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 Gladstone Wealth Partners
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 Gladstone Wealth Partners.
Reported ownership and control details
Form ADV · Filing date 2026-09-24 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | INTEGRITY WEALTH, LLC.MEMBERDomestic entity | GLADSTONE WEALTH PARTNERS | 75% or moreCode E | Yes | MEMBER06/2024 | Schedule APDF page 64 |
| 2 | KRISTOPHER BONOCOREPRESIDENTIndividual | GLADSTONE WEALTH PARTNERS | Less than 5%Code NA | Yes | PRESIDENT01/2021 | Schedule APDF page 64 |
| 3 | JAMES HERLEINCHIEF FINANCIAL OFFICERIndividual | GLADSTONE WEALTH PARTNERS | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER12/2021 | Schedule APDF page 64 |
| 4 | EVAN LASSE BALDWINCHIEF COMPLIANCE OFFICERIndividual | GLADSTONE WEALTH PARTNERS | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER03/2025 | Schedule APDF page 64 |
| 5 | Jennifer Lynn HOFFMANCHIEF OPERATING OFFICERIndividual | GLADSTONE WEALTH PARTNERS | Less than 5%Code NA | Yes | CHIEF OPERATING OFFICER03/2025 | Schedule APDF page 64 |
| 6 | ANDREW ALLEN OSBYCHIEF INVESTMENT OFFICERIndividual | GLADSTONE WEALTH PARTNERS | Less than 5%Code NA | Yes | CHIEF INVESTMENT OFFICER09/2025 | Schedule APDF page 64 |
| 7 | INTEGRITY MARKETING PARTNERS, LLC.INDIRECT OWNERDomestic entity | INTEGRITY WEALTH, LLC. | 75% or moreCode E | Yes | INDIRECT OWNER06/2024 | Schedule BPDF page 65 |
| 8 | INTEGRITY MARKETING ACQUISITION, LLC.INDIRECT OWNERDomestic entity | INTEGRITY MARKETING PARTNERS, LLC. | 75% or moreCode E | Yes | INDIRECT OWNER10/2022 | Schedule BPDF page 65 |
| 9 | INTEGRITY MARKETING INTERMEDIATE, LLC.INDIRECT OWNERDomestic entity | INTEGRITY MARKETING ACQUISITION, LLC. | 75% or moreCode E | Yes | INDIRECT OWNER10/2022 | Schedule BPDF page 65 |
| 10 | INTEGRITY MARKETING PARENT, LLC.INDIRECT OWNERDomestic entity | INTEGRITY MARKETING INTERMEDIATE, LLC. | 75% or moreCode E | Yes | INDIRECT OWNER10/2022 | Schedule BPDF page 65 |
| 11 | INTEGRITY, LLC.INDIRECT OWNERDomestic entity | INTEGRITY MARKETING PARENT, LLC. | 75% or moreCode E | Yes | INDIRECT OWNER10/2022 | Schedule BPDF page 65 |
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 9/24/2026 2:50:51 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 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 actions5 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?No
- 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 actions2 Yes2 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?Yes
FProfessional authorizations1 Yes
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?Yes
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 1TIRANA, ALTINPDF pages 65–67
- Advisory affiliate name — filed text
- TIRANA, ALTIN
- Regulator name — filed text
- MARYLAND
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
MARYLAND CENSURED TIRANA BASED ON FINRA SUSPENSION/TIRANA'S AWC.
Other filed details
Description of allegations — filed text
TIRANA'S WAS SUSPENDED AFTER HE ENTERED INTO AN AWC WITH FINRA WITHOUT ADMITTING OR DENYING THE FINDINGS THE VIOLATED THE SECURITIES ACT. HE WAS SUSPENDED BY FINRA IN ALL CAPACITIES FOR A PERIOD OF 3 MONTHS AND AGREED TO PAY A FINE IN THE AMOUNT OF $5,000.
