Summit Financial, 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 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:
11039
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SUMMIT EQUITIES 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) 
FINRA
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CENSURE
3.
Date Initiated (MM/DD/YYYY): 
05/01/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2015043159201
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Annuity(ies) - Variable
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REASONABLY SUPERVISE ITS REGISTERED REPRESENTATIVES' RECOMMENDATIONS OF MULTI-SHARE CLASS VARIABLE ANNUITIES (VAS) TO CUSTOMERS
AND FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A REASONABLE SUPERVISORY SYSTEM AND PROCEDURES RELATED TO THE SALE AND SUITABILITY
OF SUCH SECURITIES, INCLUDING SALES OF L-SHARE CONTRACTS. THE FINDINGS ALSO STATE THAT THE FIRM FAILED TO PROVIDE TRAINING TO ITS
REGISTERED REPRESENTATIVES AND PRINCIPALS ON THE SALE AND SUPERVISION OF MULTI-SHARE CLASS VAS AND THE SALE OF LONG-TERM INCOME
RIDERS WITH MULTI-SHARE CLASS VAS. THE FIRM DID NOT PROVIDE TRAINING OR GUIDANCE TO REGISTERED REPRESENTATIVES ON THE FEATURES OF
VARIOUS SHARE CLASSES AND THE ASSOCIATED FEES AND SURRENDER CHARGES, AND DID NOT PROVIDE THEM WITH ADEQUATE INFORMATION TO
COMPARE SHARE CLASSES TO MAKE SUITABILITY DETERMINATIONS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE THE

PRIVATE SECURITIES TRANSACTIONS OF A REGISTERED REPRESENTATIVE. THE FIRM ALLOWED THE REGISTERED REPRESENTATIVE TO FORM A SEPARATE
BROKER-DEALER. THE FIRM FAILED TO ADEQUATELY SUPERVISE THE REGISTERED REPRESENTATIVE'S ACTIVITIES THROUGH THE SEPARATE BROKER-
DEALER AND FAILED TO ENSURE THAT HE COMPLIED WITH RESTRICTIONS IMPOSED BY THE FIRM. IN ADDITION, THE FIRM FAILED TO DETECT SEVERAL
RED FLAGS THAT SHOULD HAVE ALERTED IT TO THE REGISTERED REPRESENTATIVE'S ACTIVITY.
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):
05/01/2017
 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: $ 325,000.00
 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: 
THE FIRM WAS CENSURED AND FINED $325,000.
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).
SUMMIT HAS SIGNIFICANTLY EXPANDED AND ENHANCED ITS MANAGEMENT, COMPLIANCE, SUPERVISORY AND LEGAL PERSONNEL AS WELL AS ITS
OVERALL COMPLIANCE AND SUPERVISORY STRUCTURES AND TRAINING PROGRAMS. NOTWITHSTANDING THIS AWC'S FINDINGS THAT THE FIRM'S
SUPERVISION AND TRAINING REGARDING VA SHARE CLASSES WAS INADEQUATE, WHICH SUMMIT DOES NOT DISPUTE, SUMMIT BELIEVES THAT THE RRS
DID MAKE APPROPRIATE SUITABILITY DETERMINATIONS REGARDING THE SHARE CLASSES THEY RECOMMENDED TO THEIR VA CLIENTS. FURTHER, SUMMIT
EQUITIES NO LONGER PERMITS RRS TO ASSOCIATE WITH ANY BROKERAGE FIRM OTHER THAN SUMMIT.

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:
11039
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
SUMMIT EQUITIES, 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) 
COMMONWEALTH OF MASSACHUSETTS SECURITIES DIVISION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
CEASE AND DESIST AND OTHER REMEDIAL ACTIONS
3.
Date Initiated (MM/DD/YYYY): 
12/26/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
R-2018-0083
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):
ALLEGED FAILURE TO REASONABLY SUPERVISE REGISTERED REPRESENTATIVES(AS DEFINED BY MA LAWS) TO ASSURE COMPLIANCE WITH MA PRIVACY
LAWS, RESULTING IN VIOLATION OF MASS.GEN.LAWS. CH110A, SECTION 204(A)(2)(J)
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:
Settled
11. Resolution Date (MM/DD/YYYY):
12/26/2018
 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: $ 100,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
SUMMIT AGREED TO CERTIFY THE STEPS IT TOOK TO ENSURE DEPARTING REGISTERED REPRESENTATIVES ABIDED BY SUMMIT'S POLICIES
PROHIBITING THEM FROM TAKING CUSTOMER PERSONAL INFORMATION; NOTIFY POTENTIALLY IMPACTED MA CUSTOMERS THAT THEIR
INFORMATION MAY HAVE BEEN COMPROMISED; AND PROVIDE MA WITH DETAILED INFORMATION REGARDING CERTAIN FORMER REGISTERED
REPRESENTATIVES WHO USE EXTERNAL CRMS AND HOW SUMMIT PREVENTED SUCH REGISTERED REPRESENTATIVES FROM VIOLATING SUMMIT'S
POLICIES TO PROTECT CUSTOMER INFORMATION.
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: 
A FINE OF $100,00 WAS IMPOSED ON SUMMIT EQUITIES AND PAID IN FULL IN DECEMBER 2018
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 FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO REASONABLY SUPERVISE ITS DEPARTING REGISTERED
REPRESENTATIVES TO ASSURE COMPLIANCE WITH MA PRIVACY LAWS. EVEN THOUGH THE FIRM HAD ADOPTED A POLICY REQUIRING ALL REGISTERED
REPRESENTATIVES DEPARTING THE FIRM FOR ANY REASON TO RETURN AND NOT RETAIN COPIES OF ANY RECORDS AND FILES CONTAINING FIRM
CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION, AND REQUIRED REGISTERED REPRESENTATIVES TO COMPLETE VARIOUS FORMS OF TRAINING IN
THIS REGARD, IT PERMITTED ITS REGISTERED REPRESENTATIVES TO USE THIRD-PARTY CONTACT OR CUSTOMER RELATIONSHIP MANAGEMENT SYSTEMS
OVER WHICH THE FIRM DID NOT HAVE ACCESS OR CONTROL. REGISTERED REPRESNTATIVES USING THESE SYSTEMS INPUT FIRM CUSTOMERS'
INFORMATION IN SUCH SYSTEM, AND AS A RESULT OF THE FIRM NOT HAVING ACCESS TO THESE SYSTEMS, THE FIRM WAS NOT ABLE TO (I) MONITOR OR
CONTROL THE USERS OF EACH SYSTEM IN ORDER TO PREVENT ACCESS BY OR SHARING WITH UNAUTHORIZED PERSONS, (II) MONITOR OR CONTROL THE
INFORMATION THAT REGISTERED REPRESENTATIVES INPUT INTO THE SYSTEMS TO PREVENT UNAUTHORIZED SHARING OF FIRM CUSTOMERS' PERSONALLY
IDENTIFIABLE INFORMATION, OR (III) REMOTELY WIPE OR OTHERWISE REMOVE ITS CUSTOMERS' PERSONALLY IDENTIFIABLE INFORMATION WITHIN
THOSE SYSTEMS AS NEEDED, SUCH AS WHEN REGISTERED REPRESENTATIVES DEPARTED THE FIRM. AS OF DECEMBER 26, 2018, THE FIRM HAS FINALIZED
ITS SETTLEMENT WITH MA.