RIA profile

Independence Square Holdings, LLC

KING OF PRUSSIA, PACRD 300139Registration Status: ApprovedEffective since June 7, 2019SEC # 801-116750Latest Form ADV October 7, 2026
Assets Under Management
$1.8B
Employees
37
Offices
14 offices
Total Clients
2,648

Independence Square Holdings, LLC's Form ADV filing dated 2026-10-07 reports $1,833,978,825 in regulatory assets under management, $1,833,229,303 discretionary and $749,522 non-discretionary, 2,648 accounts, and 37 employees.

Associated firm names

12 names listed
  • BARNES LANE ADVISORS LLC
  • TOUEY & COMPANY
  • THE PLAN ADVOCATE
  • STRATAVEST

Leadership

2 roles identified
CCOKaleb M. Burns
CIOZachary S. Mineur

Advisory services offered

5 types reported
Financial Planning Services
Pension consulting services
Portfolio management for individuals and small businesses

Fee models offered

7 types reported
Asset based fees
Commissions
Fixed fees

Offices & Contact

Primary office

KING OF PRUSSIA, Pennsylvania, United States

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Primary office regionOther reported regions
Pennsylvania

KING OF PRUSSIAPrimary office · PLYMOUTH MEETING

California

CARLSBAD

Maryland

CHESTERTOWN · BALTIMORE

New Jersey

CHERRY HILL · SHORT HILLS

North Carolina

DUCK

Texas

FORT WORTH

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

9 office records listed · 14 total offices reported. 5 additional office addresses are undisclosed and are not mapped. 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$1.8Bas of October 7, 2026
Discretionary100.0%
$1.8B
100% of total RAUM100.0%
Non-discretionary0.0%
$750K
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 58.2% of total clients.
Top client categories% of clientsClients
1
Individuals
58.2%
1,541
2
HNWI
40.8%
1,080
3
Pension Plans
0.5%
13
4
Charitable
0.3%
7
5
Corporations
0.3%
7

Assets Under Management

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

Total AUM$1.8B
Total Accounts2,648
10Y AUM Change+$1.8B

Employee Growth by Quarter

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

Total Employees37
Clients per Employee72:1
10Y Employee Change-1 (-2.6%)

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.

Private Funds

Private funds reported by Independence Square Holdings, LLC

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Custodians

Reported custodian relationships by Independence Square Holdings, LLC

  • ( ) y LPL FINANCIAL LLC

    $883,908,445

These custodians are disclosed for separately managed accounts under Form ADV’s 10% reporting threshold. This is not a complete list of custodians for all client assets.


Ownership

Reported direct and indirect relationships by Independence Square Holdings, LLC

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%
JOSEPH BLACK ELLIOTTDirect owner · Schedule AInterest in INDEPENDENCE SQUARE HOLDINGS, LLC
75%+

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 Independence Square Holdings, LLC.

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

Reported ownership and control details

3 entries

Compliance & Disclosures

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 none of the events below involve the firm or its supervised persons.RIA responseNo
AFelonies1 Yes1 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?Yes
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 actions5 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?No
  • 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 actions3 Yes1 No

Has a self-regulatory organization or commodities exchange ever:

  • E1Found you or an advisory affiliate made a false statement or omission?Yes
  • 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?Yes
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 2 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.