Sanction detail — filed text
THREE MONTH SUSPENSION BY FINRA; START DATE 2/21/2023 - END DATE 5/20/2023
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: 4837498 This advisory affiliate is a Firm an Individual Registered: Yes No Name: TIRANA, ALTIN (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) MARYLAND 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/10/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: BD20230059 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MORGAN STANLEY 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): TIRANA'S WAS SUSPENDED AFTER HE ENTERED INTO AN AWC WITH FINRA WITHOUT ADMITTING OR DENYING THE FINDINGS THE VIOLATED THE SECURITIES ACT. HE WAS SUSPENDED BY FINRA IN ALL CAPACITIES FOR A PERIOD OF 3 MONTHS AND AGREED TO PAY A FINE IN THE AMOUNT OF $5,000. 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): 03/30/2023 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: $ 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: THREE MONTH SUSPENSION BY FINRA; START DATE 2/21/2023 - END DATE 5/20/2023 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). MARYLAND CENSURED TIRANA BASED ON FINRA SUSPENSION/TIRANA'S AWC.
regulatory · block 2TIRANA, ALTINPDF pages 67–69
- Advisory affiliate name — filed text
- TIRANA, ALTIN
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
TIRANA SUSPENDED IN ALL CAPACITIES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, TIRANA CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE FALSIFIED THE REPRESENTATIVE CODE FOR TRADES IN HIS MEMBER FIRM'S ORDER ENTRY SYSTEM, CAUSING THE FIRM'S TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE AND AS A RESULT, HE CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS. THE FINDINGS STATED THAT TIRANA ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH A RETIRED REPRESENTATIVE. ALTHOUGH THE FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT REPRESENTATIVE CODE, TIRANA ENTERED THE TRANSACTIONS UNDER HIS PERSONAL REPRESENTATIVE CODE THROUGH WHICH HE RECEIVED A HIGHER PERCENTAGE OF COMMISSIONS THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. TIRANA MISTAKENLY BELIEVED THE REPRESENTATIVE HAD AGREED THAT HE COULD CHANGE THE REPRESENTATIVE CODE SO THAT TIRANA WOULD RECEIVE HIGHER PERCENTAGES OF COMMISSIONS IN ORDER TO INCREASE COMPENSATION HE PAID TO SUPPORT STAFF SERVICING THE CUSTOMER ACCOUNTS SUBJECT TO THE AGREEMENT. HOWEVER, TIRANA NEGLIGENTLY FAILED TO VERIFY WHETHER THE REPRESENTATIVE HAD AGREED THAT HE COULD CHANGE THE REPRESENTATIVE CODE IN THIS MANNER. THE FIRM PAID RESTITUTION OF APPROXIMATELY $24,000 TO THE REPRESENTATIVE, WHICH IS THE APPROXIMATE AMOUNT OF ADDITIONAL COMMISSIONS TIRANA RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES.
Sanction detail — filed text
SUSPENSION IN ALL CAPACITIES; STARTED 2/21/2023 - END DATE 5/20/2023
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: 4837498 This advisory affiliate is a Firm an Individual Registered: Yes No Name: TIRANA, ALTIN (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) FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: SUSPENSION 3. Date Initiated (MM/DD/YYYY): 07/10/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2020067608101 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MORGAN STANLEY 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, TIRANA CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE FALSIFIED THE REPRESENTATIVE CODE FOR TRADES IN HIS MEMBER FIRM'S ORDER ENTRY SYSTEM, CAUSING THE FIRM'S TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE AND AS A RESULT, HE CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS. THE FINDINGS STATED THAT TIRANA ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH A RETIRED REPRESENTATIVE. ALTHOUGH THE FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE JOINT REPRESENTATIVE CODE, TIRANA ENTERED THE TRANSACTIONS UNDER HIS PERSONAL REPRESENTATIVE CODE THROUGH WHICH HE RECEIVED A HIGHER PERCENTAGE OF COMMISSIONS THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. TIRANA MISTAKENLY BELIEVED THE REPRESENTATIVE HAD AGREED THAT HE COULD CHANGE THE REPRESENTATIVE CODE SO THAT TIRANA WOULD RECEIVE HIGHER PERCENTAGES OF COMMISSIONS IN ORDER TO INCREASE COMPENSATION HE PAID TO SUPPORT STAFF SERVICING THE CUSTOMER ACCOUNTS SUBJECT TO THE AGREEMENT. HOWEVER, TIRANA NEGLIGENTLY FAILED TO VERIFY WHETHER THE REPRESENTATIVE HAD AGREED THAT HE COULD CHANGE THE REPRESENTATIVE CODE IN THIS MANNER. THE FIRM PAID RESTITUTION OF APPROXIMATELY $24,000 TO THE REPRESENTATIVE, WHICH IS THE APPROXIMATE AMOUNT OF ADDITIONAL COMMISSIONS TIRANA RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON THE TRADES. 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): 01/23/2023 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: $ 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: SUSPENSION IN ALL CAPACITIES; STARTED 2/21/2023 - END DATE 5/20/2023 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). TIRANA SUSPENDED IN ALL CAPACITIES.
