Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Goldstone Financial Group, LLC
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
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
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
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 Goldstone Financial Group, LLC.
No indirect ownership information reported in the source’s Schedule B.
Reported ownership and control details
Form ADV · Filing date 2026-03-31 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | ANTHONY PELLEGRINOOWNER/MANAGING MEMBERIndividual | GOLDSTONE FINANCIAL GROUP, LLC | 75% or moreCode E | Yes | OWNER/MANAGING MEMBER11/2008 | Schedule APDF page 28 |
| 2 | BRIAN ROBERT KORIENEKMINORITY OWNERIndividual | GOLDSTONE FINANCIAL GROUP, LLC | 10% to less than 25%Code B | No | MINORITY OWNER09/2022 | Schedule APDF page 28 |
| 3 | Ian Disbrow MeiksinsCHIEF COMPLIANCE OFFICERIndividual | GOLDSTONE FINANCIAL GROUP, LLC | Less than 5%Code NA | No | CHIEF COMPLIANCE OFFICER11/2025 | Schedule APDF page 28 |
| 4 | JESSICA B DEBOLDPRESIDENTIndividual | GOLDSTONE FINANCIAL GROUP, LLC | Less than 5%Code NA | Yes | PRESIDENT08/2025 | Schedule APDF page 28 |
| 5 | MATTHEW RAYMON RICECHIEF INVESTMENT OFFICERIndividual | GOLDSTONE FINANCIAL GROUP, LLC | Less than 5%Code NA | Yes | CHIEF INVESTMENT OFFICER10/2025 | Schedule APDF page 28 |
| 6 | STEPHEN MARTIN LAPOINTECHIEF OPERATIONS OFFICERIndividual | GOLDSTONE FINANCIAL GROUP, LLC | Less than 5%Code NA | Yes | CHIEF OPERATIONS OFFICER12/2025 | Schedule APDF page 28 |
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 3/31/2026 3:45:19 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.
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 actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- 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?No
- 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 actions1 Yes4 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?No
- 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?No
- 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 actions4 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?No
- 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 No
- 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?No
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 2 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 1PELLEGRINO, ANTHONYPDF pages 29–30
- Advisory affiliate name — filed text
- PELLEGRINO, ANTHONY
- Regulator name — filed text
- IDAHO DEPARTMENT OF FINANCE
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
IN 2017 A RECOMMENDATION WAS MADE TO A HUSBAND AND WIFE WHO HELD AN INSURANCE RELATIONSHIP SINCE 2013 AND HELD AN ADVISORY RELATIONSHIP WITH THE FIRM SINCE 2015. WHEN THE RELATIONSHIP BEGAN THEIR RESIDENCE WAS IN ILLINOIS. SHORTLY BEFORE THE RECOMMENDATION WAS MADE OF THE SECURITY IN QUESTION THE COUPLE RELOCATED TO IDAHO. THE HOUSEHOLD REMAINS A CLIENT AND CONTINUES TO BE ADVISED BY THE FIRM ON THEIR INVESTMENTS.
Other filed details
Description of allegations — filed text
VIOLATION OF IDAHO CODE 30-14-502 BY MAKING AN UNSUITABLE RECOMMENDATION OF AN UNREGISTERED SECURITY TO ONE CLIENT WHO RESIDES IN IDAHO.
Sanction detail — filed text
FINE PAID IN FULL ON 2/4/2022
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: 6390276 This advisory affiliate is a Firm an Individual Registered: Yes No Name: PELLEGRINO, ANTHONY (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) IDAHO DEPARTMENT OF FINANCE 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 01/05/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2019-7-05-C 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: NOTE 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): VIOLATION OF IDAHO CODE 30-14-502 BY MAKING AN UNSUITABLE RECOMMENDATION OF AN UNREGISTERED SECURITY TO ONE CLIENT WHO RESIDES IN IDAHO. 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): 01/05/2022 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: $ 10,000.00 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: FINE PAID IN FULL ON 2/4/2022 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). IN 2017 A RECOMMENDATION WAS MADE TO A HUSBAND AND WIFE WHO HELD AN INSURANCE RELATIONSHIP SINCE 2013 AND HELD AN ADVISORY RELATIONSHIP WITH THE FIRM SINCE 2015. WHEN THE RELATIONSHIP BEGAN THEIR RESIDENCE WAS IN ILLINOIS. SHORTLY BEFORE THE RECOMMENDATION WAS MADE OF THE SECURITY IN QUESTION THE COUPLE RELOCATED TO IDAHO. THE HOUSEHOLD REMAINS A CLIENT AND CONTINUES TO BE ADVISED BY THE FIRM ON THEIR INVESTMENTS.
