Bountiful Investment 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:
4498004
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WELLS, JOSHUA, JON
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
EUCLID FINANCIAL SERVICES,
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) 
SECURITIES DIVISION OF THE OFFICE OF THE SECRETARY OF STATE OF THE COMMONWEALTH OF MASSACHUSETTS
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE; DISGORGEMENT OF ANY COMMISSIONS THROUGH OFFER TO REIMBURSE CLIENTS; AND ADMINISTRATIVE FINE ONLY AGAINST EUCLID
FINANCIAL SERVICES, LLC.
3.
Date Initiated (MM/DD/YYYY): 
02/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
E-2019-0057
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
EUCLID FINANCIAL SERVICES, LLC
6.
Principal Product Type:
Annuity(ies) - Fixed
Other Product Types: 
STOCKS & BONDS WITHIN 403(B) RETIREMENT ACCOUNT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

TWO INDEPENDENT CONTRACTORS OF EUCLID FINANCIAL SERVICES, LLC, WHO WERE ONLY LICENSED AS INSURANCE PRODUCERS AND NOT
INVESTMENT ADVISER REPRESENTATIVES, ALLEGEDLY RECOMMENDED THAT A CUSTOMER ROLLOVER THE VALUE OF THE CUSTOMER'S 403(B)
RETIREMENT ACCOUNT (WHICH INCLUDED STOCKS AND BONDS) TO PURCHASE AN ANNUITY. JOSHUA WELLS, WHO IS LICENSED AS AN INSURANCE
PRODUCER BUT NOT AS AN INVESTMENT ADVISER REPRESENTATIVE, AND EUCLID FINANCIAL SERVICES, LLC ALLEGEDLY RECEIVED A PORTION OF THE
COMMISSION FROM THE ANNUITY TRANSACTION FUNDED THROUGH THE 403(B) ROLLOVER. JOSHUA WELLS IS THE PRIMARY OWNER OF EUCLID
FINANCIAL SERVICES, LLC AND EUCLID WEALTH MANAGEMENT LLC, WHICH IS AN INVESTMENT ADVISER. THE SECURITIES DIVISION OF THE
SECRETARY OF STATE OF THE COMMONWEALTH OF MASSACHUSETTS ALLEGED THAT EUCLID FINANCIAL SERVICES, LLC IS NOT REGISTERED AS AN
INVESTMENT ADVISER AND JOSHUA WELLS IS NOT REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE. MA ALSO ALLEGED THAT EUCLID
WEALTH MANAGEMENT EMPLOYED AN INVESTMENT ADVISER REPRESENTATIVE WHO WAS NOT REGISTERED. MA ALLEGED THAT JOSHUA MADE A FALSE
OR MISLEADING STATEMENT TO MA.
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):
02/09/2022
 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: $ 25,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE ADMINISTRATIVE FINE WAS AGAINST ONLY EUCLID FINANCIAL SERVICES, LLC. IN ADDITION, THE ORDER REQUIRES AMONG OTHER THINGS:
(A) CHANGE OF NAMES OF EUCLID WEALTH MANAGEMENT LLC AND EUCLID FINANCIAL SERVICES, LLC; (B) REGISTER APPLICABLE INDIVIDUALS
AS IARS; (C) IDENTIFY INSURANCE PRODUCERS AS SUCH; (D) UPDATE SIGNAGE, MARKETING, ADVERTISING, FORMS, REGULATORY DOCS AND
CONTRACTS; (E) SEND WRITTEN NOTICE TO ALL CLIENTS; AND (F) ENTER INTO SHARED SERVICES AGREEMENT.
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: 
OFFERS TO REIMBURSE THE CLIENTS FOR COMMISSIONS RECEIVED HAVE BEEN MADE.
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).
EUCLID FINANCIAL SERVICES, LLC HAS PAID THE ADMINISTRATIVE FINE. OFFERS TO REIMBURSE THE CLIENTS FOR COMMISSIONS RECEIVED HAVE
BEEN MADE. EUCLID WEALTH MANAGEMENT LLC AND EUCLID FINANCIAL SERVICES, LLC HAVE CHANGED THEIR RESPECTIVE NAMES, AND THEY ARE
WORKING ON THE OTHER REQUIREMENTS OF THE ORDER.