regulatory · block 3BRETTLER, STEVEN, GPDF pages 69–71
- Advisory affiliate name — filed text
- BRETTLER, STEVEN, G
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
BRETTLER SUSPENDED IN ALL CAPACITIES.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, BRETTLER CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN THE FIRM'S ORDER ENTRY SYSTEM, CAUSING THE FIRM'S TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT BRETTLER ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A RETIRED REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS BRETTLER AND THE ESTATE OF THE RETIRED REPRESENTATIVE EARNED ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. ALTHOUGH THE FIRM'S SYSTEM PREPOPULATED THE TRADES WITH A JOINT REPRESENTATIVE CODE BRETTLER SHARED WITH THE ESTATE OF THE RETIRED REPRESENTATIVE, BRETTLER ENTERED THE TRANSACTIONS UNDER HIS PERSONAL REPRESENTATIVE CODE. BRETTLER FAILED TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. IN ADDITION, BRETTLER DID NOT ASK THE ESTATE OF THE RETIRED REPRESENTATIVE WHETHER HE COULD CHANGE THE CODE ON THE TRADES AT ISSUE. AS A RESULT, THE FIRM'S TRADE CONFIRMATIONS INACCURATELY REFLECTED BRETTLER'S PERSONAL REPRESENTATIVE CODE INSTEAD OF THE JOINT REPRESENTATIVE CODE THAT BRETTLER SHARED WITH THE ESTATE OF THE RETIRED REPRESENTATIVE. BRETTLER'S ACTIONS RESULTED IN HIS RECEIVING HIGHER COMMISSIONS FROM THE TRADES THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. THE FIRM HAS SINCE PAID RESTITUTION TO THE ESTATE OF THE RETIRED REPRESENTATIVE. BRETTLER REIMBURSED THE FIRM A TOTAL OF APPROXIMATELY $76,577, WHICH IS THE APPROXIMATE AMOUNT OF ADDITIONAL COMMISSIONS THAT BRETTLER RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON TRADES.
Sanction detail — filed text
THREE MONTH SUSPENSION IN ALL CAPACITIES; START DATE 2/21/2023 - END DATE 5/20/2023
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: 4367351 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BRETTLER, STEVEN, G (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) FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: SUSPENSION 3. Date Initiated (MM/DD/YYYY): 11/10/2020 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2020068689201 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MORGAN STANLEY 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, BRETTLER CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY FALSIFYING THE REPRESENTATIVE CODE FOR TRADES IN THE FIRM'S ORDER ENTRY SYSTEM, CAUSING THE FIRM'S TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT BRETTLER ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A RETIRED REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS BRETTLER AND THE ESTATE OF THE RETIRED REPRESENTATIVE EARNED ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. ALTHOUGH THE FIRM'S SYSTEM PREPOPULATED THE TRADES WITH A JOINT REPRESENTATIVE CODE BRETTLER SHARED WITH THE ESTATE OF THE RETIRED REPRESENTATIVE, BRETTLER ENTERED THE TRANSACTIONS UNDER HIS PERSONAL