regulatory · block 2PDF pages 30–33
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 150,000.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
AS DETAILED MORE FULLY IN THE ORDER, THIS MATTER ARISES FROM THE PERIOD MAY 2017 THROUGH JUNE 2018, DURING WHICH TIME THE FIRM, ANTHONY PELLEGRINO AND MICHAEL PELLEGRINO, A FORMER MANAGER AND OWNER DISCUSSED BELOW, OFFERED AND SOLD AN INVESTMENT OF A THIRD PARTY COMPANY CALLED 1 GLOBAL CAPITAL (1GC), WHICH FILED FOR BANKRUPTCY IN JULY 2018, AFTER WHICH THE SEC CHARGED 1GC AND ITS OWNER WITH OFFERING AND SELLING 1GC INVESTMENTS AS UNREGISTERED SECURITIES, WHERE THERE WAS NO APPLICABLE EXEMPTION FROM REGISTRATION, AS WELL AS MISREPRESENTATIONS REGARDING AMONG OTHER FACTS, THE USE OF INVESTOR FUNDS, THE VALUE OF THE INVESTMENTS AND THAT THE 1GC INVESTMENTS WERE EXEMPT FROM THE REGISTRATION REQUIREMENTS UNDER THE SECURITIES LAWS. 1GC AND ITS PRINCIPAL OWNER SUBSEQUENTLY SETTLED THE SEC'S CHARGES AGAINST IT. NEITHER THE FIRM, ANTHONY NOR MICHAEL PELLEGRINO WERE AWARE OF 1GC'S MISREPRESENTATIONS AND INDEED WERE THEMSELVES MISLEAD BY 1GC AND ITS OUTSIDE SECURITIES COUNSEL. IN THIS REGARD, 1GC OBTAINED OUTSIDE SECURITIES COUNSEL WHO PREPARED FALSE LEGAL OPINIONS AND WHO FALSELY MISREPRESENTED TO MICHAEL AND ANTHONY THAT THE 1GC INVESTMENT RETURNS WERE VALIDATED BY AN INDEPENDENT ACCOUNTING FIRM AND TOUTED LEGAL OPINIONS AUTHORED BY OUTSIDE COUNSEL THAT THE 1GC INVESTMENTS WERE NOT CONSIDERED SECURITIES SUBJECT TO REGISTRATION. IN RELIANCE UPON 1GC AND 1GC'S OUTSIDE SECURITIES COUNSEL, AND DESPITE EFFORTS TO CONDUCT THEIR OWN RESEARCH AND ANALYSIS REGARDING 1GC AND ITS INVESTMENTS INCLUDING IN-PERSON MEETINGS AT 1GC, NUMEROUS COMMUNICATIONS WITH 1GC AND ITS OUTSIDE SECURITIES COUNSEL, THE FIRM, ANTHONY PELLEGRINO AND MICHAEL PELLEGRINO OFFERED AND SOLD THE UNREGISTERED 1GC SECURITIES BETWEEN MAY 2017 AND JUNE 2018 TO GOLDSTONE CLIENTS AS AN ALTERNATIVE INVESTMENT PRODUCT FOR THEIR CLIENTS' INVESTMENT PORTFOLIOS. IN DOING SO, THE FIRM, ANTHONY, AND MICHAEL ALSO DID NOT ADEQUATELY DISCLOSE THE FEES THEY RECEIVED FROM 1GC TO THEIR ADVISORY CLIENTS INCLUDING THAT THEY RECEIVED REFERRAL FEES FOR REFERRING CLIENTS TO 1GC, THE DISCLOSURE OF WHICH WOULD HAVE BEEN IMPORTANT IN DECIDING WHETHER TO INVEST IN THE 1GC INVESTMENT. AFTER 1GC FILED FOR BANKRUPTCY AND WAS CHARGED BY THE SEC, THE FIRM AND ANTHONY PROVIDED FUNDS TO FACILITATE A SETTLEMENT WITH ALL ITS CLIENTS WHO INVESTED IN 1GC, RETURNING THE REFERRAL FEES RECEIVED FROM 1GC IN ADDITION TO INSURANCE PROCEEDS. THE FIRM AND ANTHONY ALSO ASSISTED ITS CLIENTS AT THEIR EXPENSE TO FILE PROOFS OF CLAIM IN THE 1GC BANKRUPTCY. THE FIRM ALSO HIRED A NEW CHIEF COMPLIANCE OFFICER (WHO IS STILL HERE), CREATED A NEW DUE DILIGENCE COMMITTEE TO REVIEW AND APPROVE NEW INVESTMENT PRODUCTS, REVISED RELEVANT POLICIES AND PROCEDURES INCLUDING PROHIBITIONS ON OFFERING ANY UNREGISTERED SECURITIES. IN ENTERING THE ORDER, THE SEC CONSIDERED THE FIRM'S AND ANTHONY'S REMEDIAL EFFORTS PROMPTLY UNDERTAKEN AND COOPERATION AFFORDED THE SEC.
