Firm profile

Continental Investors Services, Inc..

LONGVIEW, WACRD 29775Registration Status: ApprovedEffective since November 22, 2021SEC # 801-122737Latest ADV September 24, 2026

Continental Investors Services, Inc. is an SEC registered investment adviser organized as a corporation with a primary office location in Longview, WA. Its latest Form ADV filing, dated September 24, 2026, reports $232M in regulatory assets under management, 14 employees, 2 offices, and 824 accounts.

Assets Under Management
$232M
Employees
14
Offices
2 offices
Total Clients
605

Associated firm names

2 names listed
  • CIS-WEALTH MANAGEMENT-A DIVISION OF CIS
  • CONTINENTAL INVESTORS SERVICES, INC.

Leadership

3 roles identified
CEOMax Bryan Kamp
CCOMax Bryan Kamp
CFOMichelle Francis Elo

Advisory services offered

2 types reported
Other advisory services
Portfolio management for individuals and small businesses

Fee models offered

2 types reported
Asset based fees
Commissions

Offices & Contact

Primary office

LONGVIEW, Washington, United States

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Primary office regionOther reported regions

Shading shows states and countries with reported offices. Cities are listed below; shading does not indicate service coverage.

Washington

LONGVIEWPrimary office

Idaho

CALDWELL

2 office records listed · 2 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$232Mas of September 24, 2026
Discretionary100.0%
$232M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 99.5% of total clients.
Top client categories% of clientsClients
1
Individuals
99.5%
602
2
Charitable
0.5%
3
Categories with <5 clients
Charitable Organizations<5 clients

Assets under management Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total AUM$232M
Total Accounts824
10Y AUM Change+$132M (+131.1%)

Private Funds

Private funds reported by Continental Investors Services, Inc..

Loading private fund disclosures…

Employee Growth by Quarter

Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.

Total Employees14
Clients per Employee43:1
10Y Employee Change-2 (-12.5%)

Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.


Ownership

Reported direct and indirect ownership ranges

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
MAX BRYAN KAMPDirect owner · Schedule AInterest in CONTINENTAL INVESTORS SERVICES, INC.
50% to < 75%
BETTY JANE TREMBLEYDirect owner · Schedule AInterest in CONTINENTAL INVESTORS SERVICES, INC.
25% to < 50%

Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Continental Investors Services, Inc...

No indirect ownership information reported in the source’s Schedule B.

Reported ownership and control details

Form ADV · Filing date 2026-09-24 · Schedules A and B

3 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1MAX BRYAN KAMPPRESIDENT, CEO/DIRECTOR,CCOIndividualCONTINENTAL INVESTORS SERVICES, INC.50% to less than 75%Code DYesPRESIDENT, CEO/DIRECTOR,CCO06/2013Schedule APDF page 20
2BETTY JANE TREMBLEYSHAREHOLDERIndividualCONTINENTAL INVESTORS SERVICES, INC.25% to less than 50%Code CNoSHAREHOLDER12/1993Schedule APDF page 20
3MICHELLE FRANCIS ELOCHIEF FINANCIAL OFFICERIndividualCONTINENTAL INVESTORS SERVICES, INC.Less than 5%Code NAYesCHIEF FINANCIAL OFFICER01/2023Schedule APDF page 20

Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.

Compliance & Disclosures

Filing dated 9/24/2026 3:32:54 PM

Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No

In the past ten years, have you or any advisory affiliate:

  • A1Been convicted of or pleaded guilty or no contest to a felony?No
  • A2Been charged with a felony?No
BMisdemeanors2 No

In the past ten years, have you or any advisory affiliate:

  • B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
  • B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions5 No

Has the SEC or CFTC ever:

  • C1Found you or an advisory affiliate made a false statement or omission?No
  • C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?No
  • C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • C4Entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?No
DOther regulatory actions1 Yes4 No

Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:

  • D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
  • D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
  • D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
  • D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?No
  • E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
  • E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
  • E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 3 source blocks

Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.

regulatory · block 1PDF pages 20–22
Regulator name — filed text
STATE OF NEW MEXICO
Monetary/Fine Amount — filed text
$ 500.00
How was matter resolved — filed text
Other

Action status / disposition — filed text

UNDERTAKING SIGNED AND APPROVED ON 10-17-2000. CHECK NO. 9744 IN THE AMOUNT OF $500.00 DATED 10-03-2000. PROOF OF RESCISSION OFFER, DATED 10-3-2000.
Other filed details

Description of allegations — filed text

THE FIRM EXECUTING A TRADE IN THE ACCOUNT OF NEW MEXICO RESIDENT, DAVID LUND, PRIOR TO BEING LICENSE IN NEW MEXICO.

Sanction detail — filed text

THE FIRM PAID A $500.00 CIVIL PENALTY ON 10/03/2000. NONE OF THE PENALTY WAS WAIVED. THE FIRM SIGNED A "UNDERTAKING" WITH THE STATE OF NEW MEXICO AND COMPLETED A RESCISSION OFFER FOR DAVID LUND.
Full extracted filing text

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) 
STATE OF NEW MEXICO
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/13/2000
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2000-2000-998 (UN)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Debt - Municipal

