Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Polus Capital Management (Us) Inc..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
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
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
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 Polus Capital Management (Us) Inc...
Reported ownership and control details
Form ADV · Filing date 2026-03-31 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | POLUS CAPITAL MANAGEMENT GROUP LIMITEDSHAREHOLDERForeign entity | POLUS CAPITAL MANAGEMENT (US) INC. | 75% or moreCode E | Yes | SHAREHOLDER03/2011 | Schedule APDF page 35 |
| 2 | NICHOLAS IAN CHALMERSDIRECTORIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | DIRECTOR01/2021 | Schedule APDF page 36 |
| 3 | DAVID DAE KIMDIRECTORIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | DIRECTOR07/2023 | Schedule APDF page 36 |
| 4 | STEFANO NMN DOVADIRECTORIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | DIRECTOR03/2024 | Schedule APDF page 36 |
| 5 | ANNALISA NMN ROTUNNODIRECTORIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | DIRECTOR03/2024 | Schedule APDF page 36 |
| 6 | FRANK NMN GOASGUENDIRECTORIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | DIRECTOR03/2024 | Schedule APDF page 36 |
| 7 | WILLIAM ROBERT CANNONCHIEF COMPLIANCE OFFICERIndividual | POLUS CAPITAL MANAGEMENT (US) INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER10/2025 | Schedule APDF page 36 |
| 8 | MEDIOBANCA-BANCA DI CREDITO FINANZIARIO S.P.ASHAREHOLDERForeign entity | POLUS CAPITAL MANAGEMENT GROUP LIMITED | 50% to less than 75%Code D | Yes | SHAREHOLDER12/2015 | Schedule BPDF page 36 |
| 9 | BANCA MONTE DEI PASCHI DI SIENA S.P.A.SHAREHOLDERForeign entity | MEDIOBANCA-BANCA DI CREDITO FINANZIARIO S.P.A | 75% or moreCode E | Yes | SHAREHOLDER09/2025 | Schedule BPDF page 36 |
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 3/31/2026 9:23:44 AM
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.
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 actions2 Yes3 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?Yes
- 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 actions4 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?No
- 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 proceedings1 Yes3 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?Yes
- 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 6 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 1MEDIOBANCA-BANCA DI CREDITO FINANZIARIO S.P.APDF pages 37–39
- Advisory affiliate name — filed text
- MEDIOBANCA-BANCA DI CREDITO FINANZIARIO S.P.A
- Regulator name — filed text
- COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
- Monetary/Fine Amount — filed text
- $ 16,900.00
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
THE ACTION STATUS IS FINAL AS THE MONETARY SANCTION LEVIED BY CONSOB AGAINST MEDIOBANCA WAS PAID BY MEDIOBANCA AND NO APPEAL WAS FILED.
Other filed details
Description of allegations — filed text
CONSOB ALLEGED MISSING OR DELAYED ENTRIES IN THREE REGISTERS HELD FOR MARKET ABUSE PURPOSES IN RELATION TO THREE BOOK BUILDING TRANSACTIONS OCCURED IN 2013 AND 2014.
Sanction detail — filed text
A MONETARY SANCTION OF THE EQUIVALENT OF $16,900 WAS LEVIED. THIS WAS PAID IN FULL BY MEDIOBANCA AND NO APPEAL WAS FILED.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: MEDIOBANCA-BANCA DI CREDITO FINANZIARIO S.P.A (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) COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/17/2014 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 19335 OF 08/26/2015 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MEDIOBANCO- BANCA DI CREDITO FINANZIARIO S.P.A 6. Principal Product Type: Other Other Product Types: TWO ACCELERATED BOOK BUILDING TRANSACTIONS AND ONE REVERSE ACCELERATED BOOK BUILDING TRANSACTION IN RELATION TO SHARES OF ITALIAN LISTED ISSUER 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): CONSOB ALLEGED MISSING OR DELAYED ENTRIES IN THREE REGISTERS HELD FOR MARKET ABUSE PURPOSES IN RELATION TO THREE BOOK BUILDING TRANSACTIONS OCCURED IN 2013 AND 2014. 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: Order 11. Resolution Date (MM/DD/YYYY): 08/26/2015 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: $ 16,900.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: A MONETARY SANCTION OF THE EQUIVALENT OF $16,900 WAS LEVIED. THIS WAS PAID IN FULL BE MEDIOBANCA AND NO APPEAL WAS FILED. 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 MONETARY SANCTION OF THE EQUIVALENT OF $16,900 WAS LEVIED. THIS WAS PAID IN FULL BY MEDIOBANCA AND NO APPEAL WAS FILED. 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 ACTION STATUS IS FINAL AS THE MONETARY SANCTION LEVIED BY CONSOB AGAINST MEDIOBANCA WAS PAID BY MEDIOBANCA AND NO APPEAL WAS FILED.