Other filed details
Description of allegations — filed text
ON MARCH 28, 2022, THE FIRM AND ITS OWNER AND PRINCIPAL, ANTHONY PELLEGRINO, WERE THE SUBJECT OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS (THE "ORDER") ENTERED BY THE SEC, TO WHICH THEY PREVIOUSLY CONSENTED WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND DESIST ORDER FROM AND BASED ON VIOLATIONS OF SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTIONS 5(A) AND (C) OF THE SECURITIES ACT OF 1933.
Sanction detail — filed text
CENSURE OF FIRM AND ANTHONY PELLEGRINO, CIVIL MONETARY PENALTY OF $70,000 PAYABLE BY THE FIRM, CIVIL MONETARY PENALTY OF $30,000 PAYABLE BY ANTHONY PELLEGRINO, BAR OF MICHAEL PELLEGRINO FROM AFFILIATION WITH INVESTMENT ADVISER AS OF MARCH 28, 2022, CIVIL MONETARY PENALTY OF $50,000 PAYABLE BY MICHAEL PELLEGRINO.
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: 6390276 This advisory affiliate is a Firm an Individual Registered: Yes No Name: PELLEGRINO, ANTHONY (For individuals, Last, First, Middle) CRD Number: 5900843 This advisory affiliate is a Firm an Individual Registered: Yes No Name: PELLEGRINO, MICHAEL, AUGUST (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: CENSURE OF FIRM AND ANTHONY PELLEGRINO, CIVIL MONETARY PENALTY OF $70,000 PAYABLE BY THE FIRM, CIVIL MONETARY PENALTY OF $30,000 PAYABLE BY ANTHONY PELLEGRINO, BAR OF MICHAEL PELLEGRINO FROM AFFILIATION WITH INVESTMENT ADVISER, CIVIL MONETARY PENALTY OF $50,000 PAYABLE BY MICHAEL PELLEGRINO 3. Date Initiated (MM/DD/YYYY): 03/28/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ADMINISTRATIVE PROCEEDING FILE NO. 3-20805 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): GOLDSTONE FINANCIAL GROUP, LLC 6. Principal Product Type: Other Other Product Types: NOTES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON MARCH 28, 2022, THE FIRM AND ITS OWNER AND PRINCIPAL, ANTHONY PELLEGRINO, WERE THE SUBJECT OF AN ORDER INSTITUTING ADMINISTRATIVE AND CEASE AND DESIST PROCEEDINGS (THE "ORDER") ENTERED BY THE SEC, TO WHICH THEY PREVIOUSLY CONSENTED WITHOUT ADMITTING OR DENYING THE FINDINGS THEREIN, MAKING FINDINGS AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND DESIST ORDER FROM AND BASED ON VIOLATIONS OF SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF 1940 AND SECTIONS 5(A) AND (C) OF THE SECURITIES ACT OF 1933. 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): 03/28/2022 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: $ 150,000.00 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: CENSURE OF FIRM AND ANTHONY PELLEGRINO, CIVIL MONETARY PENALTY OF $70,000 PAYABLE BY THE FIRM, CIVIL MONETARY PENALTY OF $30,000 PAYABLE BY ANTHONY PELLEGRINO, BAR OF MICHAEL PELLEGRINO FROM AFFILIATION WITH INVESTMENT ADVISER AS OF MARCH 28, 2022, CIVIL MONETARY PENALTY OF $50,000 PAYABLE BY MICHAEL PELLEGRINO. 