First Command Advisory Services

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:
3641
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FIRST COMMAND FINANCIAL
PLANNING, INC.
(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 MARYLAND
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
10/18/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3012-0105
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):
FROM THE TIME PERIOD OF OCTOBER 2006 THROUGH MAY 2012, BETWEEN ONE AND THREE ADVISORS CONDUCTED BUSINESS REQUIRING ADVISORY
REGISTRATION; HOWEVER, DUE TO AN ADMINSTRATIVE ERROR, THE ADVISORS' MARYLAND STATE ADVISORY REGISTRATION LAPSED. ALL OF THE
ADVISORS HAD PASSED THE QUALIFIYING EXAMINATIONS, BUT THE FEES WERE NOT PAID TO THE STATE. NO HARM CAME TO CUSTOMERS IN THESE
INSTANCES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
10/18/2013
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 5,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
N/A
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: 
N/A

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).
FROM THE TIME PERIOD OF OCTOBER 2006 THROUGH MAY 2012, BETWEEN ONE AND THREE ADVISORS CONDUCTED BUSINESS REQUIRING ADVISORY
REGISTRATION; HOWEVER, DUE TO AN ADMINSTRATIVE ERROR, THE ADVISORS' MARYLAND STATE ADVISORY REGISTRATION LAPSED. ALL OF THE
ADVISORS HAD PASSED THE QUALIFIYING EXAMINATIONS, BUT THE FEES WERE NOT PAID TO THE STATE. NO HARM CAME TO CUSTOMERS IN THESE
INSTANCES. THE FIRM RE-REGISTERED TEH INDIVIDUAL IN THE STATE THAT ARE STILL WITH TEH COMPANY, AND CREATED AN ALERT IN AN
ELECTRONIC MONITORING SYSTEM THAT WILL NOTIFY THE FIRM IF AN INCIDENT SUCH AS THIS OCCURS AGAIN.

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:
4393016
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
JOSEPH, TIMOTHY
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:

SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
FINRA
2.
Principal Sanction:
Suspension
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
01/04/2021
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019064399201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
FIRST COMMAND ADVISORY SERVICES.INC.
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, JOSEPH CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT HE ELECTRONICALLY
AFFIXED CUSTOMER SIGNATURES TO IRA DISTRIBUTION FORMS, AUTOMATED CLEARING HOUSE (ACH) AUTHORIZATION AGREEMENTS AND ADVISORY
ACCOUNT OPENING DOCUMENTS THAT HE SUBMITTED TO THE FIRM, WITHOUT PRIOR AUTHORIZATION. THE FINDINGS STATED THAT JOSEPH MET WITH
A CUSTOMER REGARDING OPENING ACCOUNTS WITH THE FIRM'S INVESTMENT ADVISOR AFFILIATE. AFTER MEETING WITH THE CUSTOMER AGAIN,
JOSEPH ELECTRONICALLY AFFIXED THE CUSTOMER'S SIGNATURE TO THE ACCOUNT OPENING DOCUMENTS, CAUSING ASSETS TO BE TRANSFERRED
FROM HER FIRM ACCOUNT TO THE NEW ADVISORY ACCOUNTS. WHEN THE CUSTOMER LEARNED THAT THE ADVISORY ACCOUNTS WERE OPENED, SHE
IMMEDIATELY INSTRUCTED JOSEPH TO REVERSE THE TRANSACTIONS. JOSEPH REPORTED THE CUSTOMER'S COMPLAINT TO THE FIRM, AND THE FIRM
REVERSED THE TRANSACTIONS. JOSEPH ALSO ELECTRONICALLY AFFIXED THE SIGNATURES OF OTHER FIRM CUSTOMERS TO ADVISORY ACCOUNT
OPENING DOCUMENTS, A FIRM CUSTOMER'S SIGNATURE TO IRA DISTRIBUTION FORMS, AND FIRM CUSTOMERS' SIGNATURES TO ACH AUTHORIZATION
AGREEMENTS. THE FIRM USED THE DOCUMENTS TO AUTHORIZE AND RECORD THE SALE, TRANSFER, OR DISBURSEMENT OF CASH OR SECURITIES FROM
THE CUSTOMERS' ACCOUNTS. ALTHOUGH THESE CUSTOMERS DID NOT INITIALLY AUTHORIZE JOSEPH TO ELECTRONICALLY AFFIX THEIR SIGNATURES,
THEY SUBSEQUENTLY APPROVED THE TRANSACTIONS. WHEN THE FIRM DISCOVERED JOSEPH'S CONDUCT, IT DISCIPLINED HIM BY, AMONG OTHER
THINGS, FINING HIM $10,000 AND ASSIGNING HIM ADDITIONAL TRAINING. THE FINDINGS ALSO STATED THAT, BY ENGAGING IN HIS CONDUCT, JOSEPH
ALSO CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS.
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):
01/04/2021
 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: $
 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: 