REPRESENTATIVE CODE. BRETTLER FAILED TO VERIFY WHETHER THE TRANSACTIONS AT ISSUE WERE SUBJECT TO THE JOINT PRODUCTION AGREEMENT. IN ADDITION, BRETTLER DID NOT ASK THE ESTATE OF THE RETIRED REPRESENTATIVE WHETHER HE COULD CHANGE THE CODE ON THE TRADES AT ISSUE. AS A RESULT, THE FIRM'S TRADE CONFIRMATIONS INACCURATELY REFLECTED BRETTLER'S PERSONAL REPRESENTATIVE CODE INSTEAD OF THE JOINT REPRESENTATIVE CODE THAT BRETTLER SHARED WITH THE ESTATE OF THE RETIRED REPRESENTATIVE. BRETTLER'S ACTIONS RESULTED IN HIS RECEIVING HIGHER COMMISSIONS FROM THE TRADES THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. THE FIRM HAS SINCE PAID RESTITUTION TO THE ESTATE OF THE RETIRED REPRESENTATIVE. BRETTLER REIMBURSED THE FIRM A TOTAL OF APPROXIMATELY $76,577, WHICH IS THE APPROXIMATE AMOUNT OF ADDITIONAL COMMISSIONS THAT BRETTLER RECEIVED AS A RESULT OF CHANGING THE REPRESENTATIVE CODE ON TRADES. 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): 01/31/2023 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: $ 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: THREE MONTH SUSPENSION IN ALL CAPACITIES; START DATE 2/21/2023 - END DATE 5/20/2023 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). BRETTLER SUSPENDED IN ALL CAPACITIES.
regulatory · block 4WILINSKI, BRYCE, SCOTTPDF pages 71–73
- Advisory affiliate name — filed text
- WILINSKI, BRYCE, SCOTT
- Regulator name — filed text
- FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
- Monetary/Fine Amount — filed text
- $ 352,815.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
AFTER CONSIDERING THE PLEADINGS, THE TESTIMONY AND EVIDENCE PRESENTED AT THE HEARING, AND RESPONDENT'S POST-HEARING SUBMISSION, THE PANEL HAS DECIDED IN FULL AND FINAL RESOLUTION OF THE ISSUES SUBMITTED FOR DETERMINATION AS FOLLOWS: 1. RESPONDENT IS LIABLE FOR AND SHALL PAY TO CLAIMANTS COMPENSATORY DAMAGES IN THE AMOUNT OF $352,815.00. 2. CLAIMANTS' REQUEST FOR ATTORNEYS' FEES IS DENIED. 3. RESPONDENT'S REQUEST FOR EXPUNGEMENT OF THE CRD RECORDS OF UNNAMED PARTY BRYCE WILINSKI IS DENIED. 4. ANY AND ALL RELIEF NOT SPECIFICALLY ADDRESSED HEREIN, INCLUDING PUNITIVE AND CONSEQUENTIAL DAMAGES IS DENIED.
Other filed details
Description of allegations — filed text
MATERIALITY OF OMISSIONS AND MISREPRESENTATIONS; BREACH OF FIDUCIARY DUTY; UNSUITABILITY; VIOLATION OF FINRA'S CONDUCT RULES; AND SECONDARY LIABILITY.
Sanction detail — filed text
AFTER CONSIDERING THE PLEADINGS, THE TESTIMONY AND EVIDENCE PRESENTED AT THE HEARING, AND RESPONDENT'S POST-HEARING SUBMISSION, THE PANEL HAS DECIDED IN FULL AND FINAL RESOLUTION OF THE ISSUES SUBMITTED FOR DETERMINATION AS FOLLOWS: 1. RESPONDENT IS LIABLE FOR AND SHALL PAY TO CLAIMANTS COMPENSATORY DAMAGES IN THE AMOUNT OF $352,815.00. 2. CLAIMANTS' REQUEST FOR ATTORNEYS' FEES IS DENIED. 3. RESPONDENT'S REQUEST FOR EXPUNGEMENT OF THE CRD RECORDS OF UNNAMED PARTY BRYCE WILINSKI IS DENIED. 4. ANY AND ALL RELIEF NOT SPECIFICALLY ADDRESSED HEREIN, INCLUDING PUNITIVE AND CONSEQUENTIAL DAMAGES IS DENIED.
