Assets Under Management
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total AUM$6.5B
Total Accounts11,892
10Y AUM Change+$5.3B (+445.2%)
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Total Employees1,839
Clients per Employee9:1
10Y Employee Change+989 (+116.4%)
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 Osaic Institutions, Inc..
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Custodians
Reported custodian relationships by Osaic Institutions, Inc..
- PERSHING LLC
$4,024,448,972
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
Ownership information is not yet available for this profile.
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 one or more events below involve the firm or its supervised persons.RIA responseYes
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions4 Yes1 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?Yes
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- 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?Yes
- 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?Yes
DOther regulatory actions4 Yes1 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?Yes
- 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?Yes
- 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 actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 10 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1PDF pages 45–47
- Regulator name — filed text
- STATE OF CONNECTICUT DEPARTMENT OF BANKING
- Monetary/Fine Amount — filed text
- $ 1,000.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
INFINEX INVESTMENTS, INC HAS FULLY COMPLIED WITH ALL OF THE TERMS AND CONDITIONS OF THE STIPULATION AND AGREEMENT WITH THE STATE OF CONNECTICUT DEPARTMENT OF BANKING.
Other filed details
Description of allegations — filed text
THE STATE OF CONNECTICUT DEPARTMENT OF BANKING ALLEGED THAT INFINEX INVESTMENTS, INC., FORMERLY KNOWN AS CONNECTICUT ASSOCIATION SECURITIES, INC., EFFECTED CERTAIN TRANSACTIONS IN SECURITIES IN CONNECTICUT FROM UNREGISTERED BRANCHES AND FAILED TO SUPERVISE CERTAIN AGENTS IN CONNECTION WITH SUCH ACTIVITIES.
Sanction detail — filed text
A FINE IN THE AMOUNT OF $1,000.00 WAS PAID ON OR ABOUT APRIL 6, 1996.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF CONNECTICUT DEPARTMENT OF BANKING 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/06/1996 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: ST-96-2897-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Money Market Fund(s) Other Product Types: EQUITY LISTED, ANNUITY(IES)-VARIABLE 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE STATE OF CONNECTICUT DEPARTMENT OF BANKING ALLEGED THAT INFINEX INVESTMENTS, INC., FORMERLY KNOWN AS CONNECTICUT ASSOCIATION SECURITIES, INC., EFFECTED CERTAIN TRANSACTIONS IN SECURITIES IN CONNECTICUT FROM UNREGISTERED BRANCHES AND FAILED TO SUPERVISE CERTAIN AGENTS IN CONNECTION WITH SUCH ACTIVITIES. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 04/06/1996 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: $ 1,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: INFINEX INVESTMENTS, INC. WAS REQUIRED TO REVIEW AND IMPLEMENT NEW SUPERVISORY AND COMPLIANCE PROCEDURES AND FILE CERTAIN REPORTS WITH THE STATE OF CONNECTICUT DEPARTMENT OF BANKING. 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 IN THE AMOUNT OF $1,000.00 WAS PAID ON OR ABOUT APRIL 6, 1996. 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). INFINEX INVESTMENTS, INC HAS FULLY COMPLIED WITH ALL OF THE TERMS AND CONDITIONS OF THE STIPULATION AND AGREEMENT WITH THE STATE OF CONNECTICUT DEPARTMENT OF BANKING.
regulatory · block 2PDF pages 47–48
- Regulator name — filed text
- STATE OF ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT
- Monetary/Fine Amount — filed text
- $ 6,500.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
THE FIRM ENTERED INTO A CONSENT ORDER WITH THE STATE OF ILLINOIS REGARDING THE INADVERTENT PERFORMANCE OF CERTAIN SECURITIES ACTIVITIES IN THE STATE OF ILLINOIS, GERNERALLY INVOLVING CLIENTS WHO HAD RELOCATED TO ILLINOIS FROM STATES IN WHICH THE FIRM WAS REGISTERED. THE FIRM ENTERED INTO A STIPULATION AND PAID A STIPULATED SUM OF $10,100.00, $6,500.00 OF WHICH WAS CHARACTERIZED AS A FINE AND $3,600.00 OF WHICH WAS CHARACTERIZED AS BACK REGISTRATION FEES.
Other filed details
Description of allegations — filed text
THE RESPONDENT ACTED AS A DEALER IN THE STATE OF ILLINOIS WITHOUT BEING PROPERLY REGISTERED IN VIOLATION OF SECTION 12.A AND 12.C OF THE ILLINOIS SECURITIES LAW.
