Supreme Alliance LLC

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: 
THE FIRM IS CENSURED, FINED $65,000, AND AGREES TO THE UNDERTAKINGS THAT IT WILL CERTIFY IN WRITING THAT IT HAS NOTIFIED THOSE
CUSTOMERS WHOSE IDENTIFYING INFORMATION WAS TRANSMITTED TO THE UNAUTHORIZED EMAIL ACCOUNT, THAT IT HAS REVISED ITS IDENTITY
THEFT PREVENTION PROGRAM TO ADDRESS THE DEFICIENCIES IDENTIFIED HEREIN, AND COMPLY WITH REGULATION S-ID, AND THAT THE FIRM HAS
ENHANCED IT'S EMAIL SECURITY SYSTEMS.
3.
Date Initiated (MM/DD/YYYY): 
12/18/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019062898302
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
DEVELOP AND IMPLEMENT A WRITTEN IDENTITY THEFT PREVENTION PROGRAM (PROGRAM) REASONABLY DESIGNED TO DETECT, PREVENT, AND
MITIGATE IDENTITY THEFT IN CONNECTION WITH OPENING OR MAINTAINING CUSTOMER ACCOUNTS. THE FINDINGS STATED THAT THE FIRM'S PROGRAM
FAILED TO INCLUDE REASONABLE POLICIES AND PROCEDURES TO IDENTIFY OR DETECT RED FLAGS OF IDENTITY THEFT, AND ITS PROCEDURES FOR
RESPONDING TO SUSPECTED IDENTITY THEFT WERE NOT TAILORED TO ITS BUSINESS. ALTHOUGH NOTFORMALLY TITLED IDENTITY THEFT PREVENTION
PROGRAM, THE FIRM HAD WRITTEN PROCEDURES IN PLACE TO RESPOND TO RED FLAGS OF IDENTITY THEFT. THE PROGRAM FAILED TO PROVIDE
ASSOCIATED PERSONS ANY GUIDANCE REGARDING STEPS TO TAKE IN THE EVENT HEOR SHE SUSPECTED THAT AN INCIDENT OF IDENTITY THEFT HAD
OCCURRED. MOREOVER, THE FIRM'S PROGRAM CONSISTED OF GENERIC POLICIES AND PROCEDURES AND WAS NOT TAILED TO THE FIRM'S ACTUAL
BUSINESS MODEL. THE FINDINGS ALSO STATED THAT UPON LEARNING OF AN EMAIL SECURITY BREACH INVOLVING THE FIRM EMAIL ACCOUNT OF THE
FIRM'S CEO AND CCO, THE FIRM FAILED TO IMPLEMENT THE PROCEDURES SET FORTH IN ITS PROGRAM TO MITIGATE THE RISK OF IDENTITY THEFT DUE
TO THE EXPOSURE OF ITS CUSTOMERS' IDENTIFYING INFORMATION TO AN UNAUTHORIZED THIRD PARTY. THE FIRM'S CEO AND CCO BEGAN TO RECEIVE
HUNDREDS OF NOTIFICATIONS IN HIS FIRM EMAIL ACCOUNT MAILBOX STATING THAT EMAIL MESSAGES SENT FROM HIS FIRM ACCOUNT COULD NOT BE
DELIVERED TO A CERTAIN EXTERNAL EMAIL ADDRESS. ALTHOUGH THE FIRM'S CEO AND CCO DIDNOT RECOGNIZE THE EXTERNAL EMAIL ADDRESS, HE
IGNORED THEUNDELIVERABLE NOTIFICATIONS. HE FORWARDED ONE OF THEUNDELIVERABLE MESSAGES TO THE FIRM'S OUTSIDE EMAIL VENDOR,
INFORMING THE VENDOR THAT HE HAD RECEIVED MORE THAN 100 SUCH MESSAGES. THE VENDOR INFORMED HIM THERE WAS AN AUTOMATED RULE
SET UP ON HIS FIRM EMAIL ACCOUNT THAT BLIND-COPIED ALL EMAILS HE RECEIVED TO THE EXTERNAL EMAIL ADDRESS. THE VENDOR FURTHER
INFORMED HIM THAT HIS FIRM EMAIL ACCOUNT HAD LIKELY BEEN COMPROMISED. THE FIRM FAILED TO TAKE STEPS TO MITIGATE THE RISK OF
IDENTITY THEFT RESULTING FROM THE INCIDENT. FOR EXAMPLE, AT THE TIME IT DISCOVERED THE BREACH, THE FIRM MADE NO EFFORT TO DETERMINE
