Firm profile

Ibn Financial Services, Inc.

LIVERPOOL, NYCRD 42360Registration Status: ApprovedEffective since October 12, 2017SEC # 801-111848Latest ADV August 27, 2026

Ibn Financial Services, Inc is an SEC registered investment adviser organized as a corporation with a primary office location in Liverpool, NY. Its latest Form ADV filing, dated August 27, 2026, reports $88M in regulatory assets under management, 52 employees, 1 office, and 519 accounts.

Assets Under Management
$88M
Employees
52
Offices
1 office
Total Clients
519

Associated firm names

3 names listed
  • IBN FINANCIAL SERVICES, INC
  • M. ROBERT BURTON ASSOCIATES, INC.
  • IBN FINANCIAL SERVICES, INC.

Leadership

2 roles identified
CEORichard James Jr Carlesco
CCOMonica Ann Coles

Advisory services offered

3 types reported
Financial Planning Services
Portfolio management for individuals and small businesses
Selection of other advisers

Fee models offered

3 types reported
Asset based fees
Hourly charges
Other fee arrangements

Offices & Contact

Primary office

LIVERPOOL, New York, United States

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Primary office regionOther reported regions

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

New York

LIVERPOOLPrimary office

1 office records listed · 1 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links
Phone315-652-4426
WebsiteNot found
LinkedInNot found

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$88Mas of August 27, 2026
Discretionary100.0%
$88M
100% of total RAUM100.0%
Non-discretionary0.0%
$0
0% of total RAUM0.0%
All regulatory assets under management are discretionary.

Client Coverage Demographics

Top client segmentIndividuals represent 88.1% of total clients.
Top client categories% of clientsClients
1
Individuals
88.1%
457
2
HNWI
7.7%
40
3
Pension Plans
1.9%
10
4
Charitable
1.2%
6
5
Corporations
1.2%
6

Assets under management Growth by Quarter

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

Total AUM$88M
Total Accounts519
10Y AUM Change+$32M (+56.6%)

Private Funds

Private funds reported by Ibn Financial Services, Inc.

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Employee Growth by Quarter

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

Total Employees52
Clients per Employee10:1
10Y Employee Change+45 (+642.9%)

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

Each range applies to a separate reported relationship and should not be added together.

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
RICHARD JAMES JR CARLESCODirect owner · Schedule AInterest in IBN FINANCIAL SERVICES, INC
50% to < 75%
CHRISTOPHER RYAN AVERYDirect owner · Schedule AInterest in IBN FINANCIAL SERVICES, INC
25% to < 50%
TIMOTHY EDWARD EVANSDirect owner · Schedule AInterest in IBN FINANCIAL SERVICES, INC
5% to < 10%

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 Ibn Financial Services, Inc..

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

Reported ownership and control details

Form ADV · Filing date 2026-08-27 · Schedules A and B

5 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1RICHARD JAMES JR CARLESCOCHIEF EXECUTIVE OFFICER, CHEIF FINANCIAL OFFICERIndividualIBN FINANCIAL SERVICES, INC50% to less than 75%Code DYesCHIEF EXECUTIVE OFFICER, CHEIF FINANCIAL OFFICER09/2002Schedule APDF page 20
2CHRISTOPHER RYAN AVERYCHIEF OPERATIONS OFFICERIndividualIBN FINANCIAL SERVICES, INC25% to less than 50%Code CNoCHIEF OPERATIONS OFFICER10/2017Schedule APDF page 20
3TIMOTHY EDWARD EVANSEQUITY PARTNERIndividualIBN FINANCIAL SERVICES, INC5% to less than 10%Code ANoEQUITY PARTNER04/2015Schedule APDF page 20
4MONICA ANN COLESCHIEF COMPLIANCE OFFICERIndividualIBN FINANCIAL SERVICES, INCLess than 5%Code NANoCHIEF COMPLIANCE OFFICER07/2026Schedule APDF page 20
5KAREN LE'ELLEN COKERDIRECTORIndividualIBN FINANCIAL SERVICES, INCLess than 5%Code NANoDIRECTOR07/2026Schedule APDF page 20

