Firm profile

Gibbs Wealth Management, LLC

ALPHARETTA, GACRD 281621Registration Status: ApprovedEffective since February 15, 2022SEC # 801-123227Latest ADV August 28, 2026

Gibbs Wealth Management, LLC is an SEC registered investment adviser organized as a limited liability company with a primary office location in Alpharetta, GA. Its latest Form ADV filing, dated August 28, 2026, reports $1.1B in regulatory assets under management, 147 employees, 128 offices, and 5,357 accounts.

Assets Under Management
$1.1B
Employees
147
Offices
128 offices
Total Clients
5,356

Associated firm names

58 names listed
  • 360 WEALTH MANAGEMENT, LLC
  • WEALTHFUL LLC
  • TW WEALTH MANAGEMENT
  • TURNEY WEALTH MANAGEMENT, LLC

Leadership

1 roles identified
CCOSusanne M. Naso

Advisory services offered

2 types reported
Portfolio management for individuals and small businesses
Selection of other advisers

Fee models offered

1 types reported
Asset based fees

Offices & Contact

Primary office

ALPHARETTA, Georgia, United States

Loading map…

Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Georgia

ALPHARETTAPrimary office · ST. SIMONS ISLAND · LAWRENCEVILLE · DOUGLASVILLE · KENNESAW · SANDY SPRINGS · SAVANNAH

Alabama

BIRMINGHAM

Arizona

GREEN VALLEY · TUCSON, · TUCSON

California

PASADENA · BURBANK · NEWHALL · CANOGA PARK · MURRIETA · SAN MARCOS · SAN DIEGO · ROLLING HILLS ESTATES · DANVILLE · CERRITOS · ROSEVILLE · SAN JOSE · SUNNYVALE · SIMI VALLEY · SANTA MONICA · AGOURA HILLS · NEWPORT BEACH · GLENDALE · RIVERSIDE

Colorado

DENVER · BOULDER · LOVELAND

Florida

CRYSTAL RIVER · JACKSONVILLE · ORANGE PARK · FORT MYERS · CLEARWATER · BONITA SPRINGS · VENICE · SARASOTA · YULEE

Hawaii

HONOLULU

Idaho

BOISE

Illinois

ROCKFORD · ORLAND PARK · ROLLING MEADOWS · SKOKIE · ST. CHARLES · WESTCHESTER

Indiana

CROWN POINT · SOUTH BEND · VALPARAISO · LAPORTE · ELKHART · JASPER · MUNSTER · FISHERS · FORT WAYNE · EVANSVILLE

Iowa

DECORAH · WATERLOO · DUBUQUE · WEST DESMOINES · BETTENDORF · HIAWATHA

Kansas

SHAWNEE

Kentucky

OWENSBORO · LOUISVILLE

Louisiana

GRETNA · SLIDELL · METAIRIE · HOUMA · BATON ROUGE · MANDEVILLE

Massachusetts

HINGHAM

Michigan

BAY CITY · BLOOMFIELD TWP. · TRENTON · BRIGHTON · ADRIAN · ESCANABA · LIVONIA · GRAND BLANC

Minnesota

SAINT CHARLES · ROCHESTER · LA CRESCENT · OWATONNA · AUSTIN

Mississippi

BILOXI · DIAMONDHEAD

North Carolina

DURHAM · PINEVILLE

Ohio

ARCHBOLD · HOLLAND · FREMONT · FINDLAY · LIMA · COLUMBUS · PERRYSBURG

Pennsylvania

BRIDGEVILLE · PENNSBURG · LEMOYNE

Tennessee

SPARTA · KNOXVILLE · NASHVILLE · CHATTANOOGA

Texas

FLOWER MOUND · FORT WORTH · ABILENE · HOUSTON · GRANBURY · CEDAR HILL · SOUTHLAKE

Utah

CLEARFIELD · LOGAN · COTTONWOOD HEIGHTS · LEHI · ST. GEORGE · SALT LAKE CITY

Vermont

WILLISTON

Washington

BELLEVUE

West Virginia

MORGANTOWN

Wisconsin

BURLINGTON · ELM GROVE · GERMANTOWN

129 office records listed · 128 total offices reported. 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$1.1Bas of August 28, 2026
Discretionary98.2%
$1.0B
98% of total RAUM98.2%
Non-discretionary1.8%
$19M
2% of total RAUM1.8%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 97.4% of total clients.
Top client categories% of clientsClients
1
Individuals
97.4%
5,216
2
HNWI
2.6%
140
Categories with <5 clients
Pension and profit sharing plans<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$1.1B
Total Accounts5,357
10Y AUM Change+$963M (+941.6%)

Private Funds

Private funds reported by Gibbs Wealth Management, LLC

Loading private fund disclosures…

Employee Growth by Quarter

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

Total Employees147
Clients per Employee36:1
10Y Employee Change+126 (+600.0%)

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%
EDWARD BYRON GIBBSDirect owner · Schedule AInterest in GIBBS WEALTH MANAGEMENT, 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 Gibbs Wealth Management, LLC.

