Syndicated Capital, Inc..

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:
2715226
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
LEE, FAITH
(For individuals, Last, First,
Middle)
CRD
Number:
2173886
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
MCADAMS, JOSEPH, LLOYD
(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: 
PRINCIPALS OF THE FIRM WERE SUSPENSED IN PRINCIPAL CAPACITY FOR TEN BUSINESS DAYS.
3.
Date Initiated (MM/DD/YYYY): 
12/27/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009018524501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
SYNDICATED CAPITAL, INC.
6.
Principal Product Type:
Other
Other Product Types: 
PROMISSORY NOTES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD RULES 2110, 3010, 3040(C): MCADAMS, HIS MEMBER FIRM, AND LEE, FAILED TO REASONABLY SUPERVISE THE PARTICIPATION OF ONE OF THE
FIRM'S REGISTERED REPRESENTATIVES IN PRIVATE SECURITIES TRANSACTIONS THAT THE FIRM HAD RECEIVED PRIOR WRITTEN NOTICE OF AND
APPROVED, AND FAILED TO RECORD THESE TRANSACTIONS ON THE FIRM'S BOOKS AND RECORDS. MCADAMS IS THE CHAIRMAN AND SOLE OWNER OF
THE FIRM. MCADAMS WAS THE PERSON DESIGNATED WITH THE ULTIMATE AUTHORITY TO DETERMINE WHETHER A REGISTERED REPRESENTATIVE AT

THE FIRM COULD ENGAGE IN PRIVATE SECURITIES TRANSACTIONS. MCADAMS, ON BEHALF OF THE FIRM, ENTERED INTO A STOCK PURCHASE
AGREEMENT WITH A BUSINESS ENTITY, OWNED BY A REGISTERED REPRESENTATIVE ASSOCIATED WITH THE FIRM, FOR THE SALE OF 100% OF THE
STOCK OF THE FIRM. IN CONNECTION WITH THIS AGREEMENT, THE REGISTERED REPRESENTATIVE INFORMED MCADAMS AND ANOTHER PRINCIPAL, IN
WRITING AND ORALLY, THAT THE REPRESENTATIVE NEEDED TO RAISE FUNDS TO OPERATE THE BRANCH OFFICE OF THE FIRM WHERE THE
REPRESENTATIVE WAS WORKING, AND IN ORDER TO FINANCE THE PURCHASE OF THE FIRM. AFTER THE EXECUTION OF THE AGREEMENT, MCADAMS
AND THE PRINCIPAL, ACTING ON BEHALF OF THE FIRM, APPROVED OF THE REPRESENTATIVE'S PARTICIPATION IN PRIVATE SECURITIES TRANSACTIONS
TO RAISE MONEY THROUGH THE REPRESENTATIVE'S BUSINESS ENTITY THROUGH THE ISSUANCE OF PROMISSORY NOTES. THE REPRESENTATIVE RAISED
$980,000 FROM THE SALE OF PROMISSORY NOTES ISSUED BY THE REPRESENTATIVE'S BUSINESS ENTITY TO SOME INDIVIDUALS. MCADAMS, HIS FIRM
AND THE PRINCIPAL, FAILED TO SUPERVISE THE REPRESENTATIVE'S PARTICIPATION IN THE PRIVATE SECURITIES TRANSACTIONS AS IF THEY WERE
TRANSACTIONS OF THE FIRM OR IN A MANNER REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE LAWS, RULES AND REGULATIONS THAT
APPLIED TO THE REPRESENTATIVE'S PRIVATE SECURITIES SALES AWAY FROM THE FIRM. MOREOVER, MCADAMS, HIS FIRM, AND THE PRINCIPAL, FAILED
TO ENSURE THAT THE REPRESENTATIVE'S PRIVATE SECURITIES TRANSACTIONS WERE RECORDED ON THE BOOKS OF THE FIRM.
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):
12/27/2011
 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: $ 15,000.00
 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: 
PRINCIPALS OF THE FIRM WERE SUSPENSED IN PRINCIPAL CAPACITY FOR TEN BUSINESS DAYS.
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 CASE IS CLOSED.