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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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:
4498004
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WELLS, JOSHUA, JON
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
EUCLID FINANCIAL SERVICES,
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.H.
(1)(a), 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.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
SECURITIES DIVISION OF THE OFFICE OF THE SECRETARY OF STATE OF THE COMMONWEALTH OF MASSACHUSETTS
2.
Principal Relief Sought:
Cease and Desist
Other Relief Sought: 
CENSURE; DISGORGEMENT; AND ADMINISTRATIVE FINE ONLY AGAINST EUCLID FINANCIAL SERVICES, LLC.
3.
Filing Date of Court Action (MM/DD/YYYY):
02/08/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Annuity(ies) - Fixed
Other Product Types: 
STOCKS & BONDS WITHIN 403(B) RETIREMENT ACCOUNT

5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
COMMONWEALTH OF MASSACHUSETTS, OFFICE OF SECRETARY OF THE COMMONWEALTH, SECURITIES DIVISION, BOSTON, MA (DOCKET NO. E-2019-
0057)
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
TWO INDEPENDENT CONTRACTORS OF EUCLID FINANCIAL SERVICES, LLC, WHO WERE ONLY LICENSED AS INSURANCE PRODUCERS AND NOT
INVESTMENT ADVISER REPRESENTATIVES, ALLEGEDLY RECOMMENDED THAT A CUSTOMER ROLLOVER THE VALUE OF THE CUSTOMER'S 403(B)
RETIREMENT ACCOUNT (WHICH INCLUDED STOCKS AND BONDS) TO PURCHASE AN ANNUITY. JOSHUA WELLS, WHO IS LICENSED AS AN INSURANCE
PRODUCER BUT NOT AS AN INVESTMENT ADVISER REPRESENTATIVE, AND EUCLID FINANCIAL SERVICES, LLC ALLEGEDLY RECEIVED A PORTION OF THE
COMMISSION FROM THE ANNUITY TRANSACTION FUNDED THROUGH THE 403(B) ROLLOVER. JOSHUA WELLS IS THE PRIMARY OWNER OF EUCLID
FINANCIAL SERVICES, LLC AND EUCLID WEALTH MANAGEMENT LLC, WHICH IS AN INVESTMENT ADVISER. THE SECURITIES DIVISION OF THE
SECRETARY OF STATE OF THE COMMONWEALTH OF MASSACHUSETTS ALLEGED THAT EUCLID FINANCIAL SERVICES, LLC IS NOT REGISTERED AS AN
INVESTMENT ADVISER AND JOSHUA WELLS IS NOT REGISTERED AS AN INVESTMENT ADVISER REPRESENTATIVE. MA ALSO ALLEGED THAT EUCLID
WEALTH MANAGEMENT EMPLOYED AN INVESTMENT ADVISER REPRESENTATIVE WHO WAS NOT REGISTERED. MA ALLEGED THAT JOSHUA MADE A FALSE
OR MISLEADING STATEMENT TO MA.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Consent
12. Resolution Date (MM/DD/YYYY): 
02/09/2022
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 25,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
THE ADMINISTRATIVE FINE WAS AGAINST ONLY EUCLID FINANCIAL SERVICES, LLC. IN ADDITION, THE ORDER REQUIRES AMONG OTHER THINGS:
(A) CHANGE OF NAMES OF EUCLID WEALTH MANAGEMENT LLC AND EUCLID FINANCIAL SERVICES, LLC; (B) REGISTER APPLICABLE INDIVIDUALS
AS IARS; (C) IDENTIFY INSURANCE PRODUCERS AS SUCH; (D) UPDATE SIGNAGE, MARKETING, ADVERTISING, FORMS, REGULATORY DOCS AND
CONTRACTS; (E) SEND WRITTEN NOTICE TO ALL CLIENTS; AND (F) ENTER INTO SHARED SERVICES AGREEMENT.
C.
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:
OFFERS TO REIMBURSE THE CLIENTS FOR COMMISSIONS RECEIVED HAVE BEEN MADE.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
EUCLID FINANCIAL SERVICES, LLC HAS PAID THE ADMINISTRATIVE FINE. OFFERS TO REIMBURSE THE CLIENTS FOR COMMISSIONS RECEIVED HAVE
BEEN MADE. EUCLID WEALTH MANAGEMENT LLC AND EUCLID FINANCIAL SERVICES, LLC HAVE CHANGED THEIR RESPECTIVE NAMES, AND THEY ARE
WORKING ON THE OTHER REQUIREMENTS OF THE ORDER.