criminal · block 1PDF pages 30–31
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.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
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. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
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:
8013768
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Scherzer, Adam, Jason
(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.
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.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
PLYMOUTH TOWNSHIP CONSHOHOCKEN BOROUGH, MAGISTERIAL DISTRICT COURT 38-1-13, DOCKET NUMBER: MJ-38113-CR-0000547-2024
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
12/21/2024
 Exact
 Explanation
If not exact, provide explanation:
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
CHARGE: TITLE 18 PA C.S. 2706(A)1 TERRORISTIC THREATS [M1] PLEA: NOT GUILTY CHARGE: TITLE 18 PA C.S. 2709(A)4 HARASSMENT [M3] PLEA:
NOT GUILTY CHARGE: TITLE 18 PA C.S. 2702(A)4 AGGRAVATED ASSAULT [F2] PLEA: NOT GUILTY CHARGE: TITLE 18 PA C.S. 2701(A)3 SIMPLE
ASSAULT [M2] PLEA: NOT GUILTY CHARGE: TITLE 18 PA C.S. 2705 RECKLESSLY ENDANGERING ANOTHER PERSON [M2] PLEA: NOT GUILTY
CHARGE: TITLE 18 PA C.S. 5503(A)1 DISORDERLY CONDUCT [M3] PLEA: NOT GUILTY
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
CHARGE: TITLE 18 PA C.S. 2706(A)1 TERRORISTIC THREATS [M1] DISPOSITION: PRETRIAL AS OF: 02/25/2025 CHARGE: TITLE 18 PA C.S. 2709(A)4
HARASSMENT [M3] DISPOSITION: PRETRIAL AS OF: 02/25/2025 CHARGE: TITLE 18 PA C.S. 2702(A)4 AGGRAVATED ASSAULT [F2] DISPOSITION:
CHARGES DISMISSED AS OF: 02/25/2025 CHARGE: TITLE 18 PA C.S. 2701(A)3 SIMPLE ASSAULT [M2] DISPOSITION: PRETRIAL AS OF: 02/25/2025
CHARGE: TITLE 18 PA C.S. 2705 RECKLESSLY ENDANGERING ANOTHER PERSON [M2] DISPOSITION: CHARGES DISMISSED AS OF: 02/25/2025 CHARGE:
TITLE 18 PA C.S. 5503(A)1 DISORDERLY CONDUCT [M3] DISPOSITION: PRETRIAL AS OF: 02/25/2025
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
THE PLAINTIFF CAME UP BEHIND MY VEHICLE TO MAKE AN ILLEGAL PASS OVER A DOUBLE YELLOW LINE, ALMOST INTO AN ONCOMING CAR. THE
PLAINTIFF CAME VERY CLOSE TO CAUSING A HEAD ON COLLISION. THE PLAINTIFF PROCEEDED TO CUT ME OFF. THEN AT A RED LIGHT, WE HAD
WORDS, AND THE PLAINTIFF CHALLENGED ME TO FIGHT. WHEN I DECLINED, THE PLAINTIFF SPED UP TO ME AT ANOTHER RED LIGHT AND PROCEEDED
TO TELL ME HE WOULD FOLLOW ME BACK TO MY HOUSE. I TOLD HIM THAT I HAVE A LICENSE TO CARRY, AND THAT I WAS ARMED, AND NOT TO
FOLLOW ME; I TOLD HIM TO GO HOME. I THEN PULLED OFF THE ROAD AND THE PLAINTIFF CALLED THE POLICE. THE PLAINTIFF CLAIMED THAT I
POINTED A GUN AND THREATENED HIM. WHEN I PULLED UP TO MY HOUSE, THE POLICE ARRESTED ME. I HAD EXPLAINED TO THE OFFICER WHAT HAD
HAPPENED, AND I ASKED WHY I WAS IN THE ONE WHO WAS IN TROUBLE, WHEN HE WAS THE ONE WHO THREATENED ME, THEY SAID IT WAS BECAUSE
THE PLAINTIFF WAS THE ONE WHO CALLED THE POLICE AND I HADN'T. THEY SAID IF I CALLED, IT WOULD HAVE BEEN A DIFFERENT STORY.
regulatory · block 1BATANSKY, NORMAN, STANLEYPDF pages 31–33
Advisory affiliate name — filed text
BATANSKY, NORMAN, STANLEY
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 7,500.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

ACCEPTANCE, WAIVER AND CONSENT WAS ENTERED INTO AS A FINAL ORDER. THIS INVOLVED A 30 DAY SUSPENSION, PENALTIES, AND FINES. THIS HAS SENSE BEEN SATISFIED, SUSPENSION WAS SERVED 11/16/2020 - 12/15/2020.
Other filed details

Description of allegations — filed text

WITHOUT ADMITTING OR DENYING THE FINDINGS, BATANSKY CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED IN A PRIVATE SECURITIES TRANSACTION BY FACILITATING A $50,000 INVESTMENT BY HIS SON, IN A CONVERTIBLE PROMISSORY NOTE, WITHOUT PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. THE FINDINGS STATED THAT BATANSKY FORWARDED HIS SON, A FIRM CUSTOMER, AN EMAIL CONCERNING AN INVESTMENT OPPORTUNITY IN A PRIVATELY HELD MEDICAL DEVICE COMPANY. ATTACHED TO THE EMAIL WAS AN INVESTOR OVERVIEW, CONVERTIBLE NOTE TERM SHEET AND A SUBSCRIPTION AGREEMENT. USING HIS PERSONAL EMAIL ACCOUNT, BATANSKY SENT THE COMPANY'S PLACEMENT AGENT HIS SON'S RESIDENTIAL ADDRESS AND DATE OF BIRTH. BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO INFORM THE PLACEMENT AGENT THAT HIS SON "WILL DO $50,000 OF THE COMPANY." BATANSKY ASKED HIS SALES ASSISTANT TO EMAIL THE PLACEMENT AGENT A SCANNED COPY OF HIS SON'S SIGNED SUBSCRIPTION AGREEMENT FOR HIS $50,000 INVESTMENT, A COMPLETED INVESTOR PROFILE AND QUESTIONNAIRE, AND A W-9 TAX FORM. BATANSKY THEREAFTER ARRANGED THROUGH HIS BRANCH OFFICE'S OPERATIONS DEPARTMENT TO WIRE $50,000 FROM HIS SON'S BROKERAGE ACCOUNT TO HIS PERSONAL BANK ACCOUNT. BATANSKY PREPARED AND EMAILED HIS SON A DRAFT LETTER OF INSTRUCTION TO HIS BANK TO WIRE $50,000 FROM HIS ACCOUNT TO THE COMPANY'S BANK ACCOUNT. BATANSKY'S SON COMPLETED HIS $50,000 INVESTMENT IN THE COMPANY. BATANSKY DID NOT RECEIVE ANY COMPENSATION IN CONNECTION WITH HIS SON'S INVESTMENT. BATANSKY FALSELY ATTESTED IN A COMPLIANCE QUESTIONNAIRE THAT HE HAD NOT PARTICIPATED IN ANY PRIVATE SECURITIES TRANSACTIONS. THE FINDINGS ALSO STATED THAT BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO SEND A TOTAL OF 32 SECURITIES-RELATED EMAILS THAT WERE NOT MONITORED OR RETAINED BY THE FIRM. BATANSKY ATTESTED IN COMPLIANCE QUESTIONNAIRES THAT HE UNDERSTOOD THAT HE MUST USE FIRM OR APPROVED EMAIL ADDRESSES FOR ALL BUSINESS-RELATED COMMUNICATIONS WITH ALL CLIENTS AND PROSPECTS.

