIALLY INCORRECT AND UNTRUE INFORMATION WITHIN THE MEANING OF SECTION 2110(A)(2) OF THE INSURANCE LAW ON THE RENEWAL APPLICATION FOR AN AGENT'S LICENSE BY FAILING TO DISCLOSE ADMINISTRATIVE ACTIONS, IMPOSITION OF MONETARY PENALTIES AGAINST G.A. REPPLE & COMPANY BY ANY OTHER STATE OR REGULATORY BODY. THE EVENTS AT ISSUE WITH NEW YORK OCCURRED BETWEEN OCTOBER 18, 2007 AND NOVEMBER 8, 2010.
Sanction detail — filed text
G.A. REPPLE & COMPANY PAID $3,000.00 BY CHECK DATED OCT. 21, 2011.
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: 374301 This advisory affiliate is a Firm an Individual Registered: Yes No Name: REPPLE, GLENN ALLEN (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) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/16/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: CSB-2011-768519 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): IN 2011, G.A. REPPLE & COMPANY AND GLENN REPPLE PROVIDED MATERIALLY INCORRECT AND UNTRUE INFORMATION WITHIN THE MEANING OF SECTION 2110(A)(2) OF THE INSURANCE LAW ON THE RENEWAL APPLICATION FOR AN AGENT'S LICENSE BY FAILING TO DISCLOSE ADMINISTRATIVE ACTIONS, IMPOSITION OF MONETARY PENALTIES AGAINST G.A. REPPLE & COMPANY BY ANY OTHER STATE OR REGULATORY BODY. THE EVENTS AT ISSUE WITH NEW YORK OCCURRED BETWEEN OCTOBER 18, 2007 AND NOVEMBER 8, 2010. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 10/25/2011 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: $ 3,000.00 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: G.A. REPPLE & COMPANY PAID $3,000.00 BY CHECK DATED OCT. 21, 2011. 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 6PDF pages 46–48
- Regulator name — filed text
- ALABAMA DEPARTMENT OF INSURANCE
- Monetary/Fine Amount — filed text
- $ 300.00
- How was matter resolved — filed text
- Stipulation and Consent
Other filed details
Description of allegations — filed text
G.A. REPPLE & COMPANY FAILED TO TIMELY REPORT WITHIN 30 DAYS OF THE HAPPENING OF VARIOUS EVENTS, INCLUDING THE IMPOSITION OF A MONETARY FINE BY ANY OTHER STATE OR ANY VIOLATION OF THE INSURANCE OR RELATED LAWS OF THAT STATE AS REQUIRED BY RULE 482-1-054-.03 WITHIN ALABAMA INSURANCE REGULATION. IN ADDITION, FOR PURPOSES OF ALABAMA CODE 27-7-19(A)(9), G.A. REPPLE & COMPANY PROVIDED INCORRECT INFORMATION IN QUESTION (2) OF THE NAIC UNIFORM APPLICATION FOR BUSINESS ENTITY INSURANCE LICENSE RENEWAL/CONTINUATION SUBMITTED IN OCTOBER, 2010 RELATED TO BE NAMED OR INVOLVE IN ANY ADMINISTRATIVE PROCEEDING REGARDING ANY PROFESSIONAL, OCCUPATIONAL LICENSE OR REGISTRATION.
Sanction detail — filed text
G.A. REPPLE PAID STATE OF ALABAMA DEPARTMENT OF INSURANCE $300.00 WITH A CHECK DATED NOV. 4, 2010.
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) ALABAMA DEPARTMENT OF INSURANCE 2. Principal Sanction: Other Other Sanctions: ADMINISTRATIVE ASSESSMENT OF $300.00. SAID PAYMENT IS NOT A FINE OR CIVIL PENALTY. 3. Date Initiated (MM/DD/YYYY): 10/21/2010 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: P-2010-222FM 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): G.A. REPPLE & COMPANY FAILED TO TIMELY REPORT WITHIN 30 DAYS OF THE HAPPENING OF VARIOUS EVENTS, INCLUDING THE IMPOSITION OF A MONETARY FINE BY ANY OTHER STATE OR ANY VIOLATION OF THE INSURANCE OR RELATED LAWS OF THAT STATE AS REQUIRED BY RULE 482-1-054-.03 WITHIN ALABAMA INSURANCE REGULATION. IN ADDITION, FOR PURPOSES OF ALABAMA CODE 27-7-19(A)(9), G.A. REPPLE & COMPANY PROVIDED INCORRECT INFORMATION IN QUESTION (2) OF THE NAIC UNIFORM APPLICATION FOR BUSINESS ENTITY INSURANCE LICENSE RENEWAL/CONTINUATION SUBMITTED IN OCTOBER, 2010 RELATED TO BE NAMED OR INVOLVE IN ANY ADMINISTRATIVE PROCEEDING REGARDING ANY PROFESSIONAL, OCCUPATIONAL LICENSE OR REGISTRATION. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 11/08/2010 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: $ 300.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: SAID PAYMENT IS NOT A FINE OR CIVIL PENALTY. 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: G.A. REPPLE PAID STATE OF ALABAMA DEPARTMENT OF INSURANCE $300.00 WITH A CHECK DATED NOV. 4, 2010. 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).
Show 1 more source blocks
regulatory · block 7PDF pages 48–50
- Regulator name — filed text
- SECURITIES & EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 549,689.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
ON SEPTEMBER 30, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR, DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS. WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER- COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.
Other filed details
Description of allegations — filed text
ON SEPTEMBER 30, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR, DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS. WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND 203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER- COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.
Sanction detail — filed text
G. A. REPPLE & COMPANY PLACED THE FOLLOWING INTO ESCROW TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.
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)
SECURITIES & EXCHANGE COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF
1934 AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A
CEASEAND-DESIST ORDER
3.
