Greenbacker Capital Management LLC

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GREENBACKER RENEWABLE
ENERGY COMPANY LLC
(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) 
STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCIAL REGULATION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL PENALTY OF $4500
3.
Date Initiated (MM/DD/YYYY): 
09/17/2019
 Exact
 Explanation
If not exact, provide explanation:
ON OR ABOUT SEPTEMBER 17, 2019, THE ADVISER AND THE STATE OF OREGON BEGAN HAVING COMMUNICATION RELATED TO THE DRAFTING OF THE
CONSENT ORDER.
4.
Docket/Case Number:
S-19-0100
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCIAL REGULATION ALLEGES THAT GREENBACKER
RENEWABLE ENERGY COMPANY LLC ("GREC"), AN ADVISORY AFFILIATE OF THE ADVISER, VIOLATED OREGON SECURITIES LAWS BY DISTRIBUTING
SHARES PURSUANT TO A DISTRIBUTION REINVESTMENT PLAN WITHOUT AN ACTIVE ORDER OF REGISTRATION FOR A SHORT PERIOD OF TIME.
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):
03/24/2020
 Exact
 Explanation
If not exact, provide explanation:
GREC SIGNED THE CONSENT ORDER AND THE ADVISER PAID THE RELATED FINE ON MARCH 24, 2020 BUT IS AWAITING THE COUNTER SIGNATURE FROM
THE STATE OF OREGON.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 4,500.00
 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: 
THE DISPOSITION RESULTED IN A $4500 CIVIL PENALTY THAT WAS PAID BY THE ADVISER ON OR ABOUT MARCH 24, 2020.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OR ABOUT MARCH 24, 2020, GREENBACKER RENEWABLE ENERGY COMPANY LLC ("GREC"), AN ADVISORY AFFILIATE AND CLIENT OF ADVISER,
VOLUNTARILY ENTERED INTO A CEASE AND DESIST ORDER WITH THE STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES,
DIVISION OF FINANCIAL REGULATION (THE "OREGON DIVISION") NEITHER ADMITTING NOR DENYING LIABILITY. BY WAY OF BACKGROUND, GREC
COMMENCED AN INITIAL PUBLIC OFFERING (THE "IPO") OF SHARES ON AUGUST 7, 2013 WHICH TERMINATED APRIL 13, 2017 AND COMMENCED A
FOLLOW-ON OFFERING (TOGETHER WITH "IPO", THE "OFFERINGS") OF COMMON SHARES ON APRIL 14, 2017 WHICH TERMINATED MARCH 29, 2019.
BOTH OFFERINGS INCLUDED A SHARE DISTRIBUTION REINVESTMENT PLAN (THE "DRIP") WHEREBY, AT THE TIME OF THE ORIGINAL INVESTMENT IN
GREC SHARES, INVESTORS COULD ELECT TO HAVE DISTRIBUTIONS AUTOMATICALLY REINVESTED IN THE PURCHASE OF ADDITIONAL SHARES. THE
OREGON DIVISION ISSUED AN ORDER OF SECURITIES REGISTRATION FOR THE OFFERINGS THAT ULTIMATELY EXPIRED ON FEBRUARY 13, 2019. THE
SECURITIES AND EXCHANGE COMMISSION AND MANY STATES DO NOT TREAT THE ISSUANCE OF COMMON STOCK DRIP SHARES AS A SALE OF
SECURITIES REQUIRING AN ACTIVE REGISTRATION STATEMENT. THE STATE OF OREGON, HOWEVER, DOES. AS SUCH, THE DRIP SHARES DISTRIBUTED
TO OREGON INVESTORS BY GREC FROM FEBRUARY 13, 2019, TO AUGUST 6, 2019, WERE DEEMED BY THE OREGON DIVISION TO HAVE VIOLATED
OREGON SECURITIES LAW ("ORS") 59.055. GREC STRONGLY DISAGREES WITH THE OREGON DIVISION'S CHARACTERIZATION OF THE DISTRIBUTION OF
DRIP SHARES TO EXISTING OREGON INVESTORS AS A "SALE" UNDER THE ORS. HOWEVER, IN AN EFFORT TO SETTLE THE MATTER EFFICIENTLY, AND
WITHOUT ADMITTING OR DENYING THE DIVISION'S FINDING OF FACT OR CONCLUSIONS OF LAW, GREC VOLUNTARILY AGREED TO A FINAL
DETERMINATION OF THE MATTER WHEREIN THE DIVISION FOUND THAT GREC VIOLATED ORS 59.055 BY DISTRIBUTING ITS DRIP SHARES TO EXISTING
OREGON INVESTORS FOR A SHORT TIME PERIOD WITHOUT AN ACTIVE ORDER OF REGISTRATION. THE ADVISER PAID A RELATED $4,500 FEE.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GREENBACKER RENEWABLE
ENERGY COMPANY LLC
(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) 
STATE OF NEW HAMPSHIRE DEPARTMENT OF STATE BUREAU OF SECURITIES REGULATION (THE "NH BUREAU")
2.
Principal Sanction:
Other
Other Sanctions: 
CONSENT ORDER AND ADMINISTRATIVE PENALTY OF $2,500
3.
Date Initiated (MM/DD/YYYY): 
09/29/2020
 Exact
 Explanation
If not exact, provide explanation:
ON OR ABOUT SEPTEMBER 29, 2020, GREENBACKER RENEWABLE ENERGY COMPANY LLC ("GREC") RECEIVED A LETTER RELATED TO GREC'S FORM D
NOTICE FILING FILED ON AUGUST 25, 2020 WITH THE NH BUREAU.