Sanction detail — filed text

30 DAY SUSPENSION FOR ALL CAPACITIES. FINES AND PENALTIES TOTALING $7,500.00
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
CRD
Number:
834388
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BATANSKY, NORMAN, STANLEY
(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: 
CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) OF $7,500.00
3.
Date Initiated (MM/DD/YYYY): 
10/23/2020
 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):
PEAK BROKERAGE SERVICES, LLC
6.
Principal Product Type:
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, BATANSKY CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE PARTICIPATED
IN A PRIVATE SECURITIES TRANSACTION BY FACILITATING A $50,000 INVESTMENT BY HIS SON, IN A CONVERTIBLE PROMISSORY NOTE, WITHOUT
PROVIDING PRIOR WRITTEN NOTICE TO HIS MEMBER FIRM. THE FINDINGS STATED THAT BATANSKY FORWARDED HIS SON, A FIRM CUSTOMER, AN EMAIL
CONCERNING AN INVESTMENT OPPORTUNITY IN A PRIVATELY HELD MEDICAL DEVICE COMPANY. ATTACHED TO THE EMAIL WAS AN INVESTOR
OVERVIEW, CONVERTIBLE NOTE TERM SHEET AND A SUBSCRIPTION AGREEMENT. USING HIS PERSONAL EMAIL ACCOUNT, BATANSKY SENT THE
COMPANY'S PLACEMENT AGENT HIS SON'S RESIDENTIAL ADDRESS AND DATE OF BIRTH. BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO INFORM
THE PLACEMENT AGENT THAT HIS SON "WILL DO $50,000 OF THE COMPANY." BATANSKY ASKED HIS SALES ASSISTANT TO EMAIL THE PLACEMENT
AGENT A SCANNED COPY OF HIS SON'S SIGNED SUBSCRIPTION AGREEMENT FOR HIS $50,000 INVESTMENT, A COMPLETED INVESTOR PROFILE AND
QUESTIONNAIRE, AND A W-9 TAX FORM. BATANSKY THEREAFTER ARRANGED THROUGH HIS BRANCH OFFICE'S OPERATIONS DEPARTMENT TO WIRE
$50,000 FROM HIS SON'S BROKERAGE ACCOUNT TO HIS PERSONAL BANK ACCOUNT. BATANSKY PREPARED AND EMAILED HIS SON A DRAFT LETTER OF
INSTRUCTION TO HIS BANK TO WIRE $50,000 FROM HIS ACCOUNT TO THE COMPANY'S BANK ACCOUNT. BATANSKY'S SON COMPLETED HIS $50,000
INVESTMENT IN THE COMPANY. BATANSKY DID NOT RECEIVE ANY COMPENSATION IN CONNECTION WITH HIS SON'S INVESTMENT. BATANSKY FALSELY
ATTESTED IN A COMPLIANCE QUESTIONNAIRE THAT HE HAD NOT PARTICIPATED IN ANY PRIVATE SECURITIES TRANSACTIONS. THE FINDINGS ALSO
STATED THAT BATANSKY USED HIS PERSONAL EMAIL ACCOUNT TO SEND A TOTAL OF 32 SECURITIES-RELATED EMAILS THAT WERE NOT MONITORED OR
RETAINED BY THE FIRM. BATANSKY ATTESTED IN COMPLIANCE QUESTIONNAIRES THAT HE UNDERSTOOD THAT HE MUST USE FIRM OR APPROVED EMAIL
ADDRESSES FOR ALL BUSINESS-RELATED COMMUNICATIONS WITH ALL CLIENTS AND PROSPECTS.
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):
12/15/2020
 Exact
 Explanation
If not exact, provide explanation:
SUSPENSION END DATE
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 7,500.00
 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: 
30 DAY SUSPENSION FOR ALL CAPACITIES. FINES AND PENALTIES TOTALING $7,500.00
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).
ACCEPTANCE, WAIVER AND CONSENT WAS ENTERED INTO AS A FINAL ORDER. THIS INVOLVED A 30 DAY SUSPENSION, PENALTIES, AND FINES. THIS
HAS SENSE BEEN SATISFIED, SUSPENSION WAS SERVED 11/16/2020 - 12/15/2020.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix database. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.