HOW MANY EMAILS HAD BEEN BLIND COPIED TO THE UNAUTHORIZED ACCOUNT, OR WHETHER CUSTOMERS' IDENTIFYING INFORMATION HAD BEEN
EXPOSED. IT WAS NOT UNTIL FINRA STAFF INQUIRED ABOUT EMAIL COMMUNICATIONS WITH THIS EXTERNAL EMAIL ADDRESS DURING THE FIRM'S
CYCLE EXAM, THAT THE FIRM ATTEMPTEDTO DETERMINE THE SCOPE OF THE BREACH. TO DATE, THE FIRM HAS NOT NOTIFIED ANY CUSTOMERS WHOSE
IDENTIFYING INFORMATION WAS EXPOSED BECAUSE OF THE INCIDENT. APPROXIMATELY 17,000 EMAILS WERE BLIND COPIED FROM THE FIRM'S CEO
AND CCO'S FIRM EMAIL ACCOUNT TO THE UNAUTHORIZED EXTERNAL EMAIL ADDRESS. AT LEAST200 OF THE BLIND-COPIED EMAILS CONTAINED
IDENTIFYING INFORMATION RELATING TO THE FIRM'S CUSTOMERS, INCLUDING CUSTOMERS' SOCIAL SECURITY, ACCOUNT NUMBERS, DRIVER'S
LICENSE NUMBERS, AND DATES OF BIRTH. TWENTY-ONE OF THE EMAILS CONTAINING CUSTOMER IDENTIFYING INFORMATION WERE BLIND COPIED
PRIOR TO THE DATE THE FIRM'S CEO AND CCO BEGAN TO RECEIVE MESSAGES THAT THE EMAILS TO THE EXTERNAL ADDRESSES COULD NOT BE
DELIVERED.
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):
12/18/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 65,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE FIRM IS CENSURED, FINED $65,000, AND AGREES TO THE UNDERTAKINGS THAT IT WILL CERTIFY IN WRITING THAT IT HAS NOTIFIED THOSE
CUSTOMERS WHOSE IDENTIFYING INFORMATION WAS TRANSMITTED TO THE UNAUTHORIZED EMAIL ACCOUNT, THAT IT HAS REVISED ITS
IDENTITY THEFT PREVENTION PROGRAM TO ADDRESS THE DEFICIENCIES IDENTIFIED HERE IN AND COMPLY WITH REGULATION S-ID,AND THAT
THE FIRM HAS ENHANCED ITS EMAIL SECURITY SYSTEMS.
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 $65,000 ASSESSED AGAINST THE APPLICANT, TO BE PAID THROUGH FINRA'S 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 SETTLED THIS MATTER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS TO AVOID THE UNCERTAINTIES OF LITIGATION.

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) 
NORTH CAROLINA DEPARTMENT OF INSURANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
FINE PAID ON 11/14/2024
3.
Date Initiated (MM/DD/YYYY): 
11/20/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1000114587
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: 
MUTUAL FUNDS, INSURANCE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO DISCLOSE FINRA ADMINISTRATIVE PROCEEDING ON 2021 NORTH CAROLINA LICENSE APPLICATION.
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):
11/20/2024
 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: $ 250.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension

B.
Other Sanctions Ordered:
NONE
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 PAID ON 11/14/2024
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).
FINE PAID ON 11/14/2024

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 MONETARY/FINE $80,000.00 ACCEPTANCE, WAIVER & CONSENT (AWC), UNDERTAKING.
3.