SUSPENDED IN ALL CAPACITIES FOR 45 DAYS, EFFECTIVE 2/1/2021 TO 4/6/2021.
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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, JOSEPH CONSENTED TO THE SANCTION AND TO THE ENTRY OF FINDINGS THAT HE ELECTRONICALLY
AFFIXED CUSTOMER SIGNATURES TO IRA DISTRIBUTION FORMS, AUTOMATED CLEARING HOUSE (ACH) AUTHORIZATION AGREEMENTS AND ADVISORY
ACCOUNT OPENING DOCUMENTS THAT HE SUBMITTED TO THE FIRM, WITHOUT PRIOR AUTHORIZATION. THE FINDINGS STATED THAT JOSEPH MET WITH
A CUSTOMER REGARDING OPENING ACCOUNTS WITH THE FIRM'S INVESTMENT ADVISOR AFFILIATE. AFTER MEETING WITH THE CUSTOMER AGAIN,
JOSEPH ELECTRONICALLY AFFIXED THE CUSTOMER'S SIGNATURE TO THE ACCOUNT OPENING DOCUMENTS, CAUSING ASSETS TO BE TRANSFERRED
FROM HER FIRM ACCOUNT TO THE NEW ADVISORY ACCOUNTS. WHEN THE CUSTOMER LEARNED THAT THE ADVISORY ACCOUNTS WERE OPENED, SHE
IMMEDIATELY INSTRUCTED JOSEPH TO REVERSE THE TRANSACTIONS. JOSEPH REPORTED THE CUSTOMER'S COMPLAINT TO THE FIRM, AND THE FIRM
REVERSED THE TRANSACTIONS. JOSEPH ALSO ELECTRONICALLY AFFIXED THE SIGNATURES OF OTHER FIRM CUSTOMERS TO ADVISORY ACCOUNT
OPENING DOCUMENTS, A FIRM CUSTOMER'S SIGNATURE TO IRA DISTRIBUTION FORMS, AND FIRM CUSTOMERS' SIGNATURES TO ACH AUTHORIZATION
AGREEMENTS. THE FIRM USED THE DOCUMENTS TO AUTHORIZE AND RECORD THE SALE, TRANSFER, OR DISBURSEMENT OF CASH OR SECURITIES FROM
THE CUSTOMERS' ACCOUNTS. ALTHOUGH THESE CUSTOMERS DID NOT INITIALLY AUTHORIZE JOSEPH TO ELECTRONICALLY AFFIX THEIR SIGNATURES,
THEY SUBSEQUENTLY APPROVED THE TRANSACTIONS. WHEN THE FIRM DISCOVERED JOSEPH'S CONDUCT, IT DISCIPLINED HIM BY, AMONG OTHER
THINGS, FINING HIM $10,000 AND ASSIGNING HIM ADDITIONAL TRAINING. THE FINDINGS ALSO STATED THAT, BY ENGAGING IN HIS CONDUCT, JOSEPH
ALSO CAUSED THE FIRM TO MAINTAIN INACCURATE BOOKS AND RECORDS.

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:
281958
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FIRST COMMAND ADVISORY
SERVICES
(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 VIRGINIA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
12/16/2020
 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):
FIRST COMMAND ADVISORY SERVICES.INC.
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):
THE DIVISION ALLEGED FIRST COMMAND VIOLATED §13.1­504A(II) OF THE VIRGINIA SECURITIES ACT BY EMPLOYING AN INVESTMENT ADVISOR
REPRESENTATIVE IN VIRGINIA WHO WAS NOT REGISTERED WITH THE DIVISION FROM OCTOBER 2019 TO PRESENT.
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):
02/25/2021
 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: $ 20,500.00
 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: 
PAID $20,000 IN MONETARY PENALITIES AND $500 TO DEFRAY THE COST OF THE INVESTIGATION

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).
WITHOUT ADMITTING OR DENYING TO THE ALLEGATIONS MADE, FIRST COMMAND AGREED TO ENTER INTO A SETTLEMENT ORDER, PAID $20,000 IN
MONETARY PENALITIES AND $500 TO DEFRAY THE COST OF THE INVESTIGATION, AND TO BE PERMENTANTLY ENJOINED FROM VIOLATING THE VIRGINIA
SECURITIES ACT IN THE FUTURE.

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:
3641
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
FIRST COMMAND BROKERAGE
SERVICES, INC.
(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 COLORADO
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/21/2014
 Exact
 Explanation
If not exact, provide explanation:
THE ALLEGED ACTIVITY OF A SALES REPRESENTATIVE NOT LICENSED IN COLORADO THROUGH FIRST COMMAD OCCURRED BETWEEN 2014 AND APRIL
7, 2022
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
FIRST COMMAND BROKERAGE SERVICES
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):
THE STATE ALLEGES THAT FIRST COMMAND VIOLATED§ 11­51­401(2), C.R.S. WHICH PROHIBITS A BROKER­DEALER FROM EMPLOYING OR ENGAGING A
PERSON TO ACT AS A SALES REPRESENTATIVE UNLESS SUCH PERSON HAS A LICENSE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Stipulation and Consent
11. Resolution Date (MM/DD/YYYY):
06/13/2022
 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: $ 63,232.00
 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: 
$63232, 6/13/2022
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 FIRM AGREED TO ENTER INTO A STIPULATION FOR CONSENT ORDER WITH THE COLORADO DIVISION OF SECURITIES RELATED TO ITS FAILURE TO
LICENSE SALES REPRESENTATIVES WHO PROVIDE SECURITIES SERVICES IN THE STATE OF COLORADO. THE CONSENT ORDER, DATED JUNE 13, 2022,
REQUIRES THE FIRM TO: (1) PERMANENTLY CEASE AND DESIST FROM CONDUCT IN VIOLATION OF THE COLORADO SECURITIES ACT (THE "ACT") AND
THE RULES UNDER THE ACT; (2) MAINTAIN CURRENT SALES REPRESENTATIVE LICENSES FOR ALL INDIVIDUALS WHO PROVIDE SECURITIES SERVICES IN
THE STATE OF COLORADO AS LONG AS FIRST COMMAND MAINTAINS A LICENSE AND CONTINUES TO OPERATE AS A BROKER-DEALER IN THE STATE OF
COLORADO; AND PAY A SANCTION OF $63,232.00.