Firm profile

First Dallas Securities, Inc..

DALLAS, TXCRD 24549Registration Status: ApprovedEffective since January 30, 2006SEC # 801-66208Latest ADV October 31, 2025

First Dallas Securities, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Dallas, TX. Its latest Form ADV filing, dated October 31, 2025, reports $336M in regulatory assets under management, 20 employees, 1 office, and 266 accounts.

Assets Under Management
$336M
Employees
20
Offices
1 office
Total Clients
266

Associated firm names

2 names listed
  • FIRST DALLAS SECURITIES INCORPORATED
  • FIRST DALLAS SECURITIES, INC.

Leadership

2 roles identified
CEOCraig Donaldson Hodges
CCOCharmagne Marie Darabadey

Advisory services offered

1 types reported
Portfolio management for individuals and small businesses

Fee models offered

1 types reported
Commissions

Offices & Contact

Primary office

DALLAS, Texas, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Texas

DALLASPrimary office

1 office records listed · 1 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$336Mas of October 31, 2025
Discretionary100.0%
$336M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 57.9% of total clients.
Top client categories% of clientsClients
1
Individuals
57.9%
154
2
HNWI
37.2%
99
3
Corporations
3.0%
8
4
Charitable
1.1%
3
5
Banks
0.8%
2

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$336M
Total Accounts266
10Y AUM Change+$196M (+140.3%)

Private Funds

Private funds reported by First Dallas Securities, Inc..

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Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees20
Clients per Employee13:1
10Y Employee Change-7 (-25.9%)

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%
HODGES CAPITAL HOLDINGS, INC.Direct owner · Schedule AInterest in FIRST DALLAS SECURITIES, INC.
75%+
CLARK BROWN HODGESIndirect owner · Schedule BInterest in HODGES CAPITAL HOLDINGS VOTING TRUST
25% to < 50%
CRAIG DONALDSON HODGESIndirect owner · Schedule BInterest in HODGES CAPITAL HOLDINGS VOTING TRUST
25% to < 50%
HODGES CAPITAL HOLDINGS VOTING TRUSTIndirect owner · Schedule BInterest in HODGES CAPITAL HOLDINGS, INC.
25% to < 50%

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 First Dallas Securities, Inc...

Reported ownership and control details

Form ADV · Filing date 2025-10-31 · Schedules A and B

8 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1HODGES CAPITAL HOLDINGS, INC.SHAREHOLDERDomestic entityFIRST DALLAS SECURITIES, INC.75% or moreCode EYesSHAREHOLDER05/1989Schedule APDF page 20
2CRAIG DONALDSON HODGESPRESIDENTIndividualFIRST DALLAS SECURITIES, INC.Less than 5%Code NAYesPRESIDENT09/2000Schedule APDF page 20
3GARY MACK BRADSHAWMUNI PRINCIPALIndividualFIRST DALLAS SECURITIES, INC.Less than 5%Code NANoMUNI PRINCIPAL08/2019Schedule APDF page 20
4CHARMAGNE MARIE DARABADEYCHIEF COMPLIANCE OFFICERIndividualFIRST DALLAS SECURITIES, INC.Less than 5%Code NAYesCHIEF COMPLIANCE OFFICER03/2021Schedule APDF page 20
5STANLEY GLEN III HAYSFINOPIndividualFIRST DALLAS SECURITIES, INC.Less than 5%Code NANoFINOP01/2024Schedule APDF page 21
6CLARK BROWN HODGESTRUSTEEIndividualHODGES CAPITAL HOLDINGS VOTING TRUST25% to less than 50%Code CYesTRUSTEE10/2011Schedule BPDF page 21
7CRAIG DONALDSON HODGESTRUSTEEIndividualHODGES CAPITAL HOLDINGS VOTING TRUST25% to less than 50%Code CYesTRUSTEE10/2011Schedule BPDF page 21
8HODGES CAPITAL HOLDINGS VOTING TRUSTSHAREHOLDERDomestic entityHODGES CAPITAL HOLDINGS, INC.25% to less than 50%Code CNoSHAREHOLDER10/2011Schedule BPDF page 21

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 10/31/2025 2:21:33 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 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?No
  • 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?No
  • 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?No
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 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 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 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 1MARSHALL, ERIC, JAYPDF pages 22–23
Advisory affiliate name — filed text
MARSHALL, ERIC, JAY
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:
2981115
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MARSHALL, ERIC, JAY
(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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: $
 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: 
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 2PDF pages 23–25
Regulator name — filed text
ALABAMA STATE SECURITIES
Monetary/Fine Amount — filed text
$ 5,000.00
How was matter resolved — filed text
Stipulation and Consent

Action status / disposition — filed text

ON 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS. BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A CONSENT ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000 AND INVESTIGATIVE COSTS OF $2500.
Other filed details

Description of allegations — filed text

ON 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS. BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A CONSENT ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000 AND INVESTIGATIVE COSTS OF $2500.