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 8/27/2026 12:11:40 PM

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 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 actions3 Yes2 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?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 actions2 Yes2 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?Yes
FProfessional authorizations1 No
  • FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
  • GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No

(1) Court actions

Has a domestic or foreign court:

  • H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
  • H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
  • H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No

(2) Pending civil proceedings

  • H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 8 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 21–22
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) 
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
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:
11. Resolution Date (MM/DD/YYYY):
 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: 
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 2PDF pages 22–24
Regulator name — filed text
STATE OF VERMONT
Monetary/Fine Amount — filed text
$ 2,000.00
How was matter resolved — filed text
Consent

Action status / disposition — filed text

THE FIRM PAID THE FINE ASSOCIATED WITH THE NON-SALES PRACTICE ISSUES.
Other filed details

Description of allegations — filed text

RESPONDENT VIOLATION REGULATION S-2016-01, 3-1(3) FOR FAILING TO HAVE AT LEAST ONE AGENT REGISTERED IN THE STATE OF VERMONT.

Sanction detail — filed text

THE FIRM AS FINED $2,000 BY THE STATE OF VERMONT.
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 VERMONT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
06/01/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
19-021-S
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
STATE REGISTRATION ISSUES.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
RESPONDENT VIOLATION REGULATION S-2016-01, 3-1(3) FOR FAILING TO HAVE AT LEAST ONE AGENT REGISTERED IN THE STATE OF VERMONT.
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):
08/29/2019
 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: $ 2,000.00
 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 AS FINED $2,000 BY THE STATE OF VERMONT.
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 PAID THE FINE ASSOCIATED WITH THE NON-SALES PRACTICE ISSUES.
regulatory · block 3PDF pages 24–26
Regulator name — filed text
ATTORNEY GENERAL OF THE STATE OF NEW YORK. INVESTOR PROTECTION BUREAU.
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

APPLICANT IS TO PAY NY AG IN EQUAL MONTHLY INSTALLMENTS FOR A PERIOD OF 6 MONTHS FOR BOTH THE FINE AND DISGORGEMENT FEES.
Other filed details

Description of allegations — filed text

MISREPRESENTATION. FAILURE TO DISCLOSE THAT SELLER CONTINUED TO OWN THE PENSIONS AND COULD STOP THE BENEFIT PAYMENTS BEING MADE TO THE INVESTOR.

Sanction detail — filed text

DISGORGEMENT OF $13035.29 IN COMMISSIONS EARNED. BARRED FOR A PERIOD OF FIVE YEARS FROM SELLING, MARKETING, BROKERING, OR SOLICITING, WITHIN NEW YORK STATE OR TO NEW YORK STATE RESIDENTS, ANY SECONDARY MARKET PENSION OR SIMILAR INVESTMENTS.
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) 
ATTORNEY GENERAL OF THE STATE OF NEW YORK. INVESTOR PROTECTION BUREAU.
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
APPLICANT IS BARRED FOR A PERIOD OF FIVE YEARS FROM SELLING, MARKETING, BROKERING, OR SOLICITING, WITHIN NEW YORK STATE OR TO NEW
YORK STATE RESIDENTS, ANY SECONDARY MARKET PENSION OR SIMILAR INVESTMENTS.
3.
Date Initiated (MM/DD/YYYY): 
03/01/2014
 Exact
 Explanation
If not exact, provide explanation:
NY ATTORNEY GENERAL BEGAN ITS GENERAL INVESTIGATION OF THE PRODUCTS, NOT LIMITED TO APPLICANT AT THAT TIME.
4.
Docket/Case Number:
ASSURANCE NO. 16-111
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
SECONDARY MARKET PENSION
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MISREPRESENTATION. FAILURE TO DISCLOSE THAT SELLER CONTINUED TO OWN THE PENSIONS AND COULD STOP THE BENEFIT PAYMENTS BEING
MADE TO THE INVESTOR.
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):
06/03/2016
 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: $ 10,000.00
 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: 
DISGORGEMENT OF $13035.29 IN COMMISSIONS EARNED. BARRED FOR A PERIOD OF FIVE YEARS FROM SELLING, MARKETING, BROKERING, OR
SOLICITING, WITHIN NEW YORK STATE OR TO NEW YORK STATE RESIDENTS, ANY SECONDARY MARKET PENSION OR SIMILAR INVESTMENTS.
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).
APPLICANT IS TO PAY NY AG IN EQUAL MONTHLY INSTALLMENTS FOR A PERIOD OF 6 MONTHS FOR BOTH THE FINE AND DISGORGEMENT FEES.
regulatory · block 4PDF pages 26–27
Regulator name — filed text
COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES BUREAU OF SECURITIES LICENSING COMPLIANCE AND ENFORCEMENT
Monetary/Fine Amount — filed text
$ 10,000.00
How was matter resolved — filed text
Settled

