Wilmington Trust Investment Management

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: 
DISGORGEMENT, CIVIL PENALTY(IES)/FINES.
3.
Date Initiated (MM/DD/YYYY): 
10/10/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-21780
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ORDER ALLEGES THAT BETWEEN FEBRUARY AND AUGUST 2020 WTIM (I) DID NOT PROVIDE ADEQUATE DISCLOSURE TO CLIENTS IN WTIM'S
PORTFOLIO ARCHITECT WRAP FEE PROGRAM (THE "WRAP FEE PROGRAM") CONCERNING ITS INVESTMENTS IN NO-TRANSACTION FEE MUTUAL FUND
SHARE CLASSES AND CERTAIN ASSOCIATED CONFLICTS OF INTEREST; (II) INVESTED CERTAIN WRAP FEE PROGRAM CLIENTS IN HIGHER-COST MUTUAL
FUND SHARE CLASSES THAN WERE OTHERWISE AVAILABLE; (III) AVOIDED CERTAIN TRANSACTION FEES FROM A NO-TRANSACTION FEE PROGRAM
OFFERED BY ITS CLEARING FIRM BY INVESTING ASSETS IN THE HIGHER-COST MUTUAL FUND SHARE CLASSES; (IV) BREACHED ITS DUTY OF CARE,
INCLUDING ITS DUTY TO SEEK BEST EXECUTION, BY CAUSING WRAP FEE PROGRAM CLIENTS TO INVEST IN CERTAIN SHARE CLASSES WHEN SHARE
CLASSES OF THE SAME FUNDS, OR OTHER SIMILAR FUNDS, THAT PRESENTED A MORE FAVORABLE VALUE WERE AVAILABLE; AND (V) FAILED TO ADOPT
AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE INVESTMENT
ADVISERS ACT OF 1940 ("ADVISERS ACT") AND THE RULES THEREUNDER IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION
PRACTICES. THE ORDER FINDS THAT, IN CONNECTION WITH THE ISSUES DESCRIBED ABOVE, WTIM VIOLATED SECTIONS 206(2) AND 206(4) OF THE
ADVISERS ACT AND RULE 206(4)-7 THEREUNDER.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
10/10/2023
 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: $ 1,327,147.00
 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 ORDER REQUIRES THAT WTIM (I) CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS OR FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; (II) IS CENSURED; (III) PAY DISGORGEMENT OF
$999,559, PREJUDGMENT INTEREST OF $77,588 AND A CIVIL PENALTY OF $250,000 FOR A TOTAL OF $1,327,147; AND (IV) COMPLY WITH
UNDERTAKINGS TO NOTIFYING AFFECTED INVESTORS OF THE SETTLEMENT TERMS. REQUIRED DISGORGEMENT, PREJUDGMENT INTEREST AND
CIVIL PENALTY AMOUNTS WERE PAID OCTOBER 12, 2023.
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 OCTOBER 10, 2023, THE SECURITIES AND EXCHANGE COMMISSION ("COMMISSION") ANNOUNCED IT HAD ENTERED INTO A SETTLEMENT WITH
WTIM CONCERNING SHARE CLASS SELECTION IN WTIM'S WRAP FEE PROGRAM. AS PART OF THE SETTLEMENT, WTIM HAS CONSENTED TO, WITHOUT
ADMITTING OR DENYING THE FINDINGS THEREIN, SOLELY FOR THE PURPOSE OF PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION OR
TO WHICH THE COMMISSION IS A PARTY, THE ENTRY OF AN ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSING
A CEASE-AND-DESIST ORDER ("ORDER") AGAINST WTIM, PURSUANT TO SECTION 203(E) AND 203(K) OF THE ADVISERS ACT. THE ALLEGATIONS,
DISPOSITIONS, FINDINGS, AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.