regulatory · block 2MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.APDF pages 39–40
- Advisory affiliate name — filed text
- MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A
- Regulator name — filed text
- COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
- Monetary/Fine Amount — filed text
- $ 86,900.00
- How was matter resolved — filed text
- Other
Action status / disposition — filed text
CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. MEDIOBANCA SUBSEQUENTLY APPEALED THE CONSOB ORDER BUT THE ORDER HAS BEEN CONFIRMED.
Other filed details
Description of allegations — filed text
ALLEGED BREACH OF RULES ON DISCLOSURE OBLIGATION TO THE MARKET IN RELATION TO A TRANSACTION REGARDING AN ITALIAN LISTED COMPANY ACTIVE IN THE TMT SECTOR
Sanction detail — filed text
CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. SANCTION ORDERED WAS A MONETARY PENALTY OF $86,900.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A (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) COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 02/17/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0022744/17 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ALLEGED BREACH OF RULES ON DISCLOSURE OBLIGATION TO THE MARKET IN RELATION TO A TRANSACTION REGARDING AN ITALIAN LISTED COMPANY ACTIVE IN THE TMT SECTOR 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): 10/11/2017 Exact Explanation If not exact, provide explanation: CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. MEDIOBANCA SUBSEQUENTLY APPEALED THE CONSOB ORDER BUT THE ORDER HAS BEEN CONFIRMED. 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 86,900.00 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: CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. SANCTION ORDERED WAS A MONETARY PENALTY OF $86,900. 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). CONSOB ISSUED A SANCTION ORDER ON 11 OCTOBER 2017. MEDIOBANCA SUBSEQUENTLY APPEALED THE CONSOB ORDER BUT THE ORDER HAS BEEN CONFIRMED.
regulatory · block 3MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.APDF pages 41–42
- Advisory affiliate name — filed text
- MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A
- Regulator name — filed text
- COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB)
- How was matter resolved — filed text
- Dismissed
Action status / disposition — filed text
CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED.
Other filed details
Description of allegations — filed text
ALLEGED BREACH OF DISCLOSURE OF NET SHORT POSITIONS ON THE SHARES OF AN ITALIAN LISTED COMPANY ACTIVE IN THE TMT SECTOR
Sanction detail — filed text
CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A (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) COMMISSIONE NAZIONALE PER LA SOCIETA' E LA BORSA (CONSOB) 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/16/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 37969/2015 (95029/15) 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): MEDIOBANCA - BANCA DI CREDITO FINANZIARIO S.P.A 6. Principal Product Type: Equity - OTC Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ALLEGED BREACH OF DISCLOSURE OF NET SHORT POSITIONS ON THE SHARES OF AN ITALIAN LISTED COMPANY ACTIVE IN THE TMT SECTOR 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: Dismissed 11. Resolution Date (MM/DD/YYYY): 09/14/2016 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: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: NO SANCTION WAS ISSUED 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: CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED. 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). CONSOB DISMISSED THE ALLEGATIONS AGAINST MEDIOBANCA. NO SANCTION WAS ISSUED.
regulatory · block 4BANCA MONTE DEI PASCHIDI SIENA SPAPDF pages 42–44
- Advisory affiliate name — filed text
- BANCA MONTE DEI PASCHIDI SIENA SPA
- Regulator name — filed text
- BANK OF ITALY
- Monetary/Fine Amount — filed text
- $ 3,110,540.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS HAVE BEEN REFUNDED. THE MONETARY FINE HAS BEEN PAID IN 2022 BY BANCA MONTE DEI PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT BEFORE THE COURT OF APPEAL. IN 2025 THERE WAS ANOTHER INSPECTION OF BANK OF ITALY ON THE SAMETOPIC CONCLUDED WITH A POSITIVE SCORE.
Other filed details
Description of allegations — filed text
SHORTCOMINGS IN TRANSPARENCY AND FAIRNESS IN CUSTOMER RELATIONS AND INCORRECT APPLICATION OF COMMISSIONS. THESHORTCOMINGS HAVE BEEN REMEDIED.
