Cutter Financial Group 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 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:
4733298
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CUTTER, JEFFREY, THOMAS
(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 & EXCHANGE COMMISSION
2.
Principal Relief Sought:
Injunction
Other Relief Sought: 
DISGORGEMENT, PREJUDGMENT INTEREST, CIVIL PENALTY
3.
Filing Date of Court Action (MM/DD/YYYY):
03/17/2023
 Exact
 Explanation
If not exact, provide explanation:

4.
Principal Product Type:
Annuity(ies) - Fixed
Other Product Types: 
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): 
FEDERAL DISTRICT COURT, DISTRICT OF MASSACHUSETTS; BOSTON, MASSACHUSETTS; CASE 1:23-CV-10589.
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
HORTER INVESTMENT MANAGEMENT, LLC (10/2011-02/2015); VANN EQUITY MANAGEMENT, LLC (FORMERLY PRECISION CAPITAL MANAGEMENT)
(01/2015 - 09/2017); CUTTER FINANCIAL GROUP (REGISTRANT) (09/2017-PRESENT)
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
THE SEC ALLEGES THAT CUTTER FINANCIAL GROUP AND MR. CUTTER FAILED TO ADEQUATELY DISCLOSE COMPENSATION ARRANGEMENTS AND
CONFLICTS OF INTEREST RELATED TO COMMISSIONS RECEIVED FROM SELLING ANNUITIES TO ADVISORY CLIENTS AND FREE MARKETING AND OTHER
BENEFITS PROVIDED BY THIRD PARTY MARKETING FIRMS AND THAT, IN A SMALL SUBSET OF CASES, MR. CUTTER RECOMMENDED FIXED INDEXED
ANNUITY REPLACEMENT TRANSACTIONS TO GENERATE COMMISSIONS RATHER THAN TO BENEFIT THE CLIENTS
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): 
N/A
10. If pending, date notice/process was served (MM/DD/YYYY):
03/17/2023
 Exact
 Explanation
If not exact, provide explanation:
SERVICE COMPLETED BY CONSENT AT A LATER DATE.
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
12. Resolution Date (MM/DD/YYYY): 
 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: $
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:
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). 
THERE IS A PENDING LEGAL CLAIM. IN SECURITIES AND EXCHANGE COMMISSION V. CUTTER FINANCIAL GROUP AND JEFFREY CUTTER, CASE 1:23-CV-
10589 (DISTRICT OF MASSACHUSETTS), THE SEC ALLEGED THAT CFG AND MR. CUTTER FAILED TO ADEQUATELY DISCLOSE COMPENSATION
ARRANGEMENTS AND CONFLICTS OF INTEREST RELATED TO COMPENSATION RECEIVED FROM SELLING FIXED INDEXED ANNUITIES TO ADVISORY
CLIENTS, ON APRIL 23, 2025, A JURY RETURNED A VERDICT THAT CUTTER FINANCIAL GROUP AND MR. CUTTER DID NOT VIOLATE SECTION 206(1) OF
THE INVESTMENT ADVISERS ACT OF 1940 (INTENTIONAL OR RECKLESS FRAUD), OR ADVISERS ACT SECTION 206(4) AND RULE 206(4)-7 THEREUNDER
(COMPLIANCE POLICIES AND PROCEDURES). THE JURY FOUND A VIOLATION OF ADVISERS ACT SECTION 206(2) (NEGLIGENT DISCLOSURES). THE
COURT HAS NOT DETERMINED WHAT, IF ANY, RELIEF MAY BE AWARDED AND JUDGMENT HAS NOT ISSUED ON ANY CLAIMS. THE CASE, INCLUDING
POSSIBLE APPEALS, IS PENDING.