Action status / disposition — filed text

IBN ENTERED INTO THE SUBJECT CONSENT ORDER IN LIEU OF LITIGATION, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.
Other filed details

Description of allegations — filed text

THE DEPARTMENT ALLEGED THAT THE FIRM FAILED TO REASONABLY SUPERVISE IT'S AGENT WHOSE CONTINUED REGISTRATION IN PENNSYLVANIA WAS SUBJECT TO A PLAN OF HEIGHTENED SUPERVISION.

Sanction detail — filed text

ADMINISTRATIVE ASSESSMENT OF $10000.00 PAID 07/01/2014 INVESTIGATIVE AND LEGAL COSTS OF $5000.00 PAID 07/01/2014
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) 
COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF BANKING AND SECURITIES BUREAU OF SECURITIES LICENSING COMPLIANCE AND ENFORCEMENT

2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
07/01/2014
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014-03-04 (#140024)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
IBN FINANCIAL SERVICES, INC.
6.
Principal Product Type:
No Product
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE DEPARTMENT ALLEGED THAT THE FIRM FAILED TO REASONABLY SUPERVISE IT'S AGENT WHOSE CONTINUED REGISTRATION IN PENNSYLVANIA WAS
SUBJECT TO A PLAN OF HEIGHTENED SUPERVISION.
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):
07/01/2014
 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: $ 10,000.00
 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: 
ADMINISTRATIVE ASSESSMENT OF $10000.00 PAID 07/01/2014 INVESTIGATIVE AND LEGAL COSTS OF $5000.00 PAID 07/01/2014
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).
IBN ENTERED INTO THE SUBJECT CONSENT ORDER IN LIEU OF LITIGATION, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS.
regulatory · block 5PDF pages 27–29
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 15,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

WE DID NOT KNOW WE HAD TO ACCRUE SOME OF THE FIRMS EXPENSES. THESE EXPENSES WERE PAID PERSONALLY BY THE OWNER OF THE FIRM. UPON REVIEW WE REALIZED THAT THESE HAD TO BE PAID BY THE FIRM. AT NO TIME WAS ANY CLIENT OR EMPLOYEE IN JEOPARDY.
Other filed details

Description of allegations — filed text

ON SEVERAL OCCASIONS FROM DECEMBER 2015 THROUGH SEPTEMBER 2016 THE FIRM CONDUCTED SECURITIES BUSINESS WHILE FAILING TO MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL

Sanction detail — filed text

FINE OF $15,000.00. FIRM HAS REQUESTED AN INSTALLMENT PAYMENT PLAN.
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:
Censure
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
11/17/2016
 Exact
 Explanation
If not exact, provide explanation:
TO THE BEST OF THE FIRM'S KNOWLEDGE
4.
Docket/Case Number:
2016049862001
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):
ON SEVERAL OCCASIONS FROM DECEMBER 2015 THROUGH SEPTEMBER 2016 THE FIRM CONDUCTED SECURITIES BUSINESS WHILE FAILING TO
MAINTAIN ITS REQUIRED MINIMUM NET CAPITAL
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
05/10/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 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: 
FINE OF $15,000.00. FIRM HAS REQUESTED AN INSTALLMENT PAYMENT PLAN.
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).
WE DID NOT KNOW WE HAD TO ACCRUE SOME OF THE FIRMS EXPENSES. THESE EXPENSES WERE PAID PERSONALLY BY THE OWNER OF THE FIRM.
UPON REVIEW WE REALIZED THAT THESE HAD TO BE PAID BY THE FIRM. AT NO TIME WAS ANY CLIENT OR EMPLOYEE IN JEOPARDY.
regulatory · block 6PDF pages 29–31
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 30,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

