Willow Wealth

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:
282487
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
YIELDSTREET
(For individuals, Last, First,
Middle)
CRD
Number:
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
YIELDSTREET, 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) 
U.S. SECURITIES AND EXCHANGE COMMISSION ("SEC")
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
A. RESPONDENTS SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2)
AND 17(A)(3) OF THE SECURITIES ACT AND SECTION 206(4) OF THE ADVISERS ACT AND RULES 206(4)-7 AND 206(4)-8 THEREUNDER. B. RESPONDENT
YIELDSTREET MANAGEMENT, LLC IS CENSURED. C. RESPONDENTS SHALL PAY DISGORGEMENT, PREJUDGMENT INTEREST, AND CIVIL MONETARY
PENALTIES, JOINTLY AND SEVERALLY, TOTALING $1,939,220
3.
Date Initiated (MM/DD/YYYY): 
09/12/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
FILE NO. 3-21651
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
YIELDSTREET INC. ("YS INC.") AND YIELDSTREET MANAGEMENT, LLC ("YSM") (COLLECTIVELY, "YIELDSTREET" OR "RESPONDENTS")
6.
Principal Product Type:
Other
Other Product Types: 
PRIVATE FUND OFFERING

7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SEC ORDER RELATED TO A SINGLE LEGACY VESSEL DECONSTRUCTION SECURITY OFFERING THAT WAS EXPOSED TO UNDERLYING BORROWER
DEFAULTS. THE ORDER STATES THAT YIELDSTREET FAILED TO DISCLOSE TO INVESTORS A HEIGHTENED RISK THAT IT WOULD BE UNABLE TO SEIZE THE
SHIP SERVING AS COLLATERAL FOR THE LOAN UNDERLYING THE OFFERING, IN THE EVENT OF A DEFAULT. ALTHOUGH YIELDSTREET REACHED A
SETTLEMENT WITH THE SEC, YIELDSTREET NEITHER ADMITS NOR DENIES ANY WRONGDOING. WE FULLY COOPERATED WITH THE SEC'S INQUIRY AND
ARE PLEASED TO HAVE REACHED A RESOLUTION OF THESE ISSUES. THE SEC'S ORDER ACKNOWLEDGES YIELDSTREET'S COOPERATION AND REMEDIAL
EFFORTS.
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):
09/12/2023
 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: $ 1,939,220.00
 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: 
YIELDSTREET AGREED TO PAY A FINE OF APPROXIMATELY $1.32 MILLION WHICH WILL BE PAID DIRECTLY TO INVESTORS THROUGH A FAIR FUND.
YIELDSTREET DEPOSITED THE MONEY INTO THE FAIR FUND ON SEPTEMBER 22, 2023. YIELDSTREET ALSO AGREED TO WAIVE APPROXIMATELY
$600,000 IN FEES RELATED TO THE SECURITIES OFFERING AT ISSUE.
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 SEC ADMINISTRATIVE ORDER IS FINAL. THE FULL AMOUNT OF THE DISGORGEMENT, PREJUDGMENT INTEREST AND CIVIL MONEY PENALTIES WAS
PAID INTO THE ESCROW ACCOUNT WITHIN 10 DAYS OF THE ENTRY OF THE ORDER. WITHIN 90 DAYS FROM THE DATE OF THE ORDER, YIELDSTREET
MUST SUBMIT A DISBURSEMENT CALCULATION TO THE COMMISSION FOR REVIEW AND APPROVAL. WITHIN 30 DAYS OF THE WRITTEN APPROVAL OF
THE CALCULATION BY THE COMMISSION STAFF, YIELDSTREET MUST SUBMIT A PAYMENT FILE FOR REVIEW AND ACCEPTANCE BY THE COMMISSION
STAFF DEMONSTRATING THE APPLICATION OF THE METHODOLOGY TO EACH AFFECTED ADVISORY CLIENT. TITAN MUST DISBURSE ALL AMOUNTS
PAYABLE TO AFFECTED ADVISORY CLIENTS WITHIN 90 DAYS OF THE DATE THE COMMISSION STAFF ACCEPTS THE PAYMENT FILE.