Sanction detail — filed text
IN 2021 BANCA MONTE DEI PASCHI DI SIENA S.P.A. WAS FINED BY THE BANK OF ITALY BY EUR 2,9 MILLION FOR FAILURE TO ACT TRANSPARENTLY AND TREAT CUSTOMERSFAIRLY. THE SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS REFUNDED BY EUR 40 MILLION APPROXIMATELY.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: BANCA MONTE DEI PASCHIDI SIENA SPA (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) BANK OF ITALY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/03/2021 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: BANK OF ITALY NO.698152/2021 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): SHORTCOMINGS IN TRANSPARENCY AND FAIRNESS IN CUSTOMER RELATIONS AND INCORRECT APPLICATION OF COMMISSIONS. THESHORTCOMINGS HAVE BEEN REMEDIED. 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): 12/31/2022 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: $ 3,110,540.00 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: IN 2021 BANCA MONTE DEI PASCHI DI SIENA S.P.A. WAS FINED BY THE BANK OF ITALY BY EUR 2,9 MILLION FOR FAILURE TO ACT TRANSPARENTLY AND TREAT CUSTOMERSFAIRLY. THE SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS REFUNDED BY EUR 40 MILLION APPROXIMATELY. 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). SHORTCOMINGS HAVE BEEN REMEDIED AND CUSTOMERS HAVE BEEN REFUNDED. THE MONETARY FINE HAS BEEN PAID IN 2022 BY BANCA MONTE DEI PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT BEFORE THE COURT OF APPEAL. IN 2025 THERE WAS ANOTHER INSPECTION OF BANK OF ITALY ON THE SAMETOPIC CONCLUDED WITH A POSITIVE SCORE.
regulatory · block 5BANCA MONTE DEI PASCHI DI SIENA S.P.APDF pages 44–46
- Advisory affiliate name — filed text
- BANCA MONTE DEI PASCHI DI SIENA S.P.A
- Regulator name — filed text
- BANK OF ITALY
- Monetary/Fine Amount — filed text
- $ 1,447,940.00
- How was matter resolved — filed text
- Settled
Action status / disposition — filed text
SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACK OF THE WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA MONTE DEI PASCHI DI SIENA S.P.A WITHOUT CHALLENGING IT IN THE COURT OF APPEAL.
Other filed details
Description of allegations — filed text
WEAKNESS IN THE AML CUSTOMER DUE DILIGENCE AND SUSPICIOUS ACTIVITY REPORTING PROCESSES. THE SHORTCOMINGS HAVE BEEN REMEDIED.
Sanction detail — filed text
SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACKOF THE WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA MONTE DEI PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT IN THE COURT OF APPEAL.
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: This advisory affiliate is a Firm an Individual Registered: Yes No Name: BANCA MONTE DEI PASCHI DI SIENA S.P.A (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) BANK OF ITALY 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 12/17/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: BANK OF ITALY NO. 1526250/19 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): WEAKNESS IN THE AML CUSTOMER DUE DILIGENCE AND SUSPICIOUS ACTIVITY REPORTING PROCESSES. THE SHORTCOMINGS HAVE BEEN REMEDIED. 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): 01/16/2020 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: $ 1,447,940.00 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: SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACKOF THE WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA MONTE DEI PASCHI DI SIENA S.P.A. WITHOUT CHALLENGING IT IN THE COURT OF APPEAL. 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). SHORTCOMINGS HAVE BEEN REMEDIED AND A DEDICATED ACTION PLAN COMPLETED. THE ACTION PLAN WAS DEFINED ON THE BACK OF THE WEAKNESSES IDENTIFIED IN 2018 BY THE BANK OF ITALY WHICH LED TO A MONETARY FINE OF 1.3 MILLION EUR THAT HAS BEEN PAID BY BANCA MONTE DEI PASCHI DI SIENA S.P.A WITHOUT CHALLENGING IT IN THE COURT OF APPEAL.
civil judicial · block 1PDF pages 46–48
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 Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
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 Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
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:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
MEDIOBANCA-BANCA DI
CREDITO FINANZIARIO S.P.A
(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.H.
(1)(a), 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. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.)
SEVERAL SHAREHOLDERS OF LA FONDIARIA ASSICURAZIONI S.P.A. (NOW UNIPOLSAI ASSICURAZIONI S.P.A.).
2.
Principal Relief Sought:
Money Damages (Private/Civil Complaint)
Other Relief Sought:
3.
Filing Date of Court Action (MM/DD/YYYY):
12/01/2003
Exact
Explanation
If not exact, provide explanation:
FILING DATES OF THE ACTIONS RANGED FROM DECEMBER 2003 TO MAY 2014.
4.
Principal Product Type:
Other
Other Product Types:
EQUITY-SHARE CAPITAL
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number):
COURT OF MILAN AND COURT OF FLORENCE-ITALY-SEVERAL CASE NUMBERS
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable):
N/A
7.