Date Initiated (MM/DD/YYYY): 
10/31/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020065125001
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IS FAILED TO
ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO SUPERVISE
RECOMMENDATIONS OF DEFERRED VARIABLE ANNUITY PURCHASES AND EXCHANGES TO ACHIEVE COMPLIANCE WITH RULE 2330 AND REG BI (FOR
CONDUCT POSTDATING JUNE 30, 2020). THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SYSTEM OR WSPS REASONABLY DESIGNED TO SUPERVISE
WHETHER THE FIRM'S REGISTERED REPRESENTATIVES MADE REASONABLE EFFORTS TO OBTAIN CUSTOMER PROFILE INFORMATION AND OTHER
INFORMATION NEEDED TO REASONABLY ASSESS THE SUITABILITY OF A TRANSACTION AND WHETHER THOSE TRANSACTIONS WERE IN THE
CUSTOMERS' BEST INTERESTS, INCLUDING CUSTOMERS' RISK TOLERANCES AND INFORMATION ABOUT LOST RIDER BENEFITS, PRIOR TO
RECOMMENDING THE PURCHASE OR EXCHANGE OF DEFERRED VARIABLE ANNUITIES. THE FIRM ALSO DID NOT HAVE A SYSTEM OR PROCEDURES
SUFFICIENT TO SUPERVISE WHETHER THERE WAS A REASONABLE BASIS TO BELIEVE THAT CUSTOMERS WERE ACCURATELY INFORMED ABOUT VARIOUS
FEATURES OF THE DEFERRED VARIABLE ANNUITIES THEY WERE RECOMMENDED, AS REQUIRED UNDER FINRA RULE 2330(B)(1)(A)(I), AND AS A RESULT,
FIRM SUPERVISORS APPROVED ANNUITY TRANSACTION APPLICATIONS LISTING INACCURATE COSTS, FEES, SURRENDER PERIODS, AND RIDER
INFORMATION. GIVEN THESE ISSUES, THE FIRM'S SUPERVISORY SYSTEM AND WSPS WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE
WITH THE REQUIREMENT IN RULE 2330(B)(1) TO ENSURE THAT THERE WAS A REASONABLE BASIS TO BELIEVE THAT RECOMMENDATIONS TO PURCHASE
OR EXCHANGE DEFERRED VARIABLE ANNUITIES WERE SUITABLE FOR THE CUSTOMERS OR IN THE CUSTOMERS' BEST INTEREST. SUPREME ALLIANCE
ALSO FAILED TO DOCUMENT PRINCIPAL REVIEW AND APPROVAL OF MULTIPLE VARIABLE ANNUITY APPLICATIONS SUBMITTED DURING THE RELEVANT
PERIOD, CONTRARY TO THE REQUIREMENTS OF FINRA RULES 2330(C). FURTHER, BETWEEN JUNE 30, 2020 AND APRIL 25, 2022, SUPREME ALLIANCE
FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG
BI. THE FIRM'S WRITTEN POLICIES AND PROCEDURES CONTAINED NO PROVISIONS RELATING TO REG BI DURING THAT PERIOD. FINALLY, BETWEEN
SEPTEMBER 2019 AND APRIL 2022, THE FIRM FAILED TO IMPLEMENT SURVEILLANCE PROCEDURES TO IDENTIFY IF ANY OF ITS REGISTERED
REPRESENTATIVES HAD INAPPROPRIATE EXCHANGES. THE FIRM DID NOT MAINTAIN POLICIES OR GUIDANCE EXPLAINING HOW THE FIRM WOULD
MONITOR RATES OF DEFERRED VARIABLE ANNUITY EXCHANGES, INCLUDING WHO WAS RESPONSIBLE FOR SUCH SURVEILLANCE, HOW OFTEN IT
WOULD TAKE PLACE, WHAT TOOLS TO USE TO CONDUCT THE SURVEILLANCE, OR WHAT PARAMETERS TO CONSIDER WHEN EVALUATING WHETHER
EXCHANGE RATES WERE INAPPROPRIATE. BETWEEN SEPTEMBER 2019 AND MAY 2022, SUPREME ALLIANCE FAILED TO ESTABLISH AND MAINTAIN A
SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE THE FIRM'S INVESTIGATIONS, DURING THE
HIRING PROCESS, INTO THE CHARACTER AND REPUTATION OF PROSPECTIVE REGISTERED REPRESENTATIVES, AND TO MAINTAIN RECORDS OF THOSE
INVESTIGATIONS. THE FIRM'S WRITTEN PROCEDURES DESCRIBED THE USE OF A CHECKLIST TO ENSURE CERTAIN STEPS WERE TAKEN DURING HIRING,
INCLUDING STEPS FOR VERIFICATION OF A CANDIDATE'S UNIFORM APPLICATION FOR SECURITIES REGISTRATION (FORM U4), DETAILS RELATED TO
CONTACTING THE CANDIDATE'S FORMER EMPLOYERS, AND FOR CREATING AND MAINTAINING DOCUMENTATION OF THE NEW HIRE INVESTIGATION.
