Vanguard Capital

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:
1014886
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BLAKEZUNIGA, JOHN, AMADOR
(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) 
ARKANSAS SECURITIES DEPARTMENT
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
03/30/2011
 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):
VANGUARD CAPITAL
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):
BLAKEZUNIGA FAILED TO DISCLOSE TO HIS BROKER-DEALER HIS POSITION AS CEO OR CHIEF EXECUTIVE OF AN ENTITY IN WHICH HE ISSUED
PROMISSORY NOTES AND THEREFORE CONDUCTED UNAUTHORIZED OUTSIDE BUSINESS ACTIVITIES.
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):
03/30/2011
 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: $ 3,500.00
 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: 
CEASE AND DESIST $3500 FINE
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).
BLAKEZUNIGA FAILED TO DISCLOSE TO HIS BROKER-DEALER HIS POSITION AS CEO OR CHIEF EXECUTIVE OF AN ENTITY IN WHICH HE ISSUED
PROMISSORY NOTES AND THEREFORE CONDUCTED UNAUTHORIZED OUTSIDE BUSINESS ACTIVITIES.

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.

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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:
1014886
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BLAKEZUNIGA, JOHN, AMADOR
(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): 
08/30/2011
 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):
VANGUARD CAPITAL
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):
FINRA RULE 2010, NASD RULES 2110, 3030: BLAKE-ZUNIGA FAILED TO PROVIDE PROMPT WRITTEN NOTICE OF AN OUTSIDE BUSINESS ACTIVITY TO HIS
MEMBER FIRM. BLAKE-ZUNIGA FORMED A COMPANY BEFORE BECOMING ASSOCIATED WITH HIS FIRM; ONCE HE BECAME ASSOCIATED WITH HIS FIRM,
HE DISCLOSED THE COMPANY HE FORMED AS AN OUTSIDE BUSINESS ACTIVITY AND DESCRIBED HIS ROLE AS A PASSIVE INVESTOR WITH NO DAY TO
DAY EMPLOYMENT OR MANAGEMENT RESPONSIBILITY. WHILE STILL ASSOCIATED WITH HIS FIRM, BLAKE-ZUNIGA BECAME A DIRECTOR AND THE CEO OF

THE COMPANY. THIS WAS A MATERIAL CHANGE IN THE NATURE OF BLAKE-ZUNIGA'S AFFILIATION WITH HIS COMPANY AND, THEREFORE, A NEW
OUTSIDE BUSINESS ACTIVITY OF WHICH HE WAS REQUIRED TO PROVIDE THE FIRM WITH PROMPT WRITTEN NOTICE; BLAKE-ZUNIGA FAILED TO
PROVIDE THE FIRM WITH THE REQUIRED NOTICE
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):
08/30/2011
 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:
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: 
30 DAY SUSPENSION 9/19/2011 - 10/28/2011
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).
FINRA RULE 2010, NASD RULES 2110, 3030: BLAKE-ZUNIGA FAILED TO PROVIDE PROMPT WRITTEN NOTICE OF AN OUTSIDE BUSINESS ACTIVITY TO HIS
MEMBER FIRM. BLAKE-ZUNIGA FORMED A COMPANY BEFORE BECOMING ASSOCIATED WITH HIS FIRM; ONCE HE BECAME ASSOCIATED WITH HIS FIRM,
HE DISCLOSED THE COMPANY HE FORMED AS AN OUTSIDE BUSINESS ACTIVITY AND DESCRIBED HIS ROLE AS A PASSIVE INVESTOR WITH NO DAY TO
DAY EMPLOYMENT OR MANAGEMENT RESPONSIBILITY. WHILE STILL ASSOCIATED WITH HIS FIRM, BLAKE-ZUNIGA BECAME A DIRECTOR AND THE CEO OF
THE COMPANY. THIS WAS A MATERIAL CHANGE IN THE NATURE OF BLAKE-ZUNIGA'S AFFILIATION WITH HIS COMPANY AND, THEREFORE, A NEW
OUTSIDE BUSINESS ACTIVITY OF WHICH HE WAS REQUIRED TO PROVIDE THE FIRM WITH PROMPT WRITTEN NOTICE; BLAKE-ZUNIGA FAILED TO
PROVIDE THE FIRM WITH THE REQUIRED NOTICE. WITHOUT ADMITTING OR DENYING THE FINDINGS, BLAKE-ZUNIGA CONSENTED TO THE DESCRIBED
SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, HE IS FINED $5,000 AND SUSPENDED FROM ASSOCIATION WITH ANY FINRA MEMBER IN ANY
CAPACITY FOR 30 BUSINESS DAYS. THE SUSPENSION IS IN EFFECT FROM SEPTEMBER 19, 2011, THROUGH OCTOBER 28, 2011.

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:
1014886
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BLAKEZUNIGA, JOHN, AMADOR
(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): 
04/03/2017
 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):
VANGUARD CAPITAL
6.
Principal Product Type:
Other
Other Product Types: 
LEVERAGED/INVERSE ETFS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ADVISORY AFFILIATE ACCUSED OF IMPROPERLY USING LEVERAGED AND/OR INVERSE ETF PRODUCTS DURING 2009-2012 IN CLIENT ACCOUNTS FOR
MORE THAN ONE TRADING PERIOD DESPITE FULL DISCLOSURE AND USE OF SUCH PRODUCTS FOR HEDGING PURPOSES AND NOT IN VIOLATION OF ANY
FIRM POLICIES AND PROCEDURES.

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):
04/03/2017
 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:
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: 
FINRA SUSPENSION UNTIL 02/02/2019
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).
AFTER HAVING RESIGNED FROM HIS ASSOCIATION WITH BROKER DEALER, VANGUARD CAPITAL, A FINRA REGULATED FIRM IN DECEMBER 2016; MR.
BLAKE-ZUNIGA WAS CONDITIONALLY SANCTIONED WITH A $25,000 FINE AND TWENTY-TWO MONTH DEFERRED SUSPENSION, SUBJECT TO RE-
ASSOCIATION WITH ANY FINRA REGULATED SECURITIES FIRMS. FINRA ISSUED THIS SANCTION IN APRIL 2017. MR. BLAKE-ZUNIGA HAS NOT BEEN
ASSOCIATED OR AFFILIATED WITH FINRA REGULATED SECURITIES FIRMS SINCE DECEMBER 31, 2016, AND HE HAS NO INTENTION OF RE-ASSOCIATING
IN THE FUTURE. AS A RESULT, THE STATED CONDITIONAL SANCTION IS BEING HELD IN ABEYANCE. FINRA INITIATED ITS SANCTIONS RELATING TO
SUITABILITY ISSUES RELATING TO LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS, AND FOR FAILING TO DISCLOSE LOANS ORIGINATED BY
CLIENTS IN VIOLATION OF FIRM POLICY. WHILE MR. BLAKE-ZUNIGA PRESENTED WRITTEN EVIDENCE TO FINRA REGARDING HIS KNOWLEDGE, DUE
DILIGENCE, AND APPROPRIATE SUITABILITY OF LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS FOR HIS CUSTOMERS, AND THE
AUTHORIZATION OF ALL LEVERAGED AND/OR INVERSE EXCHANGE TRADED FUNDS BY HIS SUPERVISING EMPLOYER; FINRA REGULATORS DID NOT
CONCUR WITH HIS ASSESSMENT. WITHOUT ADMITTING OR DENYING THE SPECIFIC FINDINGS PRESENTED BY FINRA, MR. BLAKE-ZUNIGA ENTERED INTO
A CONSENT AGREEMENT WITH IN ORDER TO SETTLE THIS MATTER. .