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:
29037
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SYNDICATED CAPITAL, 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 CONNECTICUT, DEPARTMENT OF BANKING, SECURITIES AND BUSINESS INVESTMENT DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
SYNDICATED, ITS OFFICERS, REPRESENTATIVES, AGENTS, EMPLOYEES, AND SUCCESSORS IN INTEREST SHALL REFRAIN FROM ENGAGING, DIRECTLY OR
INDIRECTLY, IN CONDUCT CONSTITUTING OR WHICH WOULD CONSTITUTE A VIOLATION OF THE ACT OR ANY REGULATION OR ORDER UNDER THE ACT,
INCLUDING FAILING TO ESTABLISH, ENFORCE AND MAINTAIN A SYSTEM FOR SUPERVISING THE ACTIVITIES OF ITS AGENTS AND ITS CT OFFICE
OPERATIONS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES LAWS.
3.
Date Initiated (MM/DD/YYYY): 
07/15/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CO-14-7988B-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
PROMISSORY NOTES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

FORMER REGISTERED REP, STEPHEN BLANKENSHIP, OFFERED HIGH RATES OF RETURN ON PROMISSORY NOTES. IN REALITY, HE ENGAGED IN A PONZI
SCHEME.
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):
07/15/2014
 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: 
SYNDICATED, IT OFFICERS, REPRESENTATIVES, AGENTS, EMPLOYEES, AFFILIATES, AND SUCCESSORS IN INTEREST SHALL REFRAIN FROM
ENGAGING, DIRECTLY OR INDIRECTLY, IN CONDUCT CONSTITUTING OR WHICH WOULD CONSTITUTE A VIOLATION OF THE ACT OR ANY
REGULATION OR ORDER UNDER THE ACT, INCLUDING FAILING TO ESTABLISH, ENFORCE AND MAINTAIN A SYSTEM FOR SUPERVISING THE
ACTIVITIES OF ITS AGENTS AND ITS CT OFFICE OPERATIONS REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITIES
LAWS.
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).
SYNDICATED CAPITAL REIMBURSED ITS SHARE OF MONEY TO THE VICTIMS. THE CASE IS CLOSED.

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
No Information Filed
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) 
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE, DISGORGEMENT AND RESTITUTION.
3.
Date Initiated (MM/DD/YYYY): 
03/11/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
LA4958
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types: 
MONEY MARKET FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO FULLY DISCLOSE RECEIPT OF 12B1 PAYMENTS IN CONNECTION WITH THE ADVISORY CLIENTS' INVESTMENTS.
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:
Decision & Order of Offer of Settlement

11. Resolution Date (MM/DD/YYYY):
03/27/2019
 Exact
 Explanation
If not exact, provide explanation:
SYNDICATED CAPITAL IS WORKING WITH THE SEC REIMBURSING AFFECTED CLIENTS OF THE 12B1 RECEIVED FROM 2014 THROUGH 2018.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 38,991.35
 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: 
SAME INFORMATION AS 12(A). DATE PAID IS PENDING.
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).
CLIENT ACCOUNTS ARE CODING TO REBATING 12B1 TO THEIR ACCOUNTS.

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
No Information Filed
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) 
NASD
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/03/2006
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
E0220040072-04
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):
FIRM WAS FINED $5000 FOR NET CAPITAL VIOLATION FROM 7/22/04-7/29/04. REF. SECTION 15(C)OF SECURITIES AND EXCHANGE ACT OF 1934(SEC
RULE)AND NASD CONDUCT RULE 2110.
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):
08/03/2006
 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: 

FIRM WAS FINED $5000 FOR NET CAPITAL VIOLATION FROM 7/22/04-7/29/04. TOTAL FINE WAS PAID ON 07/17/2006.
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).
FIRM WAS FINED $5000 FOR NET CAPITAL VIOLATION FROM 7/22/04-7/29/04. REF. SECTION 15(C)OF SECURITIES AND EXCHANGE ACT OF 1934(SEC
RULE)AND NASD CONDUCT RULE 2110. THE NET CAPITAL VIOLATION WAS DUE TO A TRADING ERROR TAKEN INTO AN INVENTORY ACCOUNT BY THE
NEW YORK TRADE DESK.