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: 4900714 This advisory affiliate is a Firm an Individual Registered: Yes No Name: WILINSKI, BRYCE, SCOTT (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) FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA) 2. Principal Sanction: Other Other Sanctions: ARBITRATION AWARD 3. Date Initiated (MM/DD/YYYY): 05/27/2014 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 14-01662 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MERRILL LYNCH, PIERCE, FENNER & SMITH INC. 6. Principal Product Type: Debt - Municipal Other Product Types: MUTUAL FUNDS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): MATERIALITY OF OMISSIONS AND MISREPRESENTATIONS; BREACH OF FIDUCIARY DUTY; UNSUITABILITY; VIOLATION OF FINRA'S CONDUCT RULES; AND SECONDARY LIABILITY. 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): 06/16/2016 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: $ 352,815.00 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: AFTER CONSIDERING THE PLEADINGS, THE TESTIMONY AND EVIDENCE PRESENTED AT THE HEARING, AND RESPONDENT'S POST-HEARING SUBMISSION, THE PANEL HAS DECIDED IN FULL AND FINAL RESOLUTION OF THE ISSUES SUBMITTED FOR DETERMINATION AS FOLLOWS: 1. RESPONDENT IS LIABLE FOR AND SHALL PAY TO CLAIMANTS COMPENSATORY DAMAGES IN THE AMOUNT OF $352,815.00. 2. CLAIMANTS' REQUEST FOR ATTORNEYS' FEES IS DENIED. 3. RESPONDENT'S REQUEST FOR EXPUNGEMENT OF THE CRD RECORDS OF UNNAMED PARTY BRYCE WILINSKI IS DENIED. 4. ANY AND ALL RELIEF NOT SPECIFICALLY ADDRESSED HEREIN, INCLUDING PUNITIVE AND CONSEQUENTIAL DAMAGES IS DENIED. 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). AFTER CONSIDERING THE PLEADINGS, THE TESTIMONY AND EVIDENCE PRESENTED AT THE HEARING, AND RESPONDENT'S POST-HEARING SUBMISSION, THE PANEL HAS DECIDED IN FULL AND FINAL RESOLUTION OF THE ISSUES SUBMITTED FOR DETERMINATION AS FOLLOWS: 1. RESPONDENT IS LIABLE FOR AND SHALL PAY TO CLAIMANTS COMPENSATORY DAMAGES IN THE AMOUNT OF $352,815.00. 2. CLAIMANTS' REQUEST FOR ATTORNEYS' FEES IS DENIED. 3. RESPONDENT'S REQUEST FOR EXPUNGEMENT OF THE CRD RECORDS OF UNNAMED PARTY BRYCE WILINSKI IS DENIED. 4. ANY AND ALL RELIEF NOT SPECIFICALLY ADDRESSED HEREIN, INCLUDING PUNITIVE AND CONSEQUENTIAL DAMAGES IS DENIED.
regulatory · block 5NEILL, MICHAEL, ROBERTPDF pages 73–75
- Advisory affiliate name — filed text
- NEILL, MICHAEL, ROBERT
- Regulator name — filed text
- FINRA (FINANCIAL INDUSTRY REGULATORY AUTHORITY)
- Monetary/Fine Amount — filed text
- $ 5,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
NEILL SUSPENDED IN ALL CAPACITIES
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, NEILL CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY CHANGING THE REPRESENTATIVE CODE FOR TRADES, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT NEILL ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A RETIRED REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS THE ESTATE OF THE RETIRED REPRESENTATIVE AND NEILL WOULD EARN ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. NEILL PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING HIS OWN PERSONAL REPRESENTATIVE CODE. ALTHOUGH THE FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE APPLICABLE JOINT REPRESENTATIVE CODE, NEILL CHANGED THE CODE FOR THE TRADES TO HIS PERSONAL REPRESENTATIVE CODE. NEILL DID SO BECAUSE HE MISTAKENLY BELIEVED THAT HIS AGREEMENT WITH THE ESTATE OF THE RETIRED REPRESENTATIVE DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE THEREFORE WAS AUTHORIZED TO ENTER THE TRADES USING HIS PERSONAL REPRESENTATIVE CODE. THE FIRM'S TRADE CONFIRMATIONS FOR THE TRADES INACCURATELY REFLECTED NEILL'S PERSONAL REPRESENTATIVE CODE. NEILL'S ACTIONS RESULTED IN HIS RECEIVING HIGHER COMMISSIONS FROM THE TRADES THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. SUBSEQUENTLY, THE FIRM REIMBURSED THE ESTATE OF THE RETIRED REPRESENTATIVE.