Sanction detail — filed text
TOTAL AMOUNT $10,100 INCLUDING $6,500 CHARACTERIZED AS A FINE AND $3,600 CHARACTERIZED AS BACK REGISTRATION FEES. NO OTHER SANCTION. MATTER CLOSED.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF ILLINOIS SECRETARY OF STATE SECURITIES DEPARTMENT 2. Principal Sanction: Other Other Sanctions: STIPULATION AND CONSENT. 3. Date Initiated (MM/DD/YYYY): 07/09/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 0600605 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: NO PARTICULAR PRODUCT. 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): THE RESPONDENT ACTED AS A DEALER IN THE STATE OF ILLINOIS WITHOUT BEING PROPERLY REGISTERED IN VIOLATION OF SECTION 12.A AND 12.C OF THE ILLINOIS SECURITIES LAW. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 08/22/2007 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: $ 6,500.00 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: TOTAL AMOUNT $10,100 INCLUDING $6,500 CHARACTERIZED AS A FINE AND $3,600 CHARACTERIZED AS BACK REGISTRATION FEES. NO OTHER SANCTION. MATTER CLOSED. 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 ENTERED INTO A CONSENT ORDER WITH THE STATE OF ILLINOIS REGARDING THE INADVERTENT PERFORMANCE OF CERTAIN SECURITIES ACTIVITIES IN THE STATE OF ILLINOIS, GERNERALLY INVOLVING CLIENTS WHO HAD RELOCATED TO ILLINOIS FROM STATES IN WHICH THE FIRM WAS REGISTERED. THE FIRM ENTERED INTO A STIPULATION AND PAID A STIPULATED SUM OF $10,100.00, $6,500.00 OF WHICH WAS CHARACTERIZED AS A FINE AND $3,600.00 OF WHICH WAS CHARACTERIZED AS BACK REGISTRATION FEES.
regulatory · block 3PDF pages 48–50
- Regulator name — filed text
- STATE OF NEW YORK INSURANCE DEPARTMENT
- Monetary/Fine Amount — filed text
- $ 2,250.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
IN APPLYING FOR INSURANCE LICENSURE IN 2004, THE FIRM INADVERTENTLY FAILED TO DISCLOSE A MATTER FROM 1996 AND ANOTHER MATTER CONCERNING ONE INDIVIDUAL OF WHICH THE FIRM HAD NO NOTICE. THE FIRM VOLUNTARILY DISCLOSED THE INADVERTENT OVERSIGHT. STIPULATION ENTERED INTO TO RESOLVE THE MATTER WITHOUT FURTHER COST TO THE FIRM.
Other filed details
Description of allegations — filed text
NEW YORK INSURANCE DEPARTMENT ALLEGED THAT FIRM FILED INCORRECT INSURANCE LICENSE APPLICATIONS IN 2004.
Sanction detail — filed text
PENALTY OF $2,250.00 AGAINST INSURANCE AGENCY PAID 6/01/2009. ACKNOWLEDGED AND FINALIZED BY STATE OF NEW YORK 6/02/2009. MATTER CLOSED.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) STATE OF NEW YORK INSURANCE DEPARTMENT 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 04/17/2009 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2009-0136-S 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): NEW YORK INSURANCE DEPARTMENT ALLEGED THAT FIRM FILED INCORRECT INSURANCE LICENSE APPLICATIONS IN 2004. 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: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 06/02/2009 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: $ 2,250.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: NO OTHER SANCTIONS. 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: PENALTY OF $2,250.00 AGAINST INSURANCE AGENCY PAID 6/01/2009. ACKNOWLEDGED AND FINALIZED BY STATE OF NEW YORK 6/02/2009. MATTER CLOSED. 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). IN APPLYING FOR INSURANCE LICENSURE IN 2004, THE FIRM INADVERTENTLY FAILED TO DISCLOSE A MATTER FROM 1996 AND ANOTHER MATTER CONCERNING ONE INDIVIDUAL OF WHICH THE FIRM HAD NO NOTICE. THE FIRM VOLUNTARILY DISCLOSED THE INADVERTENT OVERSIGHT. STIPULATION ENTERED INTO TO RESOLVE THE MATTER WITHOUT FURTHER COST TO THE FIRM.
regulatory · block 4PDF pages 50–52
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 150,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
BROKER/DEALER ONLY MATTER INVOLVING A UIT TRADING SWEEP.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $109,628. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS, DESPITE THE FACT THAT THE FIRM DID NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SUCH SALES CHARGE DISCOUNTS.
Sanction detail — filed text
THE FIRM IS CENSURED, FINED $150,000, AND PAID RESTITUTION OF 109,627.84 TO CUSTOMERS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 10/19/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2014041841901 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Unit Investment Trust(s) 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 THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) RESULTING IN CUSTOMERS PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $109,628. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO ENSURE THAT CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS, DESPITE THE FACT THAT THE FIRM DID NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SUCH SALES CHARGE DISCOUNTS. 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): 10/19/2015 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: $ 150,000.00 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 IS CENSURED, FINED $150,000, AND PAID RESTITUTION OF 109,627.84 TO CUSTOMERS. 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). BROKER/DEALER ONLY MATTER INVOLVING A UIT TRADING SWEEP.
regulatory · block 5PDF pages 52–54
- Regulator name — filed text
- MASSACHUSETTS SECURITIES DIVISION
- Monetary/Fine Amount — filed text
- $ 125,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
IN JULY OF 2018, INFINEX ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF MASSACHUSETTS REGARDING INFINEX'S FAILURE TO REASONABLY SUPERVISE SEVERAL TRANSACTIONS EXECUTED BY FOUR REGISTERED REPRESENTATIVES AFFILIATED WITH THREE BANKS IN NETWORKING RELATIONSHIPS WITH INFINEX. WITHOUT ADMITTING OR DENYING THE FINDINGS, INFINEX CONSENTED TO A CENSURE, FINE, RESTITUTION TO CLIENT ACCOUNTS AND THE ENGAGEMENT OF A CONSULTANT TO REVIEW INFINEX'S SUPERVISORY POLICIES AND PROCEDURES.