THE FIRM IS PAYING ACCORDING TO APPROVED PLAN AND HAS TERMINATED ASSOCIATION WITH THE SUBJECT INDIVIDUALS.
Other filed details

Description of allegations — filed text

THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ENSURE IT EVALUATED WHETHER ITS REGISTERED PERSONS PROPOSED OBAS CONSTITUTED OUTSIDE SECURITIES ACTIVITIES. THAT TWO OF ITS REGISTERED REPRESENTATIVES WERE ENGAGED IN OBAS THAT INVOLVED INVESTMENT FUNDS AND PRIVATE PLACEMENT OFFERINGS, BUT DID NOT EVALUATE WHETHER THE ACTIVITY CONSTITUTED AN OUTSIDE SECURITIES ACTIVITY. NONE OF THE INVESTORS WERE FIRM CUSTOMERS

Sanction detail — filed text

FIRM WAS CENSURED AND FINED #30,000.
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: 
3.
Date Initiated (MM/DD/YYYY): 
09/20/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022075812301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
INVESTMENT FUNDS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ENSURE IT
EVALUATED WHETHER ITS REGISTERED PERSONS PROPOSED OBAS CONSTITUTED OUTSIDE SECURITIES ACTIVITIES. THAT TWO OF ITS REGISTERED
REPRESENTATIVES WERE ENGAGED IN OBAS THAT INVOLVED INVESTMENT FUNDS AND PRIVATE PLACEMENT OFFERINGS, BUT DID NOT EVALUATE
WHETHER THE ACTIVITY CONSTITUTED AN OUTSIDE SECURITIES ACTIVITY. NONE OF THE INVESTORS WERE FIRM CUSTOMERS
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):
09/20/2022
 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: $ 30,000.00
 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: 
FIRM WAS CENSURED AND FINED #30,000.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FIRM IS PAYING ACCORDING TO APPROVED PLAN AND HAS TERMINATED ASSOCIATION WITH THE SUBJECT INDIVIDUALS.
Show 2 more source blocks
regulatory · block 7PDF pages 31–33
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 45,000.00
How was matter resolved — filed text
Acceptance, Waiver & Consent(AWC)

Action status / disposition — filed text

THE FIRM'S DESIGNATED PRINCIPAL INADVERTENTLY FAILED TO TIMELY OPEN AND REVIEW AN E-MAIL FROM THE INVESTMENT PRODUCT SPONSOR THAT CONTAINED INFORMATION ABOUT A DELAY IN THE ISSUER'S MAKING OF REQUIRED FILINGS WITH THE SEC. AS SUCH, THE FIRM AND ITS REPRESENTATIVES DID NOT HAVE ACTUAL KNOWLEDGE OF THE DELAY IN THE REQUIRED FILINGS AT THE TIME OF THE EIGHT SALES TO CLIENTS REFERENCED IN THE AWC.
Other filed details

Description of allegations — filed text

BETWEEN JUNE 8, 2018, AND JUNE 29, 2018, IBN NEGLIGENTLY OMITTED TO TELL EIGHT INVESTORS IN TWO OFFERINGS RELATED TO GPB CAPITAL HOLDINGS, LLC (GPB CAPITAL) THAT THE ISSUER FAILED TO TIMELY MAKE REQUIRED FILINGS WITH THE SECURITIES AND EXCHANGE COMMISSION,INCLUDING FILING AUDITED FINANCIAL STATEMENTS. THIS CONSITUTES A VIOLATION OF FINRA RULE 2010.