Sanction detail — filed text
SUSPENSION IN ALL CAPACITIES; STARTED 6/5/2023 - END DATE 7/4/2023
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: 4700490 This advisory affiliate is a Firm an Individual Registered: Yes No Name: NEILL, MICHAEL, ROBERT (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) FINRA (FINANCIAL INDUSTRY REGULATORY AUTHORITY) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: SUSPENSION 3. Date Initiated (MM/DD/YYYY): 04/21/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2021071288701 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MORGAN STANLEY 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): WITHOUT ADMITTING OR DENYING THE FINDINGS, NEILL CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE CAUSED HIS MEMBER FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS BY CHANGING THE REPRESENTATIVE CODE FOR TRADES, CAUSING THE TRADE CONFIRMATIONS TO SHOW AN INACCURATE REPRESENTATIVE CODE. THE FINDINGS STATED THAT NEILL ENTERED INTO AN AGREEMENT THROUGH WHICH HE AGREED TO SERVICE CERTAIN CUSTOMER ACCOUNTS, INCLUDING EXECUTING TRADES FOR THOSE ACCOUNTS, UNDER A JOINT REPRESENTATIVE CODE THAT HE SHARED WITH THE ESTATE OF A RETIRED REPRESENTATIVE. THE AGREEMENT SET FORTH WHAT PERCENTAGES OF THE COMMISSIONS THE ESTATE OF THE RETIRED REPRESENTATIVE AND NEILL WOULD EARN ON TRADES PLACED USING THE JOINT REPRESENTATIVE CODE. NEILL PLACED TRADES IN ACCOUNTS THAT WERE COVERED BY THE AGREEMENT USING HIS OWN PERSONAL REPRESENTATIVE CODE. ALTHOUGH THE FIRM'S SYSTEM CORRECTLY PREPOPULATED THE TRADES WITH THE APPLICABLE JOINT REPRESENTATIVE CODE, NEILL CHANGED THE CODE FOR THE TRADES TO HIS PERSONAL REPRESENTATIVE CODE. NEILL DID SO BECAUSE HE MISTAKENLY BELIEVED THAT HIS AGREEMENT WITH THE ESTATE OF THE RETIRED REPRESENTATIVE DID NOT APPLY TO NEW ASSETS ADDED TO ACCOUNTS SUBJECT TO THE AGREEMENT AND THAT HE THEREFORE WAS AUTHORIZED TO ENTER THE TRADES USING HIS PERSONAL REPRESENTATIVE CODE. THE FIRM'S TRADE CONFIRMATIONS FOR THE TRADES INACCURATELY REFLECTED NEILL'S PERSONAL REPRESENTATIVE CODE. NEILL'S ACTIONS RESULTED IN HIS RECEIVING HIGHER COMMISSIONS FROM THE TRADES THAN WHAT HE WAS ENTITLED TO RECEIVE PURSUANT TO THE AGREEMENT. SUBSEQUENTLY, THE FIRM REIMBURSED THE ESTATE OF THE RETIRED REPRESENTATIVE. 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): 05/09/2023 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: $ 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: SUSPENSION IN ALL CAPACITIES; STARTED 6/5/2023 - END DATE 7/4/2023 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). NEILL SUSPENDED IN ALL CAPACITIES
regulatory · block 6BRETTLER, STEVEN, GPDF pages 75–76
- Advisory affiliate name — filed text
- BRETTLER, STEVEN, G
- Regulator name — filed text
- INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA SUSPENDED BRETTLER IN HIS CAPACITY AS AN INSURANCE PRODUCER BASED ON FINRA SUSPENSION/BRETTLERS AWC.