Other filed details
Description of allegations — filed text
AS A BROKER-DEALER, FAILED TO REASONABLY SUPERVISE ITS REGISTERED REPRESENTATIVES OPERATING ON BANK PREMISES.
Sanction detail — filed text
N/A
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) MASSACHUSETTS SECURITIES DIVISION 2. Principal Sanction: Cease and Desist Other Sanctions: CENSURE, RESCISSION, RESTITUTION, COMPLIANCE REVIEW, ADMINISTRATIVE FINE 3. Date Initiated (MM/DD/YYYY): 07/18/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: E-2017-0092 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: N/A 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): AS A BROKER-DEALER, FAILED TO REASONABLY SUPERVISE ITS REGISTERED REPRESENTATIVES OPERATING ON BANK PREMISES. 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: Consent 11. Resolution Date (MM/DD/YYYY): 07/18/2018 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: $ 125,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: INDEPENDENT COMPLIANCE REVIEW. 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: N/A 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). IN JULY OF 2018, INFINEX ENTERED INTO A CONSENT ORDER WITH THE COMMONWEALTH OF MASSACHUSETTS REGARDING INFINEX'S FAILURE TO REASONABLY SUPERVISE SEVERAL TRANSACTIONS EXECUTED BY FOUR REGISTERED REPRESENTATIVES AFFILIATED WITH THREE BANKS IN NETWORKING RELATIONSHIPS WITH INFINEX. WITHOUT ADMITTING OR DENYING THE FINDINGS, INFINEX CONSENTED TO A CENSURE, FINE, RESTITUTION TO CLIENT ACCOUNTS AND THE ENGAGEMENT OF A CONSULTANT TO REVIEW INFINEX'S SUPERVISORY POLICIES AND PROCEDURES.
regulatory · block 6PDF pages 54–56
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. RESPONDENT SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-REPORTED BY RESPONDENT.
Other filed details
Description of allegations — filed text
INFINEX, IN ITS CAPACITY AS AN INVESTMENT ADVISER, VOLUNTARILY PARTICIPATED IN THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE. PURSUANT TO THE INITIATIVE, INFINEX SELF-REPORTED TO THE SEC THAT IT FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST RELATED TO THE SALE OF HIGHER COST MUTUAL FUND SHARE CLASSES WHEN LOWER COST SHARE CLASSES WERE AVAILABLE BY PLACING CLIENTS IN MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN LOWER COST SHARE CLASSES MAY HAVE BEEN AVAILABLE.
Sanction detail — filed text
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $865,932.01 AND PREJUDGMENT INTEREST OF $112,766.80, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
SANCTION AND DISGORGEMENT
3.
Date Initiated (MM/DD/YYYY):
03/11/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-19036
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Mutual Fund(s)
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
INFINEX, IN ITS CAPACITY AS AN INVESTMENT ADVISER, VOLUNTARILY PARTICIPATED IN THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE.
PURSUANT TO THE INITIATIVE, INFINEX SELF-REPORTED TO THE SEC THAT IT FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST RELATED TO
THE SALE OF HIGHER COST MUTUAL FUND SHARE CLASSES WHEN LOWER COST SHARE CLASSES WERE AVAILABLE BY PLACING CLIENTS IN MUTUAL
FUND SHARE CLASSES THAT CHARGED 12B-1 FEES WHEN LOWER COST SHARE CLASSES MAY HAVE BEEN AVAILABLE.
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):
03/11/2019
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:
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 RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $865,932.01 AND PREJUDGMENT INTEREST
OF $112,766.80, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
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).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. RESPONDENT
SELF-REPORTED TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS
SELECTION DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION
SELF-REPORTED BY RESPONDENT.Show 4 more source blocks
regulatory · block 7PDF pages 56–58
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 650,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FIRM HAS PAID THE APPLICABLE FINE AND HAS REMEDIATED THE AML ISSUES IDENTIFIED. THE FIRM HAS UPDATED AND IMPLEMENTED A WRITTEN AML PROGRAM THAT COMPLIES WITH FINRA RULE 3310. THE FIRM HAS ENHANCED EXISTING POLICIES AND IMPLEMENTED NEW PROCEDURES REASONABLY DESIGNED TO DETECT AND FACILITATE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FIRM WILL BE ADDING NEW DEDICATED OI AML STAFF AND HAS DESIGNATED NEW AML OFFICER. THE FIRM CONDUCTED A MANUAL REVIEW OF ALL BROKERAGE ACCOUNTS TO IDENTIFY CLIENTS WHO MAY PRESENT A HEIGHTENED RISK, UTILIZING FFIEC MINIMUM GUIDANCE. ADDITIONALLY, MONTHLY, THE FIRM MANUALLY REVIEWS ALL NEWLY ESTABLISHED CLIENTS TO DETERMINE IF THEY PRESENT A HEIGHTENED RISK. LASTLY, OSAIC IS EVALUATING AUTOMATED SOLUTIONS FOR CLIENT RISK SCORING FOR OI, WITH IMPLEMENTATION ANTICIPATED IN THE SECOND QUARTER OF 2026.