4.
Docket/Case Number:
I-2020000035
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NH BUREAU ALLEGES THAT GREC, AN ADVISORY AFFILIATE OF THE ADVISOR, VIOLATED NEW HAMPSHIRE RSA 421-B:3-302 BY FILING A NOTICE
FILING WITH THE NH BUREAU LATER THAN FIFTEEN (15) DAYS AFTER THE FIRST SALE IN NEW HAMPSHIRE.
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):
01/12/2021
 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: $ 2,500.00
 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: 
THE DISPOSITION RESULTED IN A $2500 ADMINISTRATIVE PENALTY THAT WAS PAID BY THE ADVISER ON OR ABOUT JANUARY 12, 2021.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON FEBRUARY 15, 2017, GREC MADE THE FIRST SALE TO A NEW HAMPSHIRE RESIDENT OF ITS PRIVATELY OFFERED SECURITIES PURSUANT TO RULE
506 OF REGULATION D UNDER THE SECURITIES ACT OF 1933, AS AMENDED. DUE TO AN ADMINISTRATIVE OVERSIGHT, GREC DID NOT FILE A FORM D
NOTICE FILING WITH THE STATE OF NEW HAMPSHIRE WITHIN FIFTEEN (15) DAYS OF THE INITIAL SALE AS REQUIRED BY RSA 421-B:3-302. DURING
AUGUST 2020, GREC PERFORMED AN INTERNAL REVIEW OF ITS FORM D NOTICE FILING REGULATORY OBLIGATIONS AND SUBMITTED ITS FORM D
NOTICE FILING WITH THE STATE OF NEW HAMPSHIRE ON AUGUST 25, 2020. ON OR ABOUT JANUARY 12, 2021, GREC VOLUNTARILY ENTERED INTO AN
ORDER WITH THE NH BUREAU RELATED TO THE LATE NOTICE FILING AND THE ADVISER PAID A RELATED ADMINISTRATIVE FINE OF $2,500.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GREENBACKER RENEWABLE
ENERGY COMPANY LLC
(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) 
STATE OF HAWAII, DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS, SECURITIES ENFORCEMENT BRANCH ("HAWAII SEB")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/15/2020
 Exact
 Explanation
If not exact, provide explanation:
ON OR ABOUT DECEMBER 15, 2020, GREENBACKER RENEWABLE ENERGY COMPANY LLC ("GREC") RECEIVED A LETTER RELATED TO GREC'S FORM D
NOTICE FILING FILED ON AUGUST 31, 2020 WITH THE HAWAII SEB.
4.
Docket/Case Number:
SEB20200086
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity - OTC

Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE HAWAII SEB ALLEGES THAT GREC, AN ADVISORY AFFILIATE OF THE ADVISOR, VIOLATED HAWAII REVISED STATUTES ("HRS") CHAPTER 485A BY
FILING A NOTICE FILING WITH THE HAWAII SEB LATER THAN FIFTEEN (15) DAYS AFTER THE FIRST SALE IN HAWAII.
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):
03/08/2021
 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: $ 2,500.00
 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: 
THE DISPOSITION RESULTED IN A $2500 ADMINISTRATIVE PENALTY THAT WAS PAID BY THE ADVISER ON OR ABOUT MARCH 8, 2021.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON AUGUST 7, 2018, GREC MADE THE FIRST SALE TO A HAWAII RESIDENT OF ITS PRIVATELY OFFERED SECURITIES PURSUANT TO RULE 506 OF
REGULATION D UNDER THE SECURITIES ACT OF 1933, AS AMENDED. DUE TO AN ADMINISTRATIVE OVERSIGHT, GREC DID NOT FILE A FORM D NOTICE
FILING WITH THE STATE OF HAWAII WITHIN FIFTEEN (15) DAYS OF THE INITIAL SALE AS REQUIRED BY HRS §485A­302(D). DURING AUGUST 2020,
GREC PERFORMED AN INTERNAL REVIEW OF ITS FORM D NOTICE FILING REGULATORY OBLIGATIONS AND SUBMITTED ITS FORM D NOTICE FILING WITH
THE STATE OF HAWAII ON AUGUST 31, 2020. ON OR ABOUT MARCH 8, 2021, GREC VOLUNTARILY ENTERED INTO AN ORDER WITH THE HAWAII SEB
RELATED TO THE LATE NOTICE FILING AND THE ADVISER PAID A RELATED ADMINISTRATIVE FINE OF $2,500.