Other filed details
Description of allegations — filed text
IN RESPONSE TO A FINRA SUSPENSION (DISCUSSED BELOW), THE CALIFORNIA DEPARTMENT OF INSURANCE SUSPENDED THE REGISTERED REP'S INSURANCE LICENSE FOR FOURTEEN DAYS FROM AUGUST 13, 2023 THROUGH AUGUST 25, 2023. ON JANUARY 31, 2023, IN CASE NO. 2020068689201, FINRA ACCEPTED REPRESENTATIVE'S AWC WHEREBY REPRESENTATIVE, WITHOUT ADMITTING OR DENYING THE AWC FINDINGS, CONSENTED TO THE IMPOSITION OF A THREE- MONTH SUSPENSION AND $5,000 FINE FOR VIOLATING FINRA RULES 4511 AND 2010.
Sanction detail — filed text
SUSPENDED AS INSURANCE PRODUCER FOR A PERIOD OF 14 DAYS. FROM 8/13/2023 - 8/26/2023.
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: 4367351 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BRETTLER, STEVEN, G (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) INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA 2. Principal Sanction: Suspension Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 06/07/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: OBS 4874-A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): GLADSTONE WEALTH PARTNERS 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): IN RESPONSE TO A FINRA SUSPENSION (DISCUSSED BELOW), THE CALIFORNIA DEPARTMENT OF INSURANCE SUSPENDED THE REGISTERED REP'S INSURANCE LICENSE FOR FOURTEEN DAYS FROM AUGUST 13, 2023 THROUGH AUGUST 25, 2023. ON JANUARY 31, 2023, IN CASE NO. 2020068689201, FINRA ACCEPTED REPRESENTATIVE'S AWC WHEREBY REPRESENTATIVE, WITHOUT ADMITTING OR DENYING THE AWC FINDINGS, CONSENTED TO THE IMPOSITION OF A THREE- MONTH SUSPENSION AND $5,000 FINE FOR VIOLATING FINRA RULES 4511 AND 2010. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Order 11. Resolution Date (MM/DD/YYYY): 06/07/2023 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: SUSPENDED 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: SUSPENDED AS INSURANCE PRODUCER FOR A PERIOD OF 14 DAYS. FROM 8/13/2023 - 8/26/2023. 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). INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA SUSPENDED BRETTLER IN HIS CAPACITY AS AN INSURANCE PRODUCER BASED ON FINRA SUSPENSION/BRETTLERS AWC.
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regulatory · block 7NEILL, MICHAEL, ROBERTPDF pages 77–78
- Advisory affiliate name — filed text
- NEILL, MICHAEL, ROBERT
- Regulator name — filed text
- DELAWARE INSURANCE DEPARTMENT
- Monetary/Fine Amount — filed text
- $ 500.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
NEILL PAID FINE IN FULL 9/25/2023
Other filed details
Description of allegations — filed text
RESPONDENT UNITENTIONALLY VIOLATED 18 DEL. C SECTION 1719 IN THAT HE DID NOT REPORT "AN ADMINISTRATIVE ACTION TAKEN BY ANOTHER JURISDICTION" TO THE DELAWARE INSURANCE COMMISSIONER.
Sanction detail — filed text
DELAWARE INSURANCE DEPARTMENT IMPOSED A MONETARY FINE OF $500 FOR NEILL FAILING TO DISCLOSE HIS FINRA SUSPENSION/AWC
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: 4700490 This advisory affiliate is a Firm an Individual Registered: Yes No Name: NEILL, MICHAEL, ROBERT (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) DELAWARE INSURANCE DEPARTMENT 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/28/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 5214-2023 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): GLADSTONE WEALTH PARTNERS 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): RESPONDENT UNITENTIONALLY VIOLATED 18 DEL. C SECTION 1719 IN THAT HE DID NOT REPORT "AN ADMINISTRATIVE ACTION TAKEN BY ANOTHER JURISDICTION" TO THE DELAWARE INSURANCE COMMISSIONER. 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): 09/28/2023 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: $ 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: DELAWARE INSURANCE DEPARTMENT IMPOSED A MONETARY FINE OF $500 FOR NEILL FAILING TO DISCLOSE HIS FINRA SUSPENSION/AWC 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). NEILL PAID FINE IN FULL 9/25/2023
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