Other filed details
Description of allegations — filed text
INFINEX'S ANTI-MONEY LAUNDERING (AML) PROGRAM IS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT (BSA) AND ITS IMPLEMENTING REGULATIONS IN MULTIPLE RESPECTS. SINCE SEPTEMBER 2021, THE FIRM HAS FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY EXPECTED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. PRIOR TO DECEMBER 2024, THE FIRM ALSO FAILED TO REVIEW OR TIMELY REVIEW AML EXCEPTION REPORTS THAT THE FIRM RELIED ON TO DETECT POTENTIALLY SUSPICIOUS TRADES AND MONEY MOVEMENTS FOR POTENTIAL SUSPICIOUS ACTIVITY REPORT (SAR) FILINGS. ADDITIONALLY, SINCE SEPTEMBER 2021, INFINEX HAS FAILED TO INCLUDE IN ITS AML PROGRAM RISK-BASED PROCEDURES FOR CONDUCTING ONGOING CUSTOMER DUE DILIGENCE. FOR THESE VIOLATIONS OF FINRA RULES 3310 AND 2010, INFINEX HAS AGREED TO A CENSURE, A $650,000 FINE, AND AN UNDERTAKING
Sanction detail — filed text
A CENSURE; A $650,000 FINE; AND AN UNDERTAKING THAT, WITHIN 60 DAYS OF THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, A MEMBER OF RESPONDENT'S SENIOR MANAGEMENT WHO IS A REGISTERED PRINCIPAL OF THE FIRM SHALL CERTIFY IN WRITING THAT, AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS REMEDIATED THE AML ISSUES IDENTIFIED IN THIS AWC AND DEVELOPED AND IMPLEMENTED A WRITTEN AML PROGRAM THAT COMPLIES WITH FINRA RULE 3310 REGARDING THE ISSUES IDENTIFIED IN THIS AWC. THE CERTIFICATION SHALL INCLUDE A NARRATIVE DESCRIPTION AND SUPPORTING EXHIBITS SUFFICIENT TO DEMONSTRATE RESPONDENT'S REMEDIATION AND IMPLEMENTATION. FINRA STAFF MAY REQUEST FURTHER EVIDENCE OF RESPONDENT'S REMEDIATION AND IMPLEMENTATION AND, RESPONDENT AGREES TO PROVIDE SUCH EVIDENCE.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 01/17/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2023077031601 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): INFINEX'S ANTI-MONEY LAUNDERING (AML) PROGRAM IS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE REQUIREMENTS OF THE BANK SECRECY ACT (BSA) AND ITS IMPLEMENTING REGULATIONS IN MULTIPLE RESPECTS. SINCE SEPTEMBER 2021, THE FIRM HAS FAILED TO ESTABLISH AND IMPLEMENT POLICIES AND PROCEDURES REASONABLY EXPECTED TO DETECT AND CAUSE THE REPORTING OF SUSPICIOUS TRANSACTIONS. PRIOR TO DECEMBER 2024, THE FIRM ALSO FAILED TO REVIEW OR TIMELY REVIEW AML EXCEPTION REPORTS THAT THE FIRM RELIED ON TO DETECT POTENTIALLY SUSPICIOUS TRADES AND MONEY MOVEMENTS FOR POTENTIAL SUSPICIOUS ACTIVITY REPORT (SAR) FILINGS. ADDITIONALLY, SINCE SEPTEMBER 2021, INFINEX HAS FAILED TO INCLUDE IN ITS AML PROGRAM RISK-BASED PROCEDURES FOR CONDUCTING ONGOING CUSTOMER DUE DILIGENCE. FOR THESE VIOLATIONS OF FINRA RULES 3310 AND 2010, INFINEX HAS AGREED TO A CENSURE, A $650,000 FINE, AND AN UNDERTAKING 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): 12/19/2025 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: $ 650,000.00 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: A CENSURE; A $650,000 FINE; AND AN UNDERTAKING THAT, WITHIN 60 DAYS OF THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, A MEMBER OF RESPONDENT'S SENIOR MANAGEMENT WHO IS A REGISTERED PRINCIPAL OF THE FIRM SHALL CERTIFY IN WRITING THAT, AS OF THE DATE OF THE CERTIFICATION, THE FIRM HAS REMEDIATED THE AML ISSUES IDENTIFIED IN THIS AWC AND DEVELOPED AND IMPLEMENTED A WRITTEN AML PROGRAM THAT COMPLIES WITH FINRA RULE 3310 REGARDING THE ISSUES IDENTIFIED IN THIS AWC. THE CERTIFICATION SHALL INCLUDE A NARRATIVE DESCRIPTION AND SUPPORTING EXHIBITS SUFFICIENT TO DEMONSTRATE RESPONDENT'S REMEDIATION AND IMPLEMENTATION. FINRA STAFF MAY REQUEST FURTHER EVIDENCE OF RESPONDENT'S REMEDIATION AND IMPLEMENTATION AND, RESPONDENT AGREES TO PROVIDE SUCH EVIDENCE. 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 HAS PAID THE APPLICABLE FINE AND HAS REMEDIATED THE AML ISSUES IDENTIFIED. THE FIRM HAS UPDATED AND IMPLEMENTED A WRITTEN AML PROGRAM THAT COMPLIES WITH FINRA RULE 3310. THE FIRM HAS ENHANCED EXISTING POLICIES AND IMPLEMENTED NEW PROCEDURES REASONABLY DESIGNED TO DETECT AND FACILITATE THE REPORTING OF SUSPICIOUS TRANSACTIONS. THE FIRM WILL BE ADDING NEW DEDICATED OI AML STAFF AND HAS DESIGNATED NEW AML OFFICER. THE FIRM CONDUCTED A MANUAL REVIEW OF ALL BROKERAGE ACCOUNTS TO IDENTIFY CLIENTS WHO MAY PRESENT A HEIGHTENED RISK, UTILIZING FFIEC MINIMUM GUIDANCE. ADDITIONALLY, MONTHLY, THE FIRM MANUALLY REVIEWS ALL NEWLY ESTABLISHED CLIENTS TO DETERMINE IF THEY PRESENT A HEIGHTENED RISK. LASTLY, OSAIC IS EVALUATING AUTOMATED SOLUTIONS FOR CLIENT RISK SCORING FOR OI, WITH IMPLEMENTATION ANTICIPATED IN THE SECOND QUARTER OF 2026.