HOWEVER, IN PRACTICE, THE FIRM DID NOT USE THIS CHECKLIST AND FAILED TO OTHERWISE MAINTAIN A SYSTEM REASONABLY DESIGNED TO
SUPERVISE THAT THE APPROPRIATE STEPS WERE TAKEN DURING THE HIRING PROCESS. FURTHER, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A
SYSTEM REASONABLY DESIGNED TO KEEP APPROPRIATE DOCUMENTATION OF ITS INVESTIGATIONS AT HIRING, INCLUDING RECORDS OF BACKGROUND
CHECKS AND DISCLOSURE FORMS REQUIRED UNDER THE FIRM'S PROCEDURES.
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):
10/31/2025
 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: $ 80,000.00
 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 FINE OF $80,000 ASSESSED AGAINST THE APPLICANT, TO BE PAID TO FINRA.
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 SETTLED THIS MATTER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS TO AVOID THE UNCERTAINTIES OF LITIGATION.

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 MONETARY/FINE $65,000.00 ACCEPTANCE, WAIVER & CONSENT (AWC), UNDERTAKING.
3.
Date Initiated (MM/DD/YYYY): 
12/18/2020
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2019062898302
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
DEVELOP AND IMPLEMENT A WRITTEN IDENTITY THEFT PREVENTION PROGRAM (PROGRAM) REASONABLY DESIGNED TO DETECT, PREVENT, AND
MITIGATE IDENTITY THEFT IN CONNECTION WITH OPENING OR MAINTAINING CUSTOMER ACCOUNTS. THE FINDINGS STATED THAT THE FIRM'S PROGRAM
FAILED TO INCLUDE REASONABLE POLICIES AND PROCEDURES TO IDENTIFY OR DETECT RED FLAGS OF IDENTITY THEFT, AND ITS PROCEDURES FOR
RESPONDING TO SUSPECTED IDENTITY THEFT WERE NOT TAILORED TO ITS BUSINESS. ALTHOUGH NOT FORMALLY TITLED IDENTITY THEFT PREVENTION
PROGRAM, THE FIRM HAD WRITTEN PROCEDURES IN PLACE TO RESPOND TO RED FLAGS OF IDENTITY THEFT. THE PROGRAM FAILED TO PROVIDE
ASSOCIATED PERSONS ANY GUIDANCE REGARDING STEPS TO TAKE IN THE EVENT HE OR SHE SUSPECTED THAT AN INCIDENT OF IDENTITY THEFT HAD
OCCURRED. MOREOVER, THE FIRM'S PROGRAM CONSISTED OF GENERIC POLICIES AND PROCEDURES AND WAS NOT TAILED TO THE FIRM'S ACTUAL
BUSINESS MODEL. THE FINDINGS ALSO STATED THAT UPON LEARNING OF AN EMAIL SECURITY BREACH INVOLVING THE FIRM EMAIL ACCOUNT OF THE
FIRM'S CEO AND CCO, THE FIRM FAILED TO IMPLEMENT THE PROCEDURES SET FORTH IN ITS PROGRAM TO MITIGATE THE RISK OF IDENTITY THEFT DUE
TO THE EXPOSURE OF ITS CUSTOMERS' IDENTIFYING INFORMATION TO AN UNAUTHORIZED THIRD PARTY. THE FIRM'S CEO AND CCO BEGAN TO RECEIVE
HUNDREDS OF NOTIFICATIONS IN HIS FIRM EMAIL ACCOUNT MAILBOX STATING THAT EMAIL MESSAGES SENT FROM HIS FIRM ACCOUNT COULD NOT BE
DELIVERED TO A CERTAIN EXTERNAL EMAIL ADDRESS. ALTHOUGH THE FIRM'S CEO AND CCO DID NOT RECOGNIZE THE EXTERNAL EMAIL ADDRESS, HE