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 DETAILED MORE FULLY IN THE ORDER, THIS MATTER ARISES FROM THE PERIOD MAY 2017 THROUGH JUNE 2018, DURING WHICH TIME THE FIRM, ANTHONY PELLEGRINO AND MICHAEL PELLEGRINO, A FORMER MANAGER AND OWNER DISCUSSED BELOW, OFFERED AND SOLD AN INVESTMENT OF A THIRD PARTY COMPANY CALLED 1 GLOBAL CAPITAL (1GC), WHICH FILED FOR BANKRUPTCY IN JULY 2018, AFTER WHICH THE SEC CHARGED 1GC AND ITS OWNER WITH OFFERING AND SELLING 1GC INVESTMENTS AS UNREGISTERED SECURITIES, WHERE THERE WAS NO APPLICABLE EXEMPTION FROM REGISTRATION, AS WELL AS MISREPRESENTATIONS REGARDING AMONG OTHER FACTS, THE USE OF INVESTOR FUNDS, THE VALUE OF THE INVESTMENTS AND THAT THE 1GC INVESTMENTS WERE EXEMPT FROM THE REGISTRATION REQUIREMENTS UNDER THE SECURITIES LAWS. 1GC AND ITS PRINCIPAL OWNER SUBSEQUENTLY SETTLED THE SEC'S CHARGES AGAINST IT. NEITHER THE FIRM, ANTHONY NOR MICHAEL PELLEGRINO WERE AWARE OF 1GC'S MISREPRESENTATIONS AND INDEED WERE THEMSELVES MISLEAD BY 1GC AND ITS OUTSIDE SECURITIES COUNSEL. IN THIS REGARD, 1GC OBTAINED OUTSIDE SECURITIES COUNSEL WHO PREPARED FALSE LEGAL OPINIONS AND WHO FALSELY MISREPRESENTED TO MICHAEL AND ANTHONY THAT THE 1GC INVESTMENT RETURNS WERE VALIDATED BY AN INDEPENDENT ACCOUNTING FIRM AND TOUTED LEGAL OPINIONS AUTHORED BY OUTSIDE COUNSEL THAT THE 1GC INVESTMENTS WERE NOT CONSIDERED SECURITIES SUBJECT TO REGISTRATION. IN RELIANCE UPON 1GC AND 1GC'S OUTSIDE SECURITIES COUNSEL, AND DESPITE EFFORTS TO CONDUCT THEIR OWN RESEARCH AND ANALYSIS REGARDING 1GC AND ITS INVESTMENTS INCLUDING IN-PERSON MEETINGS AT 1GC, NUMEROUS COMMUNICATIONS WITH 1GC AND ITS OUTSIDE SECURITIES COUNSEL, THE FIRM, ANTHONY PELLEGRINO AND MICHAEL PELLEGRINO OFFERED AND SOLD THE UNREGISTERED 1GC SECURITIES BETWEEN MAY 2017 AND JUNE 2018 TO GOLDSTONE CLIENTS AS AN ALTERNATIVE INVESTMENT PRODUCT FOR THEIR CLIENTS' INVESTMENT PORTFOLIOS. IN DOING SO, THE FIRM, ANTHONY, AND MICHAEL ALSO DID NOT ADEQUATELY DISCLOSE THE FEES THEY RECEIVED FROM 1GC TO THEIR ADVISORY CLIENTS INCLUDING THAT THEY RECEIVED REFERRAL FEES FOR REFERRING CLIENTS TO 1GC, THE DISCLOSURE OF WHICH WOULD HAVE BEEN IMPORTANT IN DECIDING WHETHER TO INVEST IN THE 1GC INVESTMENT. AFTER 1GC FILED FOR BANKRUPTCY AND WAS CHARGED BY THE SEC, THE FIRM AND ANTHONY PROVIDED FUNDS TO FACILITATE A SETTLEMENT WITH ALL ITS CLIENTS WHO INVESTED IN 1GC, RETURNING THE REFERRAL FEES RECEIVED FROM 1GC IN ADDITION TO INSURANCE PROCEEDS. THE FIRM AND ANTHONY ALSO ASSISTED ITS CLIENTS AT THEIR EXPENSE TO FILE PROOFS OF CLAIM IN THE 1GC BANKRUPTCY. THE FIRM ALSO HIRED A NEW CHIEF COMPLIANCE OFFICER (WHO IS STILL HERE), CREATED A NEW DUE DILIGENCE COMMITTEE TO REVIEW AND APPROVE NEW INVESTMENT PRODUCTS, REVISED RELEVANT POLICIES AND PROCEDURES INCLUDING PROHIBITIONS ON OFFERING ANY UNREGISTERED SECURITIES. IN ENTERING THE ORDER, THE SEC CONSIDERED THE FIRM'S AND ANTHONY'S REMEDIAL EFFORTS PROMPTLY UNDERTAKEN AND COOPERATION AFFORDED THE SEC.
* 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.