regulatory · block 8BI INVESTMENTS, LLCPDF pages 58–59
- Advisory affiliate name — filed text
- BI INVESTMENTS, LLC
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
NASD RULES 2110 AND 31010(A) AND (B): BI INVESTMENTS, LLC FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES RELATING TO ITS VARIABLE ANNUITY BUSINESS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS AND NASD RULES.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $100,000 AND UNDERTAKES TO RETAIN AN INDEPENDENT CONSULTANT WITHIN 60 DAYS TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS AND PROCEDURES(WRITTEN OR OTHERWISE) AND TRAINING RELATING TO VARIABLE ANNUITIES. THE FIRM'S CHIEF COMPLIANCE OFFICER SHALL SUBMIT A CERTIFICATION TO FINRA THAT EACH AND EVERY REGISTERED REPRESENTATIVE OF THE FIRM HAS RECEIVED, REVIEWED AND AGREED TO COMPLY WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES.
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: 125437 This advisory affiliate is a Firm an Individual Registered: Yes No Name: BI INVESTMENTS, LLC (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: Censure Other Sanctions: MONETARY/FINE AND UNDERTAKINGS 3. Date Initiated (MM/DD/YYYY): 12/31/2007 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2005001611001 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): NASD RULES 2110 AND 31010(A) AND (B): BI INVESTMENTS, LLC FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WRITTEN PROCEDURES RELATING TO ITS VARIABLE ANNUITY BUSINESS THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE FEDERAL SECURITIES LAWS AND REGULATIONS AND NASD RULES. 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): 12/31/2007 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: UNDERTAKINGS Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE THE FIRM IS CENSURED, FINED $100,000 AND UNDERTAKES TO RETAIN AN INDEPENDENT CONSULTANT WITHIN 60 DAYS TO CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY OF THE FIRM'S POLICIES, SYSTEMS AND PROCEDURES(WRITTEN OR OTHERWISE) AND TRAINING RELATING TO VARIABLE ANNUITIES. THE FIRM'S CHIEF COMPLIANCE OFFICER SHALL SUBMIT A CERTIFICATION TO FINRA THAT EACH AND EVERY REGISTERED REPRESENTATIVE OF THE FIRM HAS RECEIVED, REVIEWED AND AGREED TO COMPLY WITH THE FIRM'S WRITTEN SUPERVISORY PROCEDURES. 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).
regulatory · block 9PDF pages 59–61
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 15,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
SEC EXCHANGE ACT RULESS 17A-3, 17A-4, FINRA RULE 2010, NASD RULES 2110, 3010, 3110, MSRB RULES G-8, G-9, G-27; WITH RESPECT TO 43 CORPORATE BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: TEN OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; FOUR OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; TWO OF THE ORDER TICKETS DID NOT DISCLOSE THE FIRM'S CAPACITY; AND TWO OF THE ORDER TICKETS REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. WITH RESPECT TO 45 MUNICIPAL BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: EIGHT OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; THREE OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; AND ONE ORDER TICKET REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. MOREOVER, THE FIRM FAILED TO MAINTAIN ITS CORPORATE AND MUNICIPAL BOND ORDER TICKET INFORMATION IN AN EASILY ACCESSIBLE PLACE FOR A PERIOD OF TWO YEARS, AS REQUIRED BY EXCHANGE ACT RULE 17A-4(B) AND MSRB RULE G-9(D). FOR EXAMPLE, THE FIRM WAS UNABLE TO PROVIDE A COMPREHENSIVE RESPONSE TO FINRA STAFF'S REQUEST FOR SUCH INFORMATION FOR OVER SEVEN MONTHS. IN ADDITION, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CORPORATE AND MUNICIPAL BOND ORDER TICKET RECORDKEEPING AND RETENTION REQUIREMENTS. SPECIFICALLY, THE PROCEDURES FAILED TO PROVIDE INSTRUCTION OR GUIDANCE TO FIRM PERSONNEL ON THE MANNER IN WHICH REQUIRED TICKET INFORMATION WOULD BE OBTAINED AND PRESERVED. THE FIRM DID NOT PROVIDE FOR THE ADEQUATE TRAINING OF FIRM STAFF WITH RESPECT TO THE COMPREHENSIVE ENTRY OF ALL REQUIRED ORDER TICKET INFORMATION AND FOR THE RETRIEVAL OF THAT INFORMATION WITHIN A REASONABLE TIME FRAME.