No indirect ownership information reported in the source’s Schedule B.

Reported ownership and control details

Form ADV · Filing date 2026-08-28 · Schedules A and B

3 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1EDWARD BYRON GIBBSMANAGING MEMBER/OWNERIndividualGIBBS WEALTH MANAGEMENT, LLC75% or moreCode EYesMANAGING MEMBER/OWNER10/2015Schedule APDF page 106
2DANIEL ROY MOWERYPRESIDENTIndividualGIBBS WEALTH MANAGEMENT, LLCLess than 5%Code NAYesPRESIDENT01/2024Schedule APDF page 106
3SUSANNE MARIE NASOCHIEF COMPLIANCE OFFICERIndividualGIBBS WEALTH MANAGEMENT, LLCLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER03/2026Schedule APDF page 106

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 8/28/2026 9:36:04 AM

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 none of the events below involve the firm or its supervised persons.RIA responseNo
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 actions2 Yes3 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?Yes
  • 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?Yes
  • 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 actions4 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?No
  • 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?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
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 proceedings1 Yes3 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?Yes
  • 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 4 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 1ORFIN, DANIEL, PATRICKPDF pages 107–108
Advisory affiliate name — filed text
ORFIN, DANIEL, PATRICK
Regulator name — filed text
STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIALSERVICES
Monetary/Fine Amount — filed text
$ 3,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

ON 10/2/2018, THE MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES ENTERED A FINAL ORDER RESOLVING THE MATTER THROUGH A $3,000 SETTLEMENT. THE RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER. THE ORDER BECAME FINAL ON 10/2/2018.
Other filed details

Description of allegations — filed text

STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES(DIFS) ALLEGES VIOLATIONS OF THE FOLLOWING PROVISIONS OF THEMICHAIGAN INSURANCE CODE: MCL 500.1247(1), MCL 500.1239(1)(G), ANDMCL 500.1239(2)(E).

Sanction detail — filed text

3000
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:
7856843
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ORFIN, DANIEL, PATRICK
(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 MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIALSERVICES
2.
Principal Sanction:

Cease and Desist
Other Sanctions: 
CIVIL ADMINISTRATIVE PENALTIES / FINES
3.
Date Initiated (MM/DD/YYYY): 
01/29/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20-16277
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REAL ESTATE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES(DIFS) ALLEGES VIOLATIONS OF THE FOLLOWING PROVISIONS OF
THEMICHAIGAN INSURANCE CODE: MCL 500.1247(1), MCL 500.1239(1)(G), ANDMCL 500.1239(2)(E).
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):
10/02/2018
 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: $ 3,000.00
 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: 
3000
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 10/2/2018, THE MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES ENTERED A FINAL ORDER RESOLVING THE MATTER THROUGH A
$3,000 SETTLEMENT. THE RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER. THE ORDER BECAME FINAL ON 10/2/2018.
regulatory · block 2ORFIN, DANIEL, PATRICKPDF pages 108–110
Advisory affiliate name — filed text
ORFIN, DANIEL, PATRICK
Regulator name — filed text
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORYAFFAIRS - COPORATION, SECURITIES & COMMERICAL LICENSING BUREAU
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

ON 10/2/2018, THE MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS ISSUED AN ORDER DIRECTING THE RESPONDENT TO IMMEDIATELY CEASE AND DESIST FROM ALLEGEDLY VIOLATING MCL 451.2301 AND 451.2402(1). THE RESPONDENT CONSENTED TO THE ENTRY OF THE ORDER. THE ORDER BECAME FINAL ON 10/2/2018.
Other filed details

Description of allegations — filed text

ORDERED TO IMMEDIATELY CEASE AND DESIST FROM ALLEGEDLY VIOLATINGMCL 451.2301 AND 452.2402(1)