Sanction detail — filed text

ON 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS. BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A CONSENT ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000 AND INVESTIGATIVE COSTS OF $2500.
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 STATE SECURITIES
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
05/22/1997
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CO-97-0023
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED
INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL
RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS.
BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A CONSENT
ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000 AND
INVESTIGATIVE COSTS OF $2500.
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):
05/22/1997
 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: 
ON 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED
INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL
RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS.
BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A
CONSENT ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000
AND INVESTIGATIVE COSTS OF $2500.
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 9/23/96, FIRST DALLAS SECURITIES, INC. (FDS) FILED AN APPLICATION FOR REG. AS A DEALER W/ THE COMMISSION AND FURNISHED
INFORMATION THAT DURING THE PERIOD 1/22/91-7/23/96 A TOTAL OF 71 BUYS AND 45 SALES HAD BEEN EFFECTED IN THE ACCOUNTS OF 11 AL
RESIDENTS IN AGGREGATE AMT OF $634,280.54, WHICH RESULTED IN 2 ACCEPTING OFFERS; 5 REJECTING AND 4 NOT RESPONDING TO OFFERS.
BASED UPON A VIOLATION OF SECTION 8-6-3(A), CODE OF AL 1975, FOR EFFECTING TRANSACTIONS W/OUT BENEFIT OF REGISTRATION. A CONSENT
ORDER WAS ENTERED ON 5/22/97, RESOLVING THE VIOLATION AND FDS WAS LEVIED AN ADMINISTRATION ASSESSMENT OF $5,000 AND
INVESTIGATIVE COSTS OF $2500.
regulatory · block 3PDF pages 25–27
Regulator name — filed text
STATE OF IDAHO, DEPARTMENT OF FINANCE, SECURITIES BUREAU
Monetary/Fine Amount — filed text
$ 500.00
How was matter resolved — filed text
Order

Action status / disposition — filed text

AS PART OF THE REVIEW OF THE FIRM'S BROKER-DEALER REGISTRATION APPLICATION, IDAHO REQUESTED INFORMATION REGARDING ANY SECURITIES BUSINESS CONDUCTED BY THE FIRM IN IDAHO. THE FIRM ANSWERED BY INDICATING THAT IT CURRENTLY HAS AN ACCOUNT THAT WAS OPENED ON JUNE 18, 1999 ON BEHALF OF A CALIFORNIA CLIENT. ON OCTOBER 18, 2000 THE FIRM WAS NOTIFIED THAT THE CLIENT HAS RELOCATED TO IDAHO. FOLLOWING THE CLIENT'S MOVE TO IDAHO, THE FIRM EXECUTED TWO "BUY" ORDER ON BEHALF OF THE CLIENT ON OCTOBER 27, 2000 AND ON NOVEMBER 6, 2000 RESPECTIVELY.
Other filed details

Description of allegations — filed text

THE FIRM TRANSACTED BUSINESS (2 BUY ORDERS) IN IDAHO AS A BROKER-DEALER WITHOUT BEING REGISTERED AS A BROKER-DEALER IN IDAHO.