Sanction detail — filed text

FINE $45,000.00 PARTIAL RESTITUTION (DISGORGEMENT) $32,385.00 TO PAID ACCORDING TO ACCEPTED INSTALLMENT PAYMENT PLAN
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:
Censure
Other Sanctions: 
FINE,PARTIAL RESTITUTION
3.
Date Initiated (MM/DD/YYYY): 
04/14/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019061214401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Direct Investment(s) - DPP & LP Interest(s)
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
BETWEEN JUNE 8, 2018, AND JUNE 29, 2018, IBN NEGLIGENTLY OMITTED TO TELL EIGHT INVESTORS IN TWO OFFERINGS RELATED TO GPB CAPITAL
HOLDINGS, LLC (GPB CAPITAL) THAT THE ISSUER FAILED TO TIMELY MAKE REQUIRED FILINGS WITH THE SECURITIES AND EXCHANGE
COMMISSION,INCLUDING FILING AUDITED FINANCIAL STATEMENTS. THIS CONSITUTES A VIOLATION OF FINRA RULE 2010.
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):
04/14/2022
 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: $ 45,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
PARTIAL RESTITUTION (DISGORGEMENT) $32,385.00
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: 
FINE $45,000.00 PARTIAL RESTITUTION (DISGORGEMENT) $32,385.00 TO PAID ACCORDING TO ACCEPTED INSTALLMENT PAYMENT PLAN
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'S DESIGNATED PRINCIPAL INADVERTENTLY FAILED TO TIMELY OPEN AND REVIEW AN E-MAIL FROM THE INVESTMENT PRODUCT SPONSOR
THAT CONTAINED INFORMATION ABOUT A DELAY IN THE ISSUER'S MAKING OF REQUIRED FILINGS WITH THE SEC. AS SUCH, THE FIRM AND ITS
REPRESENTATIVES DID NOT HAVE ACTUAL KNOWLEDGE OF THE DELAY IN THE REQUIRED FILINGS AT THE TIME OF THE EIGHT SALES TO CLIENTS
REFERENCED IN THE AWC.
regulatory · block 8EVANS, TIMOTHY EDWARDPDF pages 33–35
Advisory affiliate name — filed text
EVANS, TIMOTHY EDWARD
Regulator name — filed text
FINRA
Monetary/Fine Amount — filed text
$ 50,000.00
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 THE THE ENTRY OF FINDINGS THAT IT WILLFULLY VIOLATED RULE 15L-1(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 (REG BI) BY FAILING TO REASONABLY SUPERVISE, AND FAILING TO ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG BI WITH RESPECT TO A REGISTERED REPRESENTATIVE'S RECOMMENDATIONS OF ALTERNATIVE INVESTMENTS, INCLUDING A NON-TRADED REAL ESTATE INVESTMENT TRUST (REIT) TO TWO RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM AND THE REPRESENTATIVE'S DIRECT BUSINESS LINE