Sanction detail — filed text
WITHOOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED AND FINED $15,000 ($7,500 OF WHICH PERTAINS TO THE VIOLATIONS OF MSRB RULES G-8, G-9, AND G-27).
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Other Other Sanctions: N/A 3. Date Initiated (MM/DD/YYYY): 01/20/2011 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2009016320901 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Debt - Corporate Other Product Types: MUNICIPAL BONDS 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): SEC EXCHANGE ACT RULESS 17A-3, 17A-4, FINRA RULE 2010, NASD RULES 2110, 3010, 3110, MSRB RULES G-8, G-9, G-27; WITH RESPECT TO 43 CORPORATE BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: TEN OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; FOUR OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; TWO OF THE ORDER TICKETS DID NOT DISCLOSE THE FIRM'S CAPACITY; AND TWO OF THE ORDER TICKETS REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. WITH RESPECT TO 45 MUNICIPAL BOND TRANSACTIONS, THE FIRM FAILED TO MAINTAIN ADEQUATE ORDER TICKETS AS FOLLOWS: EIGHT OF THE ORDER TICKETS DID NOT REFLECT THE ORDER TYPE; THREE OF THE ORDER TICKETS DID NOT REFLECT WHETHER THE TRADE WAS SOLICITED OR UNSOLICITED; AND ONE ORDER TICKET REFLECTED A TIME OF EXECUTION THAT WAS BEFORE THE TIME OF ORDER ENTRY. MOREOVER, THE FIRM FAILED TO MAINTAIN ITS CORPORATE AND MUNICIPAL BOND ORDER TICKET INFORMATION IN AN EASILY ACCESSIBLE PLACE FOR A PERIOD OF TWO YEARS, AS REQUIRED BY EXCHANGE ACT RULE 17A-4(B) AND MSRB RULE G-9(D). FOR EXAMPLE, THE FIRM WAS UNABLE TO PROVIDE A COMPREHENSIVE RESPONSE TO FINRA STAFF'S REQUEST FOR SUCH INFORMATION FOR OVER SEVEN MONTHS. IN ADDITION, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, AND ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES (WSPS), REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH CORPORATE AND MUNICIPAL BOND ORDER TICKET RECORDKEEPING AND RETENTION REQUIREMENTS. SPECIFICALLY, THE PROCEDURES FAILED TO PROVIDE INSTRUCTION OR GUIDANCE TO FIRM PERSONNEL ON THE MANNER IN WHICH REQUIRED TICKET INFORMATION WOULD BE OBTAINED AND PRESERVED. THE FIRM DID NOT PROVIDE FOR THE ADEQUATE TRAINING OF FIRM STAFF WITH RESPECT TO THE COMPREHENSIVE ENTRY OF ALL REQUIRED ORDER TICKET INFORMATION AND FOR THE RETRIEVAL OF THAT INFORMATION WITHIN A REASONABLE TIME FRAME. 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): 01/20/2011 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 15,000.00 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: WITHOOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS; THEREFORE IT IS CENSURED AND FINED $15,000 ($7,500 OF WHICH PERTAINS TO THE VIOLATIONS OF MSRB RULES G-8, G-9, AND G-27). 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).