IGNORED THE UNDELIVERABLE NOTIFICATIONS. HE FORWARDED ONE OF THE UNDELIVERABLE MESSAGES TO THE FIRM'S OUTSIDE EMAIL VENDOR,
INFORMING THE VENDOR THAT HE HAD RECEIVED MORE THAN 100 SUCH MESSAGES. THE VENDOR INFORMED HIM THERE WAS AN AUTOMATED RULE
SET UP ON HIS FIRM EMAIL ACCOUNT THAT BLIND-COPIED ALL EMAILS HE RECEIVED TO THE EXTERNAL EMAIL ADDRESS. THE VENDOR FURTHER
INFORMED HIM THAT HIS FIRM EMAIL ACCOUNT HAD LIKELY BEEN COMPROMISED. THE FIRM FAILED TO TAKE STEPS TO MITIGATE THE RISK OF
IDENTITY THEFT RESULTING FROM THE INCIDENT. FOR EXAMPLE, AT THE TIME IT DISCOVERED THE BREACH, THE FIRM MADE NO EFFORT TO DETERMINE
HOW MANY EMAILS HAD BEEN BLIND COPIED TO THE UNAUTHORIZED ACCOUNT, OR WHETHER CUSTOMERS' IDENTIFYING INFORMATION HAD BEEN
EXPOSED. IT WAS NOT UNTIL FINRA STAFF INQUIRED ABOUT EMAIL COMMUNICATIONS WITH THIS EXTERNAL EMAIL ADDRESS DURING THE FIRM'S
CYCLE EXAM, THAT THE FIRM ATTEMPTEDTO DETERMINE THE SCOPE OF THE BREACH. TO DATE, THE FIRM HAS NOT NOTIFIED ANY CUSTOMERS WHOSE
IDENTIFYING INFORMATION WAS EXPOSED BECAUSE OF THE INCIDENT. APPROXIMATELY 17,000 EMAILS WERE BLIND COPIED FROM THE FIRM'S CEO
AND CCO'S FIRM EMAIL ACCOUNT TO THE UNAUTHORIZED EXTERNAL EMAIL ADDRESS. AT LEAST200 OF THE BLIND-COPIED EMAILS CONTAINED
IDENTIFYING INFORMATION RELATING TO THE FIRM'S CUSTOMERS, INCLUDING CUSTOMERS' SOCIAL SECURITY, ACCOUNT NUMBERS, DRIVER'S
LICENSE NUMBERS, AND DATES OF BIRTH. TWENTY-ONE OF THE EMAILS CONTAINING CUSTOMER IDENTIFYING INFORMATION WERE BLIND COPIED
PRIOR TO THE DATE THE FIRM'S CEO AND CCO BEGAN TO RECEIVE MESSAGES THAT THE EMAILS TO THE EXTERNAL ADDRESSES COULD NOT BE
DELIVERED.
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)

p
(
)
11. Resolution Date (MM/DD/YYYY):
12/18/2020
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 65,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
THE FIRM IS CENSURED, FINED $65,000, AND AGREES TO THE UNDERTAKINGS THAT IT WILL CERTIFY IN WRITING THAT IT HAS NOTIFIED THOSE
CUSTOMERS WHOSE IDENTIFYING INFORMATION WAS TRANSMITTED TO THE UNAUTHORIZED EMAIL ACCOUNT, THAT IT HAS REVISED IT'S
IDENTIFY THEFT PREVENTION PROGRAM TO ADDRESS THE DEFICIENCIES IDENTIFIED HEREIN, AND COMPLY WITH REGULATION S-ID, AND THAT
THE FIRM HAS ENHANCED IT'S EMAIL SECURITY SYSTEMS.
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 OF $65,000 ASSESSED AGAINST THE APPLICANT, TO BE PAID THROUGH FINRA'S 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 SETTLED THIS MATTER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS TO AVOID THE UNCERTAINTIES OF LITIGATION.

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 MONETARY/FINE $80,000.00 ACCEPTANCE, WAIVER & CONSENT (AWC), UNDERTAKING.
3.