SUPERVISOR FAILED TO REASONABLY SUPERVISE THE REGISTERED REPRESENTATIVE'S RECOMMENDATIONS OF SPECULATIVE ALTERNATIVE INVESTMENTS TO THE RETAIL CUSTOMERS WHERE THE SALES WERE NOT SUITABLE OR IN THE BEST INTERESTS OF THE CUSTOMERS GIVEN THE CUSTOMERS' INVESTMENT PROFILES. THE SUPERVISOR WAS RESPONSIBLE FOR REVIEWING FOR SUPERVISORY APPROVAL APPLICATIONS TO PURCHASE ALTERNATIVE INVESTMENTS SUBMITTED BY THE REPRESENTATIVE. IN JANUARY 2019, THE REPRESENTATIVE RECOMMENDED FIVE ILLIQUID, NON-TRADED ALTERNATIVE INVESTMENTS TOTALING $400,000 TO THE FIRST CUSTOMER. THE AND THE SUPERVISOR APPROVED THE SALES NOTWITHSTANDING THE PRESENCE OF RED FLAGS SUGGESTING THAT THE SALES WERE UNSUITABLE. SPECIFICALLY, THE FIRM AND THE SUPERVISOR WERE AWARE FROM THE APPLICATION DOCUMENTS THAT THE CUSTOMER WAS 71 YEARS OLD, RETIRED, HAD A MODERATE RISK TOLERANCE, AND HAD A NET WORTH, NOT INCLUDING PRIMARY RESIDENCE OF $851,889. THE FIRM AND THE SUPERVISOR NEVERTHELESS APPROVED THE FIVE SALES, WHICH RESULTED IN THE CUSTOMER HAVING A 47% CONCENTRATION IN SPECULATIVE ALTERNATIVE INVESTMENTS. SUBSEQUENTLY, THE REPRESENTATIVE RECOMMENDED 11 SALES OF ILLIQUID, NON- TRADED ALTERNATIVE INVESTMENTS TOTALING $457,000 TO A SECOND CUSTOMER. THIS INCLUDED $90,000 OF THE NON-TRADED REIT. AGAIN, THE FIRM AND THE SUPERVISOR APPROVED THE SALES NOTWITHSTANDING THE PRESENCE OF RED FLAGS SUGGESTING THAT THE SALES WERE NOT IN THE CUSTOMER'S BEST INTEREST. SPECIFICALLY, IBN AND THE SUPERVISOR WERE AWARE FROM THE APPLICATION DOCUMENTS THAT THE CUSTOMER HAD AN ANNUAL INCOME OF NO MORE THAN $25,000, HAD A MODERATE RISK TOLERANCE, AND HAD A NET WORTH, NOT INCLUDING PRIMARY RESIDENCE, OF $587,438. THE FIRM AND THE SUPERVISOR NEVERTHELESS APPROVED THE SALES, WHICH RESULTED IN THE CUSTOMER HAVING A 77% CONCENTRATION IN SPECULATIVE ALTERNATIVE INVESTMENTS, INCLUDING 15% IN THE REIT. DESPITE RED FLAGS THAT THE RECOMMENDATIONS WERE UNSUITABLE FOR, AND NOT IN THE BEST INTEREST OF, RESPECTIVELY, THE TWO CUSTOMERS, THE FIRM AND THE SUPERVISOR DID NOT CONDUCT ANY FURTHER REVIEW OR TAKE ANY FURTHER STEPS BEFORE APPROVING THE TRANSACTIONS, SUCH AS EVALUATING WHETHER THE REPRESENTATIVE HAD GOOD CAUSE FOR THE RECOMMENDATIONS GIVEN THE CONCENTRATION LEVELS AT ISSUE AS REQUIRED BY THE FIRM'S WSPS. NOR DID THE FIRM MAINTAIN WRITTEN POLICIES AND PROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG BI WITH RESPECT TO THE REGISTERED REPRESENTATIVE'S RECOMMENDATIONS.