regulatory · block 10PDF pages 61–63
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 75,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS. THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUBJECT NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) TO THE SAME LEVEL OF REVIEW AS OTHER NEW PRODUCTS OFFERED FOR SALE TO RETAIL BROKERAGE CUSTOMERS. THE FINDINGS STATED THAT INSTEAD, THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND TO CUSTOMERS NON-TRADITIONAL ETFS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. THE FIRM PERMITTED REPRESENTATIVES WHO RECEIVED MINIMAL TRAINING ON NON-TRADITIONAL ETFS AND WHO FAILED TO PERFORM REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES OF THE PRODUCT, TO RECOMMEND TO CUSTOMERS TRANSACTIONS IN NON- TRADITIONAL ETFS. BY FIALING TO EMPLOY REASONABLE DILIGENCE REGARDING NON-TRADITIONAL ETFS, THE FIRM MISSED THE OPPORTUNITY TO EVALUATE CRITICAL ASPECTS OF THESE PRODUCTS INCLUDING THE IMPLICATIONS OF THE DAILY RESET AND LEVEDRAGE COMPONENTS AND TO ESTABLISH APPROPRIATE TRAINING AND SUPERVISION PROTOCOLS. ACCORDINGLY, THESE RECOMMENDATIONS LACKED A REASONABLE BASIS AND WERE UNSUITABLE. THE FINDINGS ALSO STATED THAT SOME NON-TRADITIONAL ETFS PURCHASES THAT THE FIRM RECOMMENDED, ACTING THROUGH SEVERAL BROKERS, WERE ALSO UNSUITABLE UNDER A CUSTOMER-SPECIFIC SUITABILITY THEORY AS THE RECOMMENDATIONS WERE MADE TO CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. THE PROSPECTUSES FOR THE NON-TRADITIONAL ETFS THAT THE FIRM SOLD GENERALLY ADVISED THAT THEY SHOULD NOT BE HELD MORE THAN ONE TRADING SESSION OR AS LONG-TERM INVESTMENTS. NOTWITHSTANDING THAT STATEMENT IN THE PROSPECTUSES, NON-TRADITIONAL ETFS WERE MAINTAINED IN CUSTOMER ACCOUNTS FOR LONGER THAN SEVEN BUSINESS DAYS. CUSTOMERS WHO HAD CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES AND WHOSE ETFS WERE HELD FOR SEVEN OR MORE DAYS, LOST MONEY ON THEIR INVESTEMENTS. THESE UNSUITABLE NON-TRADITIONAL ETF RECOMMENDATIONS RESULTED IN CUSTOMER LOSSES OF $287,171.75. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), TO MONITOR AND REVIEW THE SALE OF NON-TRADITIONAL ETFS TO ITS RETAIL CUSTOMERS AND THE FIRM FAILED TO ESTABLISH AND MAINTAIN SPECIFIC WSPS FOR THE REVIEW OF NON-TRADITIONAL EFT TRANSACTIONS. THE SUPERVISORY REVIEWS THAT THE FIRM'S PRINCIPALS PERFORMED OF TRANSACTIONS INVOLVING NON-TRADITONAL ETFS WERE INADEQUATE. THEY FAILED TO INCORPORATE THE COMPLEXITIES AND UNIQUE RISKS ASSOCIATED WITH THESE SECURITIES, SUCH AS THEIR DAILY RESET AND LEVERAGE FEATURES. INSTEAD, THE FIRM'S PRINCIPALS REVIEWED NON-TRADTIONAL ETF TRANSACTIONS FOR SUITABILITY IN THE SAME MANNER THEY REVIEWED TRADES INVOLVING THE FIRM'S OTHER SECURITIES PRODUCTS. THE FIRM MADE NO CHANGES TO ITS SUPERVISORY SYSTEM TO INCORPORATE GUIDANCE PROVIDED IN A REGULATORY NOTICE IN REVIEWING ETF ACTIVITY UNTIL AUGUST 2009, WHEN IT IMPLEMENTED WSPS FOR THE REVIEW OF NON-TRADITIONAL ETFS. THE FIRM FAILED TO EMPLOY A SYSTEM TO IDENTIFY WHICH OF THE ETFS BEING SOLD BY THE FIRM'S REGISTERED REPRESENTATIVES WERE NON-TRADITIONAL AND THEREFOR SUBJECT TO GREATER SCRUTINY. NEITHER THE FIRM'S TRADE BLOTTERS NOR ITS GENERAL SUPERVISORY REPORTS WERE CODED TO ALERT SUPERVISORS REGARDING THE LENGTH OF TIME CUSTOMERS HAD BEEN HOLDING NON- TRADITIONAL ETFS. THE FIRM'S SUPERVISORY SYSTEM WAS INADEQUATE TO DETECT AND MONITOR HOLDING PERIODS OF NON-TRADITIONAL ETFS IN CUSTOMER ACCOUNTS. THE FIRM DID NOT UTILIZE EXCEPTION REPORTS OR OTHER SURVEILLANCE TO MONITOR ETF ACTIVITY SPECIFICALLY INCLUDING THE CLASSIFICATION OF ETS AS LEVERAGED OR INVERSE. THE FIRM FAILED TO CONDUCT ANY TRAINING OR PROVIDE ANY WRITTEN GUIDANCE FOR ITS REGISTERED PERSONNEL REGARDING THE SALE AND SUPERVISION OF NON-TRADTIONAL ETFS.
