Ethos Capital Management, 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:
1698379
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
TOTO, STEVEN, JOSEPH
(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 PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES, BUREAU OF SECURITIES COMPLIANCE AND EXAMINATIONS
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/12/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
230022
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
ETHOS CAPITAL MANAGEMENT, 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):
DURING A ROUTINE ANNUAL AUDIT BY THE PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES (PDBS), IT WAS DISCOVERED THAT OUR FEE
AGREEMENT CONTAINED A CLERICAL ERROR. WHILE WE HAD BEEN BILLING CLIENTS ACCORDING TO A TIERED BILLING SCHEDULE, THE LANGUAGE IN
OUR DOCUMENTATION INSTEAD DESCRIBED A BREAKPOINT FEE SCHEDULE. AS A RESULT, THE DEPARTMENT CONCLUDED THAT WE WERE
OVERCHARGING CLIENTS BASED ON THE DOCUMENT'S WORDING. TEN CLIENTS WERE AFFECTED, AND WE PROMPTLY CONTACTED EACH OF THEM TO
CONFIRM THEIR UNDERSTANDING OF THE BILLING METHOD. NO CLIENT PAID US MORE MONEY THAN THEY WERE LEGALLY REQUIRED TO PAY US, AND
NO FEES WERE REQUIRED TO BE REFUNDED. FURTHER, ALL OF THE TEN AFFECTED CLIENTS CONFIRMED THAT THEY WERE FULLY AWARE OF THE
ARRANGEMENT, SINCE THE ACTUAL FEE STRUCTURE WAS CLEARLY REFLECTED IN BOTH THEIR CUSTODIAL ACCOUNT STATEMENTS AND SEPARATE
MONTHLY BILLING STATEMENTS SENT BY MAIL TO THEM. ALTHOUGH NO CLIENTS WERE HARMED OR MISLED, THE PDBS INSISTED ON IMPOSING A
PENALTY UPON US FOR THE CLERICAL DISCREPANCY. DURING NEGOTIATIONS, THE PDBS SOFTENED ITS POSITION ON THE OVERCHARGING
ACCUSATION, BUT, NONETHELESS, REFUSED TO DISMISS THE CHARGE ENTIRELY. ON 3/10/2025, I ULTIMATELY, AGREED TO RESOLVE THE MATTER BY
ACCEPTING A FINE, NOT FOR OVERBILLING, BUT FOR NOT HAVING A WRITTEN SUCCESSION PLAN IN PLACE AS PART OF THE NEGOTIATED SETTLEMENT.
THE CONSENT AGREEMENT AND ORDER RECEIVED FINAL APPROVAL ON MAY 29, 2025.
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):
05/29/2025
 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:
NA
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: 
STEVE TOTO PAID THE FIRST INSTALLMENT OF THE ASSESSMENT, ($8,750), ON JUNE 24, 2025. THE SECOND INSTALLMENT OF THE ASSESSMENT
($8,750) WAS MADE ON DECEMBER 16, 2025.
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).
ON 3/10/2025, STEVEN TOTO, WITHOUT ADMITTING FAULT, AGREED TO RESOLVE THE MATTER BY ACCEPTING A FINE, NOT FOR OVERBILLING WHICH
WAS THE ORIGINAL ISSUE, BUT FOR NOT HAVING WRITTEN PROCEDURES RELATING TO THE BUSINESS CONTINUITY AND SUCCESSION PLAN REQUIRED
UNDER REGULATION 304.012(A)(24), 10 PA. CODE § 304.01, AS PART OF THE NEGOTIATED SETTLEMENT. THE CONSENT AGREEMENT ERNTERED INTO
BY TOTO AND PENNSYLVANIA RECEIVED FINAL APPROVAL ON 5/29/2025.