Describe the allegations related to this civil action (your response must fit within the space provided):
ON DECEMBER 18, 2002, THE ITALIAN STOCK MARKET REGULATOR ("CONSOB"), RULED THAT MEDIOBANCA ACTED IN CONCERT WITH OTHER
COMPANIES DURING THEIR COMBINED PURCHASE OF MORE THAN 30% OF THE SHARE CAPITAL OF LA FONDIARIA ASSICURAZIONI S.P.A. ("FONDIARIA",
NOW UNIPOLSAI ASSICURAZIONI S.P.A. ("UNIPOLSAI") IN VIOLATION OF ARTICLES 106, 109 AND 122 OF LAW DECREE NO. 58 OF 24 FEBRUARY 1998
(THE ITALIAN CONSOLIDATED FINANCIAL ACT - "TUF") BY OMITTING TO LAUNCH A PUBLIC TENDER OFFER, IN BREACH OF SUCH MANDATORY
PROVISIONS. SIMILAR RULINGS HAVE BEEN ISSUED BY THE ADMINISTRATIVE COURT OF LAZIO (TAR LAZIO), THE ITALIAN ANTITRUST AUTHORITY
(AGCM) AND ALSO BY THE COURT OF APPEAL OF MILANO AND TORINO. FOLLOWING SUCH RULINGS, 16 CIVIL PROCEEDINGS WERE BROUGHT BY
FONDIARIA'S MINORITY SHAREHOLDERS AGAINST UNIPOLSAI AND MEDIOBANCA. WITH RESPECT TO THE STATUS OF SUCH PROCEEDINGS, THESE HAVE
BEEN ALL TERMINATED. THE PROCEEDING BROUGHT BY MR. ROBERTO GAVAZZI, INDICATED AS PENDING AS OF THE DATE OF THE LAST CIVIL JUDICIAL
ACTION DISCLOSURE REPORTING PAGE, HAS BEEN SETTLED ON JANUARY 9, 2025 WITH THE PAYMENT BY MEDIOBANCA OF AN AMOUNT OF 58,091.26
EURO. THE PROCEEDING HAS BEEN DECLARED FINALLY TERMINATED BY COURT ORDER OF JANUARY 29, 2025. WITH RESPECT TO THE CLAIMS BROUGHT
BY THE PLAINTIFFS IN ALL THE PROCEEDINGS, PLEASE NOTE THAT AN IMPORTANT PRINCIPLE HAS BEEN STATED, IN ONE OF THE PROCEEDINGS THAT
WAS LATER SETTLED, BY THE ITALIAN HIGH COURT (COURT OF CASSATION), IN DECISION NO. 14400 DATED AUGUST 10, 2012. THE COURT STATED
THAT EACH MINORITY SHAREHOLDER THAT HAS BEEN UNLAWFULLY DEPRIVED OF THE CHANCE TO PARTICIPATE IN A PUBLIC TENDER OFFER ON THE
SHARES HAS THE RIGHT TO RECEIVE COMPENSATION FOR DAMAGES SUBJECT TO PROOF THAT THE LOSS OF THE CHANCE TO GAIN PROFITS DEPENDS
ON THE LACK OF THE LAUNCH OF A PUBLIC TENDER OFFER, IN VIOLATION OF THE PROVISIONS OF TUF. AS A RESULT, THE PROCEEDINGS RELATE TO
THE SAME UNDERLYING VIOLATION OF ITALIAN LAW AND CAN THUS BE CONSIDERED PART OF THE SAME EVENT OR PROCEEDING.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY):
Exact
Explanation
If not exact, provide explanation:
N/A
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Judgment Rendered
12. Resolution Date (MM/DD/YYYY):
01/08/2025
Exact
Explanation
If not exact, provide explanation:
ALL PROCEEDINGS HAVE BEEN TERMINATED.
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions:
PAYMENT AS COMPENSATION FOR DAMAGES IN A TOTAL AMOUNT OF APPROXIMATELY EURO 30,5 MILLION PLUS LEGAL EXPENSES.
C.
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:
ALL PAYMENTS HAVE BEEN MADE IN ACCORDANCE WITH THE RELEVANT SETTLEMENT AGREEMENTS AND/OR JUDGEMENTS.
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided).
OF THE 16 CLAIMS BROUGHT, ALL HAVE BEEN SETTLED. CLAIMS SETTLED-PAYMENT AS COMPENSATION FOR DAMAGES IN TOTAL OF APPROXIMATELY
EURO 30.5 MILLION PLUS LEGAL EXPENSES.* 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 data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.