Sanction detail — filed text
SEE ABOVE
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE, RESTITUTION 3. Date Initiated (MM/DD/YYYY): 04/11/2014 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2011025436101 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: EXCHANGE-TRADED FUNDS 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 THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO SUBJECT NON-TRADITIONAL EXCHANGE-TRADED FUNDS (ETFS) TO THE SAME LEVEL OF REVIEW AS OTHER NEW PRODUCTS OFFERED FOR SALE TO RETAIL BROKERAGE CUSTOMERS. THE FINDINGS STATED THAT INSTEAD, THE FIRM ALLOWED ITS REGISTERED REPRESENTATIVES TO RECOMMEND TO CUSTOMERS NON-TRADITIONAL ETFS WITHOUT PERFORMING REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES ASSOCIATED WITH IT. THE FIRM PERMITTED REPRESENTATIVES WHO RECEIVED MINIMAL TRAINING ON NON-TRADITIONAL ETFS AND WHO FAILED TO PERFORM REASONABLE DILIGENCE TO UNDERSTAND THE RISKS AND FEATURES OF THE PRODUCT, TO RECOMMEND TO CUSTOMERS TRANSACTIONS IN NON- TRADITIONAL ETFS. BY FIALING TO EMPLOY REASONABLE DILIGENCE REGARDING NON-TRADITIONAL ETFS, THE FIRM MISSED THE OPPORTUNITY TO EVALUATE CRITICAL ASPECTS OF THESE PRODUCTS INCLUDING THE IMPLICATIONS OF THE DAILY RESET AND LEVEDRAGE COMPONENTS AND TO ESTABLISH APPROPRIATE TRAINING AND SUPERVISION PROTOCOLS. ACCORDINGLY, THESE RECOMMENDATIONS LACKED A REASONABLE BASIS AND WERE UNSUITABLE. THE FINDINGS ALSO STATED THAT SOME NON-TRADITIONAL ETFS PURCHASES THAT THE FIRM RECOMMENDED, ACTING THROUGH SEVERAL BROKERS, WERE ALSO UNSUITABLE UNDER A CUSTOMER-SPECIFIC SUITABILITY THEORY AS THE RECOMMENDATIONS WERE MADE TO CUSTOMERS WITH CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES. THE PROSPECTUSES FOR THE NON-TRADITIONAL ETFS THAT THE FIRM SOLD GENERALLY ADVISED THAT THEY SHOULD NOT BE HELD MORE THAN ONE TRADING SESSION OR AS LONG-TERM INVESTMENTS. NOTWITHSTANDING THAT STATEMENT IN THE PROSPECTUSES, NON-TRADITIONAL ETFS WERE MAINTAINED IN CUSTOMER ACCOUNTS FOR LONGER THAN SEVEN BUSINESS DAYS. CUSTOMERS WHO HAD CONSERVATIVE INVESTMENT OBJECTIVES AND/OR RISK TOLERANCES AND WHOSE ETFS WERE HELD FOR SEVEN OR MORE DAYS, LOST MONEY ON THEIR INVESTEMENTS. THESE UNSUITABLE NON-TRADITIONAL ETF RECOMMENDATIONS RESULTED IN CUSTOMER LOSSES OF $287,171.75. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM, INCLUDING WRITTEN SUPERVISORY PROCEDURES (WSPS), TO MONITOR AND REVIEW THE SALE OF NON-TRADITIONAL ETFS TO ITS RETAIL CUSTOMERS AND THE FIRM FAILED TO ESTABLISH AND MAINTAIN SPECIFIC WSPS FOR THE REVIEW OF NON-TRADITIONAL EFT TRANSACTIONS. THE SUPERVISORY REVIEWS THAT THE FIRM'S PRINCIPALS PERFORMED OF TRANSACTIONS INVOLVING NON-TRADITONAL ETFS WERE INADEQUATE. THEY FAILED TO INCORPORATE THE COMPLEXITIES AND UNIQUE RISKS ASSOCIATED WITH THESE SECURITIES, SUCH AS THEIR DAILY RESET AND LEVERAGE FEATURES. INSTEAD, THE FIRM'S PRINCIPALS REVIEWED NON-TRADTIONAL ETF TRANSACTIONS FOR SUITABILITY IN THE SAME MANNER THEY REVIEWED TRADES INVOLVING THE FIRM'S OTHER SECURITIES PRODUCTS. THE FIRM MADE NO CHANGES TO ITS SUPERVISORY SYSTEM TO INCORPORATE GUIDANCE PROVIDED IN A REGULATORY NOTICE IN REVIEWING ETF ACTIVITY UNTIL AUGUST 2009, WHEN IT IMPLEMENTED WSPS FOR THE REVIEW OF NON-TRADITIONAL ETFS. THE FIRM FAILED TO EMPLOY A SYSTEM TO IDENTIFY WHICH OF THE ETFS BEING SOLD BY THE FIRM'S REGISTERED REPRESENTATIVES WERE NON-TRADITIONAL AND THEREFOR SUBJECT TO GREATER SCRUTINY. NEITHER THE FIRM'S TRADE BLOTTERS NOR ITS GENERAL SUPERVISORY REPORTS WERE CODED TO ALERT SUPERVISORS REGARDING THE LENGTH OF TIME CUSTOMERS HAD BEEN HOLDING NON- TRADITIONAL ETFS. THE FIRM'S SUPERVISORY SYSTEM WAS INADEQUATE TO DETECT AND MONITOR HOLDING PERIODS OF NON-TRADITIONAL ETFS IN CUSTOMER ACCOUNTS. THE FIRM DID NOT UTILIZE EXCEPTION REPORTS OR OTHER SURVEILLANCE TO MONITOR ETF ACTIVITY SPECIFICALLY INCLUDING THE CLASSIFICATION OF ETS AS LEVERAGED OR INVERSE. THE FIRM FAILED TO CONDUCT ANY TRAINING OR PROVIDE ANY WRITTEN GUIDANCE FOR ITS REGISTERED PERSONNEL REGARDING THE SALE AND SUPERVISION OF NON-TRADTIONAL ETFS. 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): 04/11/2014 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: $ 75,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: RESTITUTION TO CUSTOMERS IN THE AMOUNT OF $287,171.75 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: SEE ABOVE 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).
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