Other Product Types: 
DEBT-CORPORATE, MUTUAL FUNDS, EQUITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FIRM EXECUTING A TRADE IN THE ACCOUNT OF NEW MEXICO RESIDENT, DAVID LUND, PRIOR TO BEING LICENSE IN NEW MEXICO.
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:
Other
11. Resolution Date (MM/DD/YYYY):
10/17/2000
 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: $ 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: 
THE FIRM PAID A $500.00 CIVIL PENALTY ON 10/03/2000. NONE OF THE PENALTY WAS WAIVED. THE FIRM SIGNED A "UNDERTAKING" WITH THE
STATE OF NEW MEXICO AND COMPLETED A RESCISSION OFFER FOR DAVID LUND.
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).
UNDERTAKING SIGNED AND APPROVED ON 10-17-2000. CHECK NO. 9744 IN THE AMOUNT OF $500.00 DATED 10-03-2000. PROOF OF RESCISSION
OFFER, DATED 10-3-2000.
regulatory · block 2PDF pages 22–24
Regulator name — filed text
FINRA MARKET REGULATION
Monetary/Fine Amount — filed text
$ 35,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

RESTITUTION AND INTEREST WAS PAID ON 4-21-2011 TO NINE CUSTOMERS WHO WERE INCORRECTLY CHARGED. FINE OF $35,000 WAS PAID ON 8- 23-2011.
Other filed details

Description of allegations — filed text

VIOLATION OF MSRB RULE G-17,G-30(A)AND G-27.FIRM SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE. TAKING INTO CONSIDERATION ALL RELEVANT FACTORS, INCLUDING THE BEST JUDGMENT OF THE FIRM AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT THAT THE FIRM IS ENTITLED TO A PROFIT AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE FOR SUPERVISION REASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITES LAWS, REGULATIONS AND MSRB RULES CONCERNING FAIR PRICING FOR MUNCIPAL SECURITIES TRANSACTIONS.

Sanction detail — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE, THE FIRM IS CENSURED, FINED $35,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR PRICING FOR MUNICIPAL SECURITIES TRANSACTIONS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC FOR VIOLATION OF MSRB RULES G-17,G-27 AND G-30(A).
Full extracted filing text

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) 
FINRA MARKET REGULATION
2.
Principal Sanction:
Censure
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
08/14/2011
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2009018104501
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
CONTINENTAL INVESTORS SERVICES, INC.
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF MSRB RULE G-17,G-30(A)AND G-27.FIRM SOLD MUNICIPAL SECURITIES FOR ITS OWN ACCOUNT TO A CUSTOMER AT AN AGGREGATE
PRICE (INCLUDING ANY MARKDOWN OR MARKUP) THAT WAS NOT FAIR AND REASONABLE. TAKING INTO CONSIDERATION ALL RELEVANT FACTORS,
INCLUDING THE BEST JUDGMENT OF THE FIRM AS TO THE FAIR MARKET VALUE OF THE SECURITIES AT THE TIME OF THE TRANSACTION AND OF ANY
SECURITIES EXCHANGED OR TRADED IN CONNECTION WITH THE TRANSACTION, THE EXPENSE INVOLVED IN EFFECTING THE TRANSACTION, THE FACT
THAT THE FIRM IS ENTITLED TO A PROFIT AND THE TOTAL DOLLAR AMOUNT OF THE TRANSACTION. THE FIRM'S SUPERVISORY SYSTEM DID NOT PROVIDE
FOR SUPERVISION REASONABLE DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE SECURITES LAWS, REGULATIONS AND MSRB RULES
CONCERNING FAIR PRICING FOR MUNCIPAL SECURITIES TRANSACTIONS.
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):
08/14/2011
 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: $ 35,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS CENSURED, FINED $35,000 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR
PRICING FOR MUNICIPAL SECURITIES TRANSACTIONS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC FOR VIOLATION OF
MSRB RULES G-17,G-27 AND G-30(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).
RESTITUTION AND INTEREST WAS PAID ON 4-21-2011 TO NINE CUSTOMERS WHO WERE INCORRECTLY CHARGED. FINE OF $35,000 WAS PAID ON 8-
23-2011.
regulatory · block 3PDF pages 24–26
Regulator name — filed text
NASD
Monetary/Fine Amount — filed text
$ 5,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

FIRM DID REPORT TRACE ELIGIBLE SECURITIES TRADES, HOWEVER, DURING THE PERIOD OF AUGUST 1, 2002 THROUGH SEPTEMBER 30, 2002 734 TRANSACTIONS WERE REPORTED AFTER THE 75 MINUTE REPORTING REQUIREMENT.
Other filed details

Description of allegations — filed text

CIS WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS FAILED TO REPORT TRACE ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER EXECUTION.

Sanction detail — filed text

FINE IN THE AMOUNT OF $5,000 TO BE PAID BY CREDIT CARD FOR THE FULL AMOUNT.
Full extracted filing text

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:
Other
Other Sanctions: 
LETTER OF ACCEPTANCE,WAIVER AND CONSENT ISSUED BY DEPARTMENT OF MARKET REGULATION AND A $5,000.00 FINE.
3.
Date Initiated (MM/DD/YYYY): 
11/20/2003
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
MRD200238481
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
MUNCIPAL BONDS, MUTUAL FUNDS AND EQUITIES
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
CIS WITHOUT ADMITTING OR DENYING THE ALLEGATIONS OR FINDINGS FAILED TO REPORT TRACE ELIGIBLE SECURITIES WITHIN 75 MINUTES AFTER
EXECUTION.
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):
12/23/2003
 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: 
FINE IN THE AMOUNT OF $5,000 TO BE PAID BY CREDIT CARD FOR THE FULL AMOUNT.
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 DID REPORT TRACE ELIGIBLE SECURITIES TRADES, HOWEVER, DURING THE PERIOD OF AUGUST 1, 2002 THROUGH SEPTEMBER 30, 2002 734
TRANSACTIONS WERE REPORTED AFTER THE 75 MINUTE REPORTING REQUIREMENT.

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