Sanction detail — filed text

FIRM AGREED TO PAY A CIVIL PENALTY OF $500 WITHIN THIRTY (30) DAYS OF THE DATE OF THE FINAL ORDER. THE FINE WAS PAID ON MARCH 7, 2001.
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) 
STATE OF IDAHO, DEPARTMENT OF FINANCE, SECURITIES BUREAU
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/18/2000
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2000-7-75
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FIRM TRANSACTED BUSINESS (2 BUY ORDERS) IN IDAHO AS A BROKER-DEALER WITHOUT BEING REGISTERED AS A BROKER-DEALER 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):
03/12/2001
 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: $ 500.00
 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 AGREED TO PAY A CIVIL PENALTY OF $500 WITHIN THIRTY (30) DAYS OF THE DATE OF THE FINAL ORDER. THE FINE WAS PAID ON MARCH 7,
2001.
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 PART OF THE REVIEW OF THE FIRM'S BROKER-DEALER REGISTRATION APPLICATION, IDAHO REQUESTED INFORMATION REGARDING ANY SECURITIES
BUSINESS CONDUCTED BY THE FIRM IN IDAHO. THE FIRM ANSWERED BY INDICATING THAT IT CURRENTLY HAS AN ACCOUNT THAT WAS OPENED ON
JUNE 18, 1999 ON BEHALF OF A CALIFORNIA CLIENT. ON OCTOBER 18, 2000 THE FIRM WAS NOTIFIED THAT THE CLIENT HAS RELOCATED TO IDAHO.
FOLLOWING THE CLIENT'S MOVE TO IDAHO, THE FIRM EXECUTED TWO "BUY" ORDER ON BEHALF OF THE CLIENT ON OCTOBER 27, 2000 AND ON
NOVEMBER 6, 2000 RESPECTIVELY.
regulatory · block 4PDF pages 27–29
Regulator name — filed text
MASSACHUSETTS SECURITIES DIVISION
Monetary/Fine Amount — filed text
$ 6,650.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

CONSENT ORDER APPROVING REGISTRATION UPON CONDITIONS WAS ENTERED AUGUST 26, 1999. ACTION STATUS IS FINAL.
Other filed details

Description of allegations — filed text

FIRST DALLAS SECURITIES, INC. HAD ENGAGED IN SECURITIES TRANSACTIONS IN MASSACHUSETTS AT TIMES WHEN IT WAS NOT REGISTERED AS A BROKER-DEALER IN MASSACHUSETTS.

Sanction detail — filed text

FINE OF $6500.00 WAS PAID ON AUGUST 26, 1999.
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:
Other
Other Sanctions: 
ADMINISTRATIVE FINE AND CONDITIONS
3.
Date Initiated (MM/DD/YYYY): 
08/26/1999
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-99-34
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FIRST DALLAS SECURITIES, INC. HAD ENGAGED IN SECURITIES TRANSACTIONS IN MASSACHUSETTS AT TIMES WHEN IT WAS NOT REGISTERED AS A
BROKER-DEALER IN MASSACHUSETTS.
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:
Consent
11. Resolution Date (MM/DD/YYYY):
08/26/1999
 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: $ 6,650.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
1)NOTIFY EACH MA CUSTOMER THAT ACTIVITY OCCURRED IN THEIR ACCOUNTS WHEN THE FIRM WAS NOT REGISTERED AS A BROKER-DEALER IN
MA 2) AMEND ITS COMPLIANCE MANUAL TO UPGRADE THE PROVISIONS OF ITS WRITTEN PROCEDURES DESIGNED TO PREVENT AND DETECT
VIOLATIONS OF THE REGISTRATION PROVISIONS OF THE ACT. 3)MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES TO ENSURE
COMPLIANCE WITH THE REGISTRATION PROVISIONS OF THE ACT. 4) PAY AN ADMINISTRATIVE FINE OF $6500 5) COMPLY WITH THE PROVISIONS
OF THE ACT.
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 OF $6500.00 WAS PAID ON AUGUST 26, 1999.
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).
CONSENT ORDER APPROVING REGISTRATION UPON CONDITIONS WAS ENTERED AUGUST 26, 1999. ACTION STATUS IS FINAL.
regulatory · block 5PDF pages 29–30
Regulator name — filed text
FINRA-FINANCIAL INDUSTRY REGULATORY AUTHORITY
Monetary/Fine Amount — filed text
$ 50,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

FDS RESEARCH REPORTS FOCUSED ON RECENT FINANCIAL PERFORMANCE OF SUBJECT COMPANIES AND HAD LIMITED DISTRIBUTION TO A SMALL NUMBER OF PRIVATE SUBSCRIBERS, MOST OF WHICH WERE INSTITUTIONAL INVESTORS. THIS LIMITED DISTRIBUTION WOULD NOT HAVE A MATERIAL IMPACT ON THE STOCK PRICE OF THE SUBJECT COMPANIES. FDS DOES NOT AND DID NOT PARTIFICPATE IN ANY INVESTMENT BANKING SERVICES, MARKET MAKING OR PROPRIETARY TRADING. NEGATING THE PROSPECT FOR THE POTENTIAL CONFLICTS OF INTEREST THAT COULD ARISE FROM THESE ACTIVITIES. FDS HAS DISCONTINUED THE PUBLISING OF RESEARCH REPORTS AS OF JUNE 2007. THE REMAINING CONCERNS HAVE BEEN ADDRESSED BY FDS IN CHANGES THE FIRM HAS MADE IN ITS COMPLIANCE DEPARTMENT TO ADDRESS ALL APPLICABLE RULES AND REGULATIONS.
Other filed details

Description of allegations — filed text

FINRA ALLEGED FIRST DALLAS SECURITIES, INC. VIOLATED NASD CONDUCT RULES 2110, 1120(B), 2711(C)(2)(A), 2711 (G)(2), 2711(G)(3), 2711(H)(1) (A), 2711(H)(1)(B), 2711(H)(7), 2711 (H)(10), 2711(I) AND 3010. THESE RULES ARE IN RELATION TO RESEARCH REPORTS ISSUED, ALLOWING AGENTS TO TRADE DURING THE PROHIBITED TIME FRAME, FAILURE TO PROVIDE A 2711 ATTESTATION FOR 2007, DEVELOP & IMPLEMENT WSP'S FOR WATCH LISTS OR RESTRICTION LISTS, AND FAILURE TO DEVELOPE A WRITTEN CE PLAN FOR 2006 AND 2007.

Sanction detail — filed text

FIRST DALLAS SECURITIES, INC WAS ISSUED A FINE OF $50,000.00
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-FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Censure

Other Sanctions: 
MONETARY FINE
3.
Date Initiated (MM/DD/YYYY): 
10/31/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2007007161501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
RESEARCH REPORTS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED FIRST DALLAS SECURITIES, INC. VIOLATED NASD CONDUCT RULES 2110, 1120(B), 2711(C)(2)(A), 2711 (G)(2), 2711(G)(3), 2711(H)(1)
(A), 2711(H)(1)(B), 2711(H)(7), 2711 (H)(10), 2711(I) AND 3010. THESE RULES ARE IN RELATION TO RESEARCH REPORTS ISSUED, ALLOWING AGENTS
TO TRADE DURING THE PROHIBITED TIME FRAME, FAILURE TO PROVIDE A 2711 ATTESTATION FOR 2007, DEVELOP & IMPLEMENT WSP'S FOR WATCH
LISTS OR RESTRICTION LISTS, AND FAILURE TO DEVELOPE A WRITTEN CE PLAN FOR 2006 AND 2007.
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):
11/11/2008
 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: $ 50,000.00
 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: 
FIRST DALLAS SECURITIES, INC WAS ISSUED A FINE OF $50,000.00
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).
FDS RESEARCH REPORTS FOCUSED ON RECENT FINANCIAL PERFORMANCE OF SUBJECT COMPANIES AND HAD LIMITED DISTRIBUTION TO A SMALL
NUMBER OF PRIVATE SUBSCRIBERS, MOST OF WHICH WERE INSTITUTIONAL INVESTORS. THIS LIMITED DISTRIBUTION WOULD NOT HAVE A MATERIAL
IMPACT ON THE STOCK PRICE OF THE SUBJECT COMPANIES. FDS DOES NOT AND DID NOT PARTIFICPATE IN ANY INVESTMENT BANKING SERVICES,
MARKET MAKING OR PROPRIETARY TRADING. NEGATING THE PROSPECT FOR THE POTENTIAL CONFLICTS OF INTEREST THAT COULD ARISE FROM THESE
ACTIVITIES. FDS HAS DISCONTINUED THE PUBLISING OF RESEARCH REPORTS AS OF JUNE 2007. THE REMAINING CONCERNS HAVE BEEN ADDRESSED
BY FDS IN CHANGES THE FIRM HAS MADE IN ITS COMPLIANCE DEPARTMENT TO ADDRESS ALL APPLICABLE RULES AND REGULATIONS.
regulatory · block 6PDF pages 30–32
Regulator name — filed text
FINRA-FINANCIAL INDUSTRY REGULATORY AUTHORITY
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)
Other filed details

Description of allegations — filed text

FINRA RULE 2010, NASD RULES 1017(A)(4), 2110: THE FIRM FAILED TO FILE FOR APPROVAL BY FINRA OF A MATERIAL CHANGE IN OWNERSHIP OR CONTROL, RELATED TO THE TRANSFER OF OWNERSHIP FROM THE FIRM'S CHAIRMAN AND MAJORITY SHAREHOLDER AND EXECUTIVES TO HIS RELATIVES WHO WERE AT THAT TIME MINORITY SHAREHOLDERS, AT LEAST 30 DAYS PRIOR TO A 25% OR GREATER INDIRECT CHANGE IN OWNERSHIP OR CONTROL. THE FIRM IMPLEMENTED A SUCCESSION PLAN THAT RESULTED IN THE TRANSFER OF OWNERSHIP FROM THE FIRM'S CHAIRMAN AND MAJORITY SHAREHOLDER TO HIS RELATIVES WHO WERE AT THAT TIME MINORITY SHAREHOLDERS AND THE TRANSFER REPRESENTED 27.91% OF THE VOTING SHARES IN THE FIRM'S HOLDING COMPANY. THE FIRM FAILED TO FILE FOR APPROVAL BY FINRA OF A MATERIAL CHANGE IN OWNERSHIP OR CONTROL RELATED TO THE TRANSFER UNTIL OVER FOUR YEARS AFTER THE TRANSFER HAD TAKEN PLACE.

Sanction detail — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, THEREFORE THE FIRM IS CENSURED AND FINED $10,000. THE FIRM HAS FILED THE MATERIAL CHANGE IN OWNERSHIP AND HAS BEEN APPROVED BY FINRA AS OF JUNE 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) 
FINRA-FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/30/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009016267801

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):
FINRA RULE 2010, NASD RULES 1017(A)(4), 2110: THE FIRM FAILED TO FILE FOR APPROVAL BY FINRA OF A MATERIAL CHANGE IN OWNERSHIP OR
CONTROL, RELATED TO THE TRANSFER OF OWNERSHIP FROM THE FIRM'S CHAIRMAN AND MAJORITY SHAREHOLDER AND EXECUTIVES TO HIS RELATIVES
WHO WERE AT THAT TIME MINORITY SHAREHOLDERS, AT LEAST 30 DAYS PRIOR TO A 25% OR GREATER INDIRECT CHANGE IN OWNERSHIP OR
CONTROL. THE FIRM IMPLEMENTED A SUCCESSION PLAN THAT RESULTED IN THE TRANSFER OF OWNERSHIP FROM THE FIRM'S CHAIRMAN AND
MAJORITY SHAREHOLDER TO HIS RELATIVES WHO WERE AT THAT TIME MINORITY SHAREHOLDERS AND THE TRANSFER REPRESENTED 27.91% OF THE
VOTING SHARES IN THE FIRM'S HOLDING COMPANY. THE FIRM FAILED TO FILE FOR APPROVAL BY FINRA OF A MATERIAL CHANGE IN OWNERSHIP OR
CONTROL RELATED TO THE TRANSFER UNTIL OVER FOUR YEARS AFTER THE TRANSFER HAD TAKEN PLACE.
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):
03/30/2011
 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: $ 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,
THEREFORE THE FIRM IS CENSURED AND FINED $10,000. THE FIRM HAS FILED THE MATERIAL CHANGE IN OWNERSHIP AND HAS BEEN APPROVED
BY FINRA AS OF JUNE 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 32–34
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 45,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

AS A RESULT OF THE FINDINGS THE FIRM NOW ONLY ASSESS A FLAT AND CONSISTENT FEE ON ALL OF THESE ADVISORY ACCOUNTS.
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT IMPROPERLY CHARGED TICKET CHARGES IN AT LEAST 449 TRANSACTIONS INVOLVING 129 ACCOUNTS FOR CLIENTS OF ITS AFFILIATED REGISTERED INVESTMENT ADVISOR (RIA). THE FINDINGS STATED THAT TRADES ON BEHALF OF THE CLIENTS WERE PLACED THROUGH THE FIRM'S TRADE PROCESSING PLATFORM, WHICH INCURRED TRANSACTION AND HANDLING FEES THAT WERE ASSESSED BY THE FIRM'S CLEARING FIRM. SOME OR ALL OF THESE FEES ARE PASSED ON BY THE FIRM TO CLIENTS IN THE FORM OF A TICKET CHARGE. IN SOME CASES, THE FIRM PERMITTED ITS REPRESENTATIVES (WHO ARE ALL DUALLY REGISTERED WITH THE RIA) TO DETERMINE THE AMOUNT OF THE TICKET CHARGE (IF ANY) THAT WOULD BE ASSESSED TO THEIR CLIENTS, THESE CHARGES WERE NOT UNIFORM. THE FIRM'S REPRESENTATIVES UTILIZED AT LEAST TWELVE DIFFERENT TICKET CHARGE STRUCTURES IN CONNECTION WITH TRADE PROCESSING, INCLUDING VARYING FLAT FEES, PER-SHARE FEES, AND HYBRID FEES. THESE FEES WERE DISCLOSED IN THE CUSTOMERS' ADVISORY AGREEMENTS WITH THE RIA. THE TOTAL AMOUNT OF OVERCHARGED TICKET CHARGES WAS $42,530, WHICH THE FIRM VOLUNTARILY REPAID TO THE AFFECTED CUSTOMERS WHEN THE CHARGES WERE DISCOVERED. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO HAVE AN ADEQUATE SUPERVISORY SYSTEM IN PLACE TO ENSURE THAT EACH CUSTOMER WAS CHARGED ONLY THE FEE THAT WAS DISCLOSED IN THAT CUSTOMER'S ADVISORY AGREEMENT. AS A RESULT, THE FIRM OFTEN ASSESSED A TICKET CHARGE THAT WAS DIFFERENT THAN THE DISCLOSED AMOUNT, AND IN MANY CASES, THIS FEE RESULTED IN THE CUSTOMER BEING CHARGED A FEE THAT EXCEEDED THE AGREED AMOUNT. THESE IMPROPER CHARGES ALSO WERE ASSESSED IN CONNECTION WITH THE PROCESSING OF BLOCK TRADES, WHICH MAY HAVE RESULTED IN THE ASSESSMENT OF A HIGHER PROCESSING FEE FOR BROKERAGE TRANSACTIONS.