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:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
GREENBACKER RENEWABLE
ENERGY COMPANY LLC
(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) 
STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCIAL REGULATION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL PENALTY OF $20,000 FOR THE SALE OF UNREGISTERED DISTRIBUTION REINVESTMENT PLAN SECURITIES WITH AN ADDITIONAL AMOUNT OF
$10,000 SUSPENDED FOR VIOLATING A PRIOR RELATED ORDER.
3.
Date Initiated (MM/DD/YYYY): 
08/02/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-23-0033
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
GREENBACKER RENEWABLE ENERGY COMPANY LLC
6.
Principal Product Type:
Equity - OTC
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS SERVICES, DIVISION OF FINANCIAL REGULATION ALLEGES THAT GREENBACKER
RENEWABLE ENERGY COMPANY LLC ("GREC"), AN ADVISORY AFFILIATE AND OWNER OF THE ADVISER, VIOLATED OREGON SECURITIES LAWS BY

DISTRIBUTING SHARES PURSUANT TO A DISTRIBUTION REINVESTMENT PLAN WITHOUT AN ACTIVE ORDER OF STATE REGISTRATION FOR A SHORT
PERIOD OF TIME.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
08/02/2023
 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: $ 20,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE DISPOSITION RESULTED IN A CIVIL PENALTY OF $20,000 FOR THE SALE OF UNREGISTERED SHARES PURSUANT TO A DISTRIBUTION
REINVESTMENT PLAN ("DRIP") AND AN ADDITIONAL AMOUNT OF $10,000 SUSPENDED FOR VIOLATING A PRIOR RELATED ORDER (AS DISCLOSED
IN THIS FORM ADV). GREC PAID THE $20,000 PENALTY ON OR ABOUT AUGUST 2, 2023.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON OR ABOUT AUGUST 2, 2023, GREENBACKER RENEWABLE ENERGY COMPANY LLC ("GREC"), AN ADVISORY AFFILIATE, OWNER, AND CLIENT OF
ADVISER, VOLUNTARILY ENTERED INTO A CEASE AND DESIST ORDER WITH THE STATE OF OREGON, DEPARTMENT OF CONSUMER AND BUSINESS
SERVICES, DIVISION OF FINANCIAL REGULATION (THE "OREGON DIVISION") NEITHER ADMITTING NOR DENYING LIABILITY. THE SECURITIES AND
EXCHANGE COMMISSION AND MANY STATES DO NOT TREAT THE ISSUANCE OF COMMON STOCK DRIP SHARES AS A SALE OF SECURITIES REQUIRING AN
ACTIVE REGISTRATION STATEMENT. THE STATE OF OREGON, HOWEVER, DOES, AND UNBEKNOWNST TO GREC IT HAD A LAPSE IN ITS OREGON DRIP
REGISTRATION FROM MAY 8, 2022 TO AUGUST 28, 2022. AS SUCH, THE DRIP SHARES DISTRIBUTED TO OREGON INVESTORS BY GREC DURING THIS
TIME FRAME WERE DEEMED BY THE OREGON DIVISION TO HAVE VIOLATED OREGON SECURITIES LAW ("ORS") 59.055. GREC STRONGLY DISAGREES
WITH THE OREGON DIVISION'S CHARACTERIZATION OF THE DISTRIBUTION OF DRIP SHARES TO EXISTING OREGON INVESTORS AS A "SALE" UNDER THE
ORS. HOWEVER, IN AN EFFORT TO SETTLE THE MATTER EFFICIENTLY, AND WITHOUT ADMITTING OR DENYING THE DIVISION'S FINDING OF FACT OR
CONCLUSIONS OF LAW, GREC VOLUNTARILY AGREED TO A FINAL DETERMINATION OF THE MATTER WHEREIN THE DIVISION FOUND THAT GREC
VIOLATED ORS 59.055 BY DISTRIBUTING ITS DRIP SHARES TO EXISTING OREGON INVESTORS FOR A SHORT TIME PERIOD WITHOUT AN ACTIVE ORDER
OF REGISTRATION.GREC PAID A RELATED $20,000 FEE.