Firm profile

Gladstone Wealth Partners

PALM BEACH GARDENS, FLCRD 250787Registration Status: ApprovedEffective since July 28, 2015SEC # 801-101532Latest ADV September 24, 2026

Gladstone Wealth Partners is an SEC registered investment adviser organized as a limited liability company with a primary office location in Palm Beach Gardens, FL. Its latest Form ADV filing, dated September 24, 2026, reports $5.7B in regulatory assets under management, 186 employees, 52 offices, and 18,794 accounts.

Assets Under Management
$5.7B
Employees
186
Offices
52 offices
Total Clients
8,385

Associated firm names

52 names listed
  • AFFINITY WEALTH MANAGEMENT GROUP
  • WHITE OAK WEALTH PARTNERS
  • WEALTH FORMAT SYSTEMS, LLC.
  • TRUE VISION FINANCIAL ADVISORS

Leadership

4 roles identified
CCOEvan L. Baldwin
CFOJames Herlein
COOJennifer L. Hoffman

Advisory services offered

5 types reported
Financial Planning Services
Other advisory services
Portfolio management for businesses

Fee models offered

2 types reported
Asset based fees
Fixed fees

Offices & Contact

Primary office

PALM BEACH GARDENS, Florida, 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.

Florida

PALM BEACH GARDENSPrimary office · NAPLES

California

CORONA · SAN DIEGO

Colorado

MONTROSE

Connecticut

WESTPORT

Georgia

STOCKBRIDGE

Illinois

SCHAUMBURG

Indiana

INDIANAPOLIS · GREENWOOD · BLOOMINGTON · COLUMBUS · EVANSVILLE

Iowa

CARROLL

Massachusetts

NEEDHAM

Nebraska

OMAHA

Nevada

LAS VEGAS

New Jersey

HACKETTSTOWN · BEDMINSTER · NEWARK · MEDFORD · PARAMUS · MORRISTOWN · RED BANK · MOUNT LAUREL · FLEMINGTON

New York

PURCHASE · WHITE PLAINS · MELVILLE · SOMERS

North Carolina

CHARLOTTE

Ohio

COLUMBUS

Pennsylvania

CRANBERRY · ERIE · BLUE BELL · DICKSON CITY · WARREN

Rhode Island

WARWICK

Texas

SOUTHLAKE · SAN ANGELO · DALLAS

45 office records listed · 52 total offices reported. 9 additional office addresses are undisclosed and are not mapped. 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$5.7Bas of September 24, 2026
Discretionary99.7%
$5.7B
100% of total RAUM99.7%
Non-discretionary0.3%
$16M
0% of total RAUM0.3%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 72.6% of total clients.
Top client categories% of clientsClients
1
Individuals
72.6%
6,089
2
HNWI
26.4%
2,213
3
Corporations
0.5%
41
4
Charitable
0.3%
26
5
Pension Plans
0.2%
14
Additional categories (<0.1%)
Investment Cos.<5 clients
Other Advisers<5 clients

Assets under management Growth by Quarter

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

Total AUM$5.7B
Total Accounts18,794
10Y AUM Change+$5.4B (+1877.0%)

Private Funds

Private funds reported by Gladstone Wealth Partners

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Employee Growth by Quarter

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

Total Employees186
Clients per Employee45:1
10Y Employee Change+156 (+520.0%)

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%
INTEGRITY WEALTH, LLC.Direct owner · Schedule AInterest in GLADSTONE WEALTH PARTNERS
75%+
INTEGRITY MARKETING PARTNERS, LLC.Indirect owner · Schedule BInterest in INTEGRITY WEALTH, LLC.
75%+
INTEGRITY MARKETING ACQUISITION, LLC.Indirect owner · Schedule BInterest in INTEGRITY MARKETING PARTNERS, LLC.
75%+
INTEGRITY MARKETING INTERMEDIATE, LLC.Indirect owner · Schedule BInterest in INTEGRITY MARKETING ACQUISITION, LLC.
75%+
INTEGRITY MARKETING PARENT, LLC.Indirect owner · Schedule BInterest in INTEGRITY MARKETING INTERMEDIATE, LLC.
75%+
INTEGRITY, LLC.Indirect owner · Schedule BInterest in INTEGRITY MARKETING PARENT, LLC.
75%+

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Gladstone Wealth Partners.

Reported ownership and control details

Form ADV · Filing date 2026-09-24 · Schedules A and B

11 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1INTEGRITY WEALTH, LLC.MEMBERDomestic entityGLADSTONE WEALTH PARTNERS75% or moreCode EYesMEMBER06/2024Schedule APDF page 64
2KRISTOPHER BONOCOREPRESIDENTIndividualGLADSTONE WEALTH PARTNERSLess than 5%Code NAYesPRESIDENT01/2021Schedule APDF page 64
3JAMES HERLEINCHIEF FINANCIAL OFFICERIndividualGLADSTONE WEALTH PARTNERSLess than 5%Code NAYesCHIEF FINANCIAL OFFICER12/2021Schedule APDF page 64
4EVAN LASSE BALDWINCHIEF COMPLIANCE OFFICERIndividualGLADSTONE WEALTH PARTNERSLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER03/2025Schedule APDF page 64
5Jennifer Lynn HOFFMANCHIEF OPERATING OFFICERIndividualGLADSTONE WEALTH PARTNERSLess than 5%Code NAYesCHIEF OPERATING OFFICER03/2025Schedule APDF page 64
6ANDREW ALLEN OSBYCHIEF INVESTMENT OFFICERIndividualGLADSTONE WEALTH PARTNERSLess than 5%Code NAYesCHIEF INVESTMENT OFFICER09/2025Schedule APDF page 64
7INTEGRITY MARKETING PARTNERS, LLC.INDIRECT OWNERDomestic entityINTEGRITY WEALTH, LLC.75% or moreCode EYesINDIRECT OWNER06/2024Schedule BPDF page 65
8INTEGRITY MARKETING ACQUISITION, LLC.INDIRECT OWNERDomestic entityINTEGRITY MARKETING PARTNERS, LLC.75% or moreCode EYesINDIRECT OWNER10/2022Schedule BPDF page 65
9INTEGRITY MARKETING INTERMEDIATE, LLC.INDIRECT OWNERDomestic entityINTEGRITY MARKETING ACQUISITION, LLC.75% or moreCode EYesINDIRECT OWNER10/2022Schedule BPDF page 65
10INTEGRITY MARKETING PARENT, LLC.INDIRECT OWNERDomestic entityINTEGRITY MARKETING INTERMEDIATE, LLC.75% or moreCode EYesINDIRECT OWNER10/2022Schedule BPDF page 65
11INTEGRITY, LLC.INDIRECT OWNERDomestic entityINTEGRITY MARKETING PARENT, LLC.75% or moreCode EYesINDIRECT OWNER10/2022Schedule 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.

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 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.
Show 1 more source blocks
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

* 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.