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
No Information Filed
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) 
CONNECTICUT
2.
Principal Sanction:

Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/14/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
CO-14-7988B-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
SYNDICATED CAPITAL, 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):
ON JULY 14, 2014, THE BANKING COMMISSIONER ENTERED A CONSENT ORDER (NO. CO-14-7988B-S) WITH RESPECT TO SYNDICATED CAPITAL, INC., A
CONNECTICUT-REGISTERED BROKER-DEALER LOCATED AT 1299 OCEAN AVENUE, SECOND FLOOR, SANTA MONICA, CALIFORNIA. FROM 2002 TO 2006,
THE FIRM MAINTAINED A BRANCH OFFICE AT 152 DEER HILL AVENUE, SUITE 203, DANBURY, CONNECTICUT, AND EMPLOYED STEPHEN BURTON
BLANKENSHIP (CRD NUMBER 2234577) AS A REGISTERED BROKER-DEALER AGENT. BLANKENSHIP, THE SOLE MANAGING MEMBER AND CONTROL
PERSON OF DEER HILL FINANCIAL GROUP, LLC, ALSO CONDUCTED TAX PREPARATION, FINANCIAL PLANNING AND INVESTMENT ADVISORY SERVICES
FROM THE DANBURY LOCATION. FOLLOWING ALLEGATIONS OF UNREGISTERED INVESTMENT ADVISORY ACTIVITY, FRAUD AND MISAPPROPRIATION, THE
BANKING COMMISSIONER ENTERED A CONSENT ORDER (DOCKET NO. CO-12-7988-S) WITH RESPECT TO BLANKENSHIP AND DEER HILL FINANCIAL
GROUP, LLC ON AUGUST 31, 2012. THAT CONSENT ORDER REVOKED BLANKENSHIP'S REGISTRATION AS A BROKER-DEALER AGENT AND PERMANENTLY
BARRED BOTH BLANKENSHIP AND DEER HILL FINANCIAL GROUP, LLC FROM TRANSACTING SECURITIES BUSINESS IN OR FROM CONNECTICUT. IN
ADDITION, THE U.S. DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT FINED BLANKENSHIP $7,500, DIRECTED BLANKENSHIP TO MAKE
$607,516.81 IN RESTITUTION AND SENTENCED BLANKENSHIP TO 41 MONTHS IN PRISON FOLLOWING BLANKENSHIP'S GUILTY PLEA TO ONE COUNT OF
FEDERAL MAIL FRAUD AND ONE COUNT OF FEDERAL SECURITIES FRAUD (UNITED STATES OF AMERICA V. STEPHEN BLANKENSHIP, D. CONN. CASE NO.
3:12CR197 (VLB)). THE CONSENT ORDER WITH SYNDICATED CAPITAL, INC. ALLEGED THAT, IN CONTRAVENTION OF SECTION 36B-31-6F OF THE
REGULATIONS UNDER THE CONNECTICUT UNIFORM SECURITIES ACT, THE FIRM FAILED TO ESTABLISH, ENFORCE AND MAINTAIN A SYSTEM FOR
SUPERVISING THE ACTIVITIES OF ITS AGENTS, INCLUDING BLANKENSHIP, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE
SECURITIES LAWS AND REGULATIONS.
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):
07/14/2014
 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:
THE CONSENT ORDER ACKNOWLEDGED THAT SYNDICATED CAPITAL, INC. AND ANOTHER SECURITIES BROKERAGE FIRM HAD REIMBURSED
AFFECTED INVESTORS FOR 100% OF THE FINANCIAL LOSSES THEY INCURRED AS A RESULT OF BLANKENSHIP'S MISCONDUCT. SPECIFICALLY,
SYNDICATED CAPITAL, INC. REPAID AFFECTED INVESTORS $303,758.20. IN RESOLUTION OF THE MATTER, THE CONSENT ORDER FINED
SYNDICATED CAPITAL, INC. $10,000 AND DIRECTED THE FIRM TO REFRAIN FROM REGULATORY VIOLATIONS.
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: 
SEE RESPONSE TO ITEM 12B

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).