Date Initiated (MM/DD/YYYY): 
10/31/2025
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2020065125001
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IS FAILED TO
ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES (WSPS) REASONABLY DESIGNED TO SUPERVISE
RECOMMENDATIONS OF DEFERRED VARIABLE ANNUITY PURCHASES AND EXCHANGES TO ACHIEVE COMPLIANCE WITH RULE 2330 AND REG BI (FOR
CONDUCT POSTDATING JUNE 30, 2020). THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SYSTEM OR WSPS REASONABLY DESIGNED TO SUPERVISE
WHETHER THE FIRM'S REGISTERED REPRESENTATIVES MADE REASONABLE EFFORTS TO OBTAIN CUSTOMER PROFILE INFORMATION AND OTHER
INFORMATION NEEDED TO REASONABLY ASSESS THE SUITABILITY OF A TRANSACTION AND WHETHER THOSE TRANSACTIONS WERE IN THE
CUSTOMERS' BEST INTERESTS, INCLUDING CUSTOMERS' RISK TOLERANCES AND INFORMATION ABOUT LOST RIDER BENEFITS, PRIOR TO
RECOMMENDING THE PURCHASE OR EXCHANGE OF DEFERRED VARIABLE ANNUITIES. THE FIRM ALSO DID NOT HAVE A SYSTEM OR PROCEDURES
SUFFICIENT TO SUPERVISE WHETHER THERE WAS A REASONABLE BASIS TO BELIEVE THAT CUSTOMERS WERE ACCURATELY INFORMED ABOUT VARIOUS
FEATURES OF THE DEFERRED VARIABLE ANNUITIES THEY WERE RECOMMENDED, AS REQUIRED UNDER FINRA RULE 2330(B)(1)(A)(I), AND AS A RESULT,
FIRM SUPERVISORS APPROVED ANNUITY TRANSACTION APPLICATIONS LISTING INACCURATE COSTS, FEES, SURRENDER PERIODS, AND RIDER
INFORMATION. GIVEN THESE ISSUES, THE FIRM'S SUPERVISORY SYSTEM AND WSPS WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE
WITH THE REQUIREMENT IN RULE 2330(B)(1) TO ENSURE THAT THERE WAS A REASONABLE BASIS TO BELIEVE THAT RECOMMENDATIONS TO PURCHASE
OR EXCHANGE DEFERRED VARIABLE ANNUITIES WERE SUITABLE FOR THE CUSTOMERS OR IN THE CUSTOMERS' BEST INTEREST. SUPREME ALLIANCE
ALSO FAILED TO DOCUMENT PRINCIPAL REVIEW AND APPROVAL OF MULTIPLE VARIABLE ANNUITY APPLICATIONS SUBMITTED DURING THE RELEVANT
PERIOD, CONTRARY TO THE REQUIREMENTS OF FINRA RULES 2330(C). FURTHER, BETWEEN JUNE 30, 2020 AND APRIL 25, 2022, SUPREME ALLIANCE
FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH REG
BI. THE FIRM'S WRITTEN POLICIES AND PROCEDURES CONTAINED NO PROVISIONS RELATING TO REG BI DURING THAT PERIOD. FINALLY, BETWEEN
SEPTEMBER 2019 AND APRIL 2022, THE FIRM FAILED TO IMPLEMENT SURVEILLANCE PROCEDURES TO IDENTIFY IF ANY OF ITS REGISTERED
REPRESENTATIVES HAD INAPPROPRIATE EXCHANGES. THE FIRM DID NOT MAINTAIN POLICIES OR GUIDANCE EXPLAINING HOW THE FIRM WOULD
MONITOR RATES OF DEFERRED VARIABLE ANNUITY EXCHANGES, INCLUDING WHO WAS RESPONSIBLE FOR SUCH SURVEILLANCE, HOW OFTEN IT
WOULD TAKE PLACE, WHAT TOOLS TO USE TO CONDUCT THE SURVEILLANCE, OR WHAT PARAMETERS TO CONSIDER WHEN EVALUATING WHETHER
EXCHANGE RATES WERE INAPPROPRIATE. BETWEEN SEPTEMBER 2019 AND MAY 2022, SUPREME ALLIANCE FAILED TO ESTABLISH AND MAINTAIN A
SUPERVISORY SYSTEM AND WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE THE FIRM'S INVESTIGATIONS, DURING THE
HIRING PROCESS, INTO THE CHARACTER AND REPUTATION OF PROSPECTIVE REGISTERED REPRESENTATIVES, AND TO MAINTAIN RECORDS OF THOSE
INVESTIGATIONS. THE FIRM'S WRITTEN PROCEDURES DESCRIBED THE USE OF A CHECKLIST TO ENSURE CERTAIN STEPS WERE TAKEN DURING HIRING,
INCLUDING STEPS FOR VERIFICATION OF A CANDIDATE'S UNIFORM APPLICATION FOR SECURITