Chapin Davis Asset Management

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:
2748785
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CRAIN, JOHN, STUART
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?

 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Other
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/08/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2018056386601
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
IMPLEMENT ITS WRITTEN CUSTOMER IDENTIFICATION PROGRAM (CIP). THE FINDINGS STATED THAT THE FIRM'S PROCEDURES PERTAINING TO ITS CIP
REQUIRED THE COMPLETION OF A NEW ACCOUNT FORM, AND THE COLLECTION OF SUPPLEMENTAL INFORMATION AND DOCUMENTATION, FOR EACH
ACCOUNT OPENED. THE FIRM'S PROCEDURES FURTHER REQUIRED THE VERIFICATION OF THE ACCURACY OF INFORMATION AND DOCUMENTATION
PROVIDED AT ACCOUNT OPENING SUFFICIENT TO FORM A REASONABLE BELIEF THAT THE TRUE IDENTITY OF THE CUSTOMER IS KNOWN. HOWEVER,
THE FIRM FAILED TO FULLY IMPLEMENT THESE PROCEDURES AND, AS A RESULT, FAILED TO VERIFY THE IDENTITY OF EACH CUSTOMER TO THE EXTENT
REASONABLE AND PRACTICABLE. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO IMPLEMENT ITS WRITTEN AML POLICIES AND PROCEDURES
RELATING TO THE DETECTION AND REPORTING OF SUSPICIOUS TRANSACTIONS. INCONSISTENT WITH ITS OWN PROCEDURES, THE FIRM FAILED TO
MONITOR ACCOUNT ACTIVITY FOR UNUSUAL SIZE, VOLUME, PATTERN, OR TYPE OF TRANSACTIONS AND OTHER RED FLAGS. THE FIRM OFTEN FAILED TO
REVIEW THE DAILY EXCEPTION REPORTS PROVIDED BY ITS CLEARING FIRM AND DAILY DEPOSIT AND WITHDRAWAL ACTIVITY, OR FAILED TO REVIEW
THEM UNTIL MONTHS AFTER THE POTENTIALLY SUSPICIOUS TRANSACTIONS OCCURRED. AS A RESULT, THE FIRM FAILED TO DETECT AND INVESTIGATE
CERTAIN CUSTOMER ACTIVITY THAT RAISED RED FLAGS OF POTENTIALLY SUSPICIOUS ACTIVITY.
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):
04/08/2020
 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: $ 35,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
$35,000 WAS PAID

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).
CHAPIN DAVIS, IN ACCORDANCE WITH INDUSTRY REGULATIONS, HAS IN PLACE AN EXECUTED ANTI-MONEY LAUNDERING PROGRAM (AML) AND
CUSTOMER IDENTIFICATION PROGRAM (CIP) WITHIN THE DEVELOPMENT OF INTERNAL POLICIES AND PROCEDURES. THE FIRM HAS DESIGNATED AN
AML COMPLIANCE OFFICER, CONDUCTED BOTH ANNUAL TRAINING FOR ALL REGISTERED ASSOCIATES AND ANNUAL INDEPENDENT AUDITS. THE FIRM'S
AML POLICIES AND PROCEDURES MEET THE GUIDELINES AS DEFINED BY RULE 3310(A) THAT CAN REASONABLY DETECT AND CAUSE THE REPORTING OF
SUSPICIOUS TRANSACTIONS REQUIRED UNDER TITLE 31 U.S. CODE 5813(G) FOR ALL CUSTOMER ACCOUNTS AT THE FIRM. FOR THE ACCOUNTS IN
QUESTION, NEW ACCOUNT DOCUMENTS WERE COMPLETED WITH ALL INFORMATION AS REQUIRED BY RULE 2090, KNOW YOUR CUSTOMER. IN
ADDITION, WITHIN TWO DAYS, THE FIRM ALSO RECEIVED PASSPORT INFORMATION FOR ALL BENEFICIAL OWNERS. COPIES OF THE PASSPORT WERE
ADDED TO THE CUSTOMER NEW ACCOUNT DOCUMENTS AND UPDATED THROUGH ACCOUNT MAINTENANCE. OFAC SEARCHES WERE GENERATED FOR
EACH BENEFICIAL OWNER RESULTING IN NO HITS OR MATCHES. OFAC REPORTS WERE FILED WITH CUSTOMER NEW ACCOUNT DOCUMENTS. THE
DOCUMENTED PROCEDURES FOR THE FIRM'S CUSTOMER IDENTIFICATION PROGRAM WERE FOLLOWED TO VERIFY EACH BENEFICIAL OWNER'S
IDENTITY. EACH OF THE INDIVIDUAL'S INFORMATION WAS SUBMITTED VIA EQUIFAX ON THE SAME DAY OF THE NEW ACCOUNT OPENING. EACH
BENEFICIAL OWNER'S CIP REPORT WAS VERIFIED AND VALIDATED USING THEIR RESPECTIVE NON-EXPIRED PASSPORT. ADDITIONALLY, NO RED FLAGS
EXISTED FOR THESE CLIENTS OF ANY SORT OR ANY INDICATION THE CUSTOMERS WERE ENGAGING OR HAD ENGAGED IN SUSPICIOUS ACTIVITY. ALL
BENEFICIAL OWNERS PROVIDED ALL REQUIRED DOCUMENTATION, DID NOT ATTEMPT TO DECEIVE OR PROVIDE FRAUDULENT GOVERNMENT ISSUED
DOCUMENTS. THERE WAS NO NEED TO LABEL THESE CLIENTS AS HIGH RISK OR NECESSITATE THE FILING OF A SUSPICIOUS ACTIVITY REPORT. THE
FIRM DID MONITOR ALL CLIENT ACCOUNTS FOR ACTIVITY RELATED TO SIZE, VOLUME, PATTERN AND OTHER RED FLAGS. THE FIRM REVIEW REPORTS IN
A MANNER CONSISTENT WITH REGULATORY REQUIREMENTS AND DID NOT DETECT ANY SUSPICIOUS ACTIVITY WITHIN THE ACCOUNTS IDENTIFIED.
THERE WAS NO ACTIVITY THAT ROSE TO THE LEVEL OF NEEDING TO FILE A SUSPICIOUS ACTIVITY REPORT.