Date Initiated (MM/DD/YYYY):
01/26/2023
Exact
Explanation
If not exact, provide explanation:
THE SECURITIES & EXCHANGE COMMISSION IS REVIEWING PRACTICES SURROUNDING 12B-1 FEES AND CASH SWEEPS OF MONEY MARKET FUNDS
RELATED TO THE 2018 SEC SHARE DISCLOSURE INITIATIVE.
4.
Docket/Case Number:
FILE NO. 3-22220
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:
MONEY MARKET FUND(S)
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON SEPTEMBER 30, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND
FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR,
DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID
FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET
MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED
CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED
REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE
REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS.
WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE
DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF
CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY
MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE
CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO
DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF
ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS
PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF
REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF
THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND
203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER-
COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND
PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND
A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424
CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000
CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.
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):
09/30/2024
Exact
Explanation
If not exact, provide explanation:
, p
p
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 549,689.00
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:
G. A. REPPLE & COMPANY PLACED THE FOLLOWING INTO ESCROW TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT
OF $356,265 AND PREJUDGMENT INTEREST OF $80,424 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A
CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000 CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.
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, 2024, G. A. REPPLE & COMPANY (GAR) CONSENTED TO AN SEC ORDER REGARDING GAR'S NON-COMPLIANCE TO PROVIDE FULL AND
FAIR DISCLOSURE IN CONNECTION WITH ITS RECEIPT OF THIRD-PARTY COMPENSATION BASED ON ADVISORY CLIENT INVESTMENTS. IN PARTICULAR,
DURING THE RELEVANT PERIOD, G.A. REPPLE RECOMMENDED OR INVESTED ADVISORY CLIENT ASSETS IN (1) MUTUAL FUND SHARE CLASSES THAT PAID
FEES PURSUANT TO RULE 12B-1 UNDER THE INVESTMENT COMPANY ACT OF 1940 ("12B-1 FEES"), WHICH G.A. REPPLE RECEIVED; (2) MONEY MARKET
MUTUAL FUNDS HELD IN CASH SWEEP ACCOUNTS FOR WHICH G.A. REPPLE RECEIVED REVENUE SHARING PAYMENTS FROM ITS UNAFFILIATED
CLEARING BROKER (THE "CLEARING BROKER"); AND (3) NO-TRANSACTION FEE ("NTF") MUTUAL FUND INVESTMENTS FOR WHICH G.A. REPPLE RECEIVED
REVENUE SHARING PAYMENTS. FOR AT LEAST A PORTION OF THE RELEVANT PERIOD, G.A. REPPLE FAILED TO PROVIDE FULL AND FAIR DISCLOSURE
REGARDING ITS SHARE CLASS SELECTION PRACTICES AND CONFLICTS OF INTEREST ASSOCIATED WITH ITS RECEIPT OF THE FOREGOING PAYMENTS.
WITH RESPECT TO THE 12B-1 FEES, G.A. REPPLE, ALTHOUGH ELIGIBLE TO DO SO, DID NOT SELF-REPORT TO THE COMMISSION PURSUANT TO THE
DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. FURTHER, G.A. REPPLE WAS IN NON-COMPLIANCE WITH ITS DUTY OF
CARE, INCLUDING THE DUTY TO SEEK BEST EXECUTION BY CAUSING ADVISORY CLIENTS TO INVEST IN SHARE CLASSES OF MUTUAL FUNDS AND MONEY
MARKET FUNDS WHEN SHARE CLASSES OF THE SAME FUNDS WERE AVAILABLE TO CLIENTS THAT PRESENTED A MORE FAVORABLE VALUE FOR THESE
CLIENTS UNDER THE PARTICULAR CIRCUMSTANCES IN PLACE AT THE TIME OF THE TRANSACTIONS, AND BY FAILING TO UNDERTAKE AN ANALYSIS TO
DETERMINE WHETHER THE PARTICULAR MUTUAL FUND AND MONEY MARKET FUND SHARE CLASSES IT RECOMMENDED WERE IN THE BEST INTERESTS OF
ITS ADVISORY CLIENTS. FINALLY, G.A. REPPLE WAS IN NON-COMPLIANCE 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 ITS
PRACTICES CONCERNING MUTUAL FUND AND MONEY MARKET FUND SHARE CLASS SELECTION PRACTICES, CASH SWEEP REVENUE SHARING, AND NTF
REVENUE SHARING. AS A RESULT OF THE CONDUCT DESCRIBED ABOVE, G.A. REPPLE WAS IN NON-COMPLIANCE WITH SECTIONS 206(2) AND 206(4) OF
THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, PURSUANT TO SECTION 15(B) OF THE EXCHANGE ACT AND SECTIONS 203(E) AND
203(K) OF THE ADVISERS ACT, G. A. REPPLE & COMPANY CONSENTED TO EVALUATE WHETHER CLIENTS SHOULD BE MOVED TO AN AVAILABLE LOWER-
COST SHARE CLASS AND MOVE CLIENTS AS NECESSARY; NOTIFY AFFECTED INVESTORS OF THE SETTLEMENT TERMS; UPDATE POLICIES AND
PROCEDURES AS NECESSARY; CORRECT AS NECESSARY ALL RELEVANT DISCLOSURE DOCUMENTS; PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND
A CIVIL PENALTY, TOTALING $549,689 AS FOLLOWS: RESPONDENT SHALL PAY DISGORGEMENT OF $356,265 AND PREJUDGMENT INTEREST OF $80,424
CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C. RESPONDENT SHALL PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $113,000
CONSISTENT WITH THE PROVISIONS OF THIS SUBSECTION C.* 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.