Sanction detail — filed text

THE FIRM WAS CENSURED, FINED $50,000, AND REQUIRED TO CERTIFY IN WRITING THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE AWC AND IMPLEMENTED A REASONABLY DESIGNED SUPERVISORY SYSTEM, INCLUDING WSPS. FINE PAID IN FULL ON FEBRUARY 14, 2025.
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:
6259284
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
EVANS, TIMOTHY EDWARD
(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:
Other
Other Sanctions: 
N/A
3.
Date Initiated (MM/DD/YYYY): 
01/29/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2022076855801
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
ALTERNATIVE INVESTMENTS, INCLUDING A NON-TRADED REAL ESTATE INVESTMENT TRUST (REIT)
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 THE THE ENTRY OF FINDINGS THAT IT WILLFULLY
VIOLATED RULE 15L-1(A)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 (REG BI) BY FAILING TO REASONABLY SUPERVISE, AND FAILING TO ENFORCE
WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG BI WITH RESPECT TO A REGISTERED
REPRESENTATIVE'S RECOMMENDATIONS OF ALTERNATIVE INVESTMENTS, INCLUDING A NON-TRADED REAL ESTATE INVESTMENT TRUST (REIT) TO TWO
RETAIL CUSTOMERS. THE FINDINGS STATED THAT THE FIRM AND THE REPRESENTATIVE'S DIRECT BUSINESS LINE SUPERVISOR FAILED TO REASONABLY
SUPERVISE THE REGISTERED REPRESENTATIVE'S RECOMMENDATIONS OF SPECULATIVE ALTERNATIVE INVESTMENTS TO THE RETAIL CUSTOMERS
WHERE THE SALES WERE NOT SUITABLE OR IN THE BEST INTERESTS OF THE CUSTOMERS GIVEN THE CUSTOMERS' INVESTMENT PROFILES. THE
SUPERVISOR WAS RESPONSIBLE FOR REVIEWING FOR SUPERVISORY APPROVAL APPLICATIONS TO PURCHASE ALTERNATIVE INVESTMENTS SUBMITTED
BY THE REPRESENTATIVE. IN JANUARY 2019, THE REPRESENTATIVE RECOMMENDED FIVE ILLIQUID, NON-TRADED ALTERNATIVE INVESTMENTS TOTALING
$400,000 TO THE FIRST CUSTOMER. THE AND THE SUPERVISOR APPROVED THE SALES NOTWITHSTANDING THE PRESENCE OF RED FLAGS SUGGESTING
THAT THE SALES WERE UNSUITABLE. SPECIFICALLY, THE FIRM AND THE SUPERVISOR WERE AWARE FROM THE APPLICATION DOCUMENTS THAT THE
CUSTOMER WAS 71 YEARS OLD, RETIRED, HAD A MODERATE RISK TOLERANCE, AND HAD A NET WORTH, NOT INCLUDING PRIMARY RESIDENCE OF
$851,889. THE FIRM AND THE SUPERVISOR NEVERTHELESS APPROVED THE FIVE SALES, WHICH RESULTED IN THE CUSTOMER HAVING A 47%
CONCENTRATION IN SPECULATIVE ALTERNATIVE INVESTMENTS. SUBSEQUENTLY, THE REPRESENTATIVE RECOMMENDED 11 SALES OF ILLIQUID, NON-
TRADED ALTERNATIVE INVESTMENTS TOTALING $457,000 TO A SECOND CUSTOMER. THIS INCLUDED $90,000 OF THE NON-TRADED REIT. AGAIN, THE
FIRM AND THE SUPERVISOR APPROVED THE SALES NOTWITHSTANDING THE PRESENCE OF RED FLAGS SUGGESTING THAT THE SALES WERE NOT IN THE
CUSTOMER'S BEST INTEREST. SPECIFICALLY, IBN AND THE SUPERVISOR WERE AWARE FROM THE APPLICATION DOCUMENTS THAT THE CUSTOMER HAD
AN ANNUAL INCOME OF NO MORE THAN $25,000, HAD A MODERATE RISK TOLERANCE, AND HAD A NET WORTH, NOT INCLUDING PRIMARY RESIDENCE,
OF $587,438. THE FIRM AND THE SUPERVISOR NEVERTHELESS APPROVED THE SALES, WHICH RESULTED IN THE CUSTOMER HAVING A 77%
CONCENTRATION IN SPECULATIVE ALTERNATIVE INVESTMENTS, INCLUDING 15% IN THE REIT. DESPITE RED FLAGS THAT THE RECOMMENDATIONS
WERE UNSUITABLE FOR, AND NOT IN THE BEST INTEREST OF, RESPECTIVELY, THE TWO CUSTOMERS, THE FIRM AND THE SUPERVISOR DID NOT
CONDUCT ANY FURTHER REVIEW OR TAKE ANY FURTHER STEPS BEFORE APPROVING THE TRANSACTIONS, SUCH AS EVALUATING WHETHER THE
REPRESENTATIVE HAD GOOD CAUSE FOR THE RECOMMENDATIONS GIVEN THE CONCENTRATION LEVELS AT ISSUE AS REQUIRED BY THE FIRM'S WSPS.
NOR DID THE FIRM MAINTAIN WRITTEN POLICIES AND PROCEDURES THAT WERE REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG BI WITH
RESPECT TO THE REGISTERED REPRESENTATIVE'S RECOMMENDATIONS.
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):
01/29/2025
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 50,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE FIRM WAS CENSURED, FINED $50,000, AND REQUIRED TO CERTIFY IN WRITING THAT IT HAS REMEDIATED THE ISSUES IDENTIFIED IN THE
AWC AND IMPLEMENTED A REASONABLY DESIGNED SUPERVISORY SYSTEM, INCLUDING WSPS. FINE PAID IN FULL ON FEBRUARY 14, 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

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