Sanction detail — filed text

THE FIRM WAS CENSURED AND FINED $45,000.
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:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
03/14/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014039095801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
UNSPECIFIED SECURITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT IMPROPERLY
CHARGED TICKET CHARGES IN AT LEAST 449 TRANSACTIONS INVOLVING 129 ACCOUNTS FOR CLIENTS OF ITS AFFILIATED REGISTERED INVESTMENT
ADVISOR (RIA). THE FINDINGS STATED THAT TRADES ON BEHALF OF THE CLIENTS WERE PLACED THROUGH THE FIRM'S TRADE PROCESSING PLATFORM,
WHICH INCURRED TRANSACTION AND HANDLING FEES THAT WERE ASSESSED BY THE FIRM'S CLEARING FIRM. SOME OR ALL OF THESE FEES ARE
PASSED ON BY THE FIRM TO CLIENTS IN THE FORM OF A TICKET CHARGE. IN SOME CASES, THE FIRM PERMITTED ITS REPRESENTATIVES (WHO ARE ALL

DUALLY REGISTERED WITH THE RIA) TO DETERMINE THE AMOUNT OF THE TICKET CHARGE (IF ANY) THAT WOULD BE ASSESSED TO THEIR CLIENTS,
THESE CHARGES WERE NOT UNIFORM. THE FIRM'S REPRESENTATIVES UTILIZED AT LEAST TWELVE DIFFERENT TICKET CHARGE STRUCTURES IN
CONNECTION WITH TRADE PROCESSING, INCLUDING VARYING FLAT FEES, PER-SHARE FEES, AND HYBRID FEES. THESE FEES WERE DISCLOSED IN THE
CUSTOMERS' ADVISORY AGREEMENTS WITH THE RIA. THE TOTAL AMOUNT OF OVERCHARGED TICKET CHARGES WAS $42,530, WHICH THE FIRM
VOLUNTARILY REPAID TO THE AFFECTED CUSTOMERS WHEN THE CHARGES WERE DISCOVERED. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED
TO HAVE AN ADEQUATE SUPERVISORY SYSTEM IN PLACE TO ENSURE THAT EACH CUSTOMER WAS CHARGED ONLY THE FEE THAT WAS DISCLOSED IN
THAT CUSTOMER'S ADVISORY AGREEMENT. AS A RESULT, THE FIRM OFTEN ASSESSED A TICKET CHARGE THAT WAS DIFFERENT THAN THE DISCLOSED
AMOUNT, AND IN MANY CASES, THIS FEE RESULTED IN THE CUSTOMER BEING CHARGED A FEE THAT EXCEEDED THE AGREED AMOUNT. THESE
IMPROPER CHARGES ALSO WERE ASSESSED IN CONNECTION WITH THE PROCESSING OF BLOCK TRADES, WHICH MAY HAVE RESULTED IN THE
ASSESSMENT OF A HIGHER PROCESSING FEE FOR BROKERAGE TRANSACTIONS.
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):
03/14/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 45,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED AND FINED $45,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
AS A RESULT OF THE FINDINGS THE FIRM NOW ONLY ASSESS A FLAT AND CONSISTENT FEE ON ALL OF THESE ADVISORY ACCOUNTS.

* 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.