Sanction detail — filed text

10000
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:
7856843
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ORFIN, DANIEL, PATRICK
(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 MICHIGAN DEPARTMENT OF LICENSING AND REGULATORYAFFAIRS - COPORATION, SECURITIES & COMMERICAL LICENSING BUREAU
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CIVIL ADMINISTRATIVE PENALTIES / FINES
3.
Date Initiated (MM/DD/YYYY): 
01/29/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
333304

5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
REAL ESTATE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ORDERED TO IMMEDIATELY CEASE AND DESIST FROM ALLEGEDLY VIOLATINGMCL 451.2301 AND 452.2402(1)
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):
10/02/2018
 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: $ 10,000.00
 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: 
10000
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 10/2/2018, THE MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS ISSUED AN ORDER DIRECTING THE RESPONDENT TO
IMMEDIATELY CEASE AND DESIST FROM ALLEGEDLY VIOLATING MCL 451.2301 AND 451.2402(1). THE RESPONDENT CONSENTED TO THE ENTRY OF THE
ORDER. THE ORDER BECAME FINAL ON 10/2/2018.
regulatory · block 3WATSON, THOMAS, WARRENPDF pages 110–112
Advisory affiliate name — filed text
WATSON, THOMAS, WARREN
Regulator name — filed text
COMMISSIONER OF SECURITIES AND INSURANCE STATE OF MONTANA
Monetary/Fine Amount — filed text
$ 2,500.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

THE ORDER WAS FINALIZED ON JANUARY 29, 2016.
Other filed details

Description of allegations — filed text

A NUMBER OF CLIENTS SOLD SECURITIES IN ORDER TO PURCHASE ANNUITIES MR. WATSON SUGGESTED AND SOLD

Sanction detail — filed text

A CIVIL MONETARY PENALTY OF $2,500 WAS IMPOSED.
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:
1997626
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
WATSON, THOMAS, WARREN
(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) 
COMMISSIONER OF SECURITIES AND INSURANCE STATE OF MONTANA
2.
Principal Sanction:
Restitution
Other Sanctions: 
MONETARY PENALTY OTHER THAN FINES
3.
Date Initiated (MM/DD/YYYY): 
01/15/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
SEC-2015-130
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
NA INDEPENDENT INSURANCE AGENT
6.
Principal Product Type:
Annuity(ies) - Fixed
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
A NUMBER OF CLIENTS SOLD SECURITIES IN ORDER TO PURCHASE ANNUITIES MR. WATSON SUGGESTED AND SOLD

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):
01/29/2016
 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: $ 2,500.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SEND A LETTER TO EACH CLIENT WHO SOLD SECURITIES TO BUY THE ANNUITY OFFERING RESTITUTION IF THEY WANTED TO UNDO THE
TRANSACTION
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: 
A CIVIL MONETARY PENALTY OF $2,500 WAS IMPOSED.
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).
THE ORDER WAS FINALIZED ON JANUARY 29, 2016.
civil judicial · block 1PDF pages 112–114
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 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:
7856843
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
ORFIN, DANIEL, PATRICK
(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.) 
PRIVATE PLAINTIFF / BANKRUPTCY COURT IN DELAWARE
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
12/01/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Principal Product Type:
Other
Other Product Types: 
REAL ESTATE
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): 
19-51005 PRIVATE PLAINTIFF / BANKRUPTCY COURT IN DELAWARE
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): 
THE SUIT WAS FILED TO RECOVER MONIES PREVIOUSLY PAID TO MR. ORFIN IN RELATION TOSECURITIES SOLD ON BEHALF OF WOODBRIDGE GROUP
OF COMPANIES ON THE GROUNDSTHAT PAYMENTS WERE FRAUDULENT AND LIABLE FOR THE SALE OF UNREGISTEREDSECURITIES, FRAUD, AND AIDING
AND ABETTING FRAUD.
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:
Settled
12. Resolution Date (MM/DD/YYYY): 
03/25/2021
 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: $ 120,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
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:
120000
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). 
ON 3/25/2021, THE CIVIL ACTION FILED IN THE U.S. BANKRUPTCY COURT FOR THE DISTRICT OF DELAWARE WAS RESOLVED THROUGH A $120,000
SETTLEMENT. THE RESPONDENT CONSENTED TO THE SETTLEMENT WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. THE COURT APPROVED THE
SETTLEMENT AND THE MATTER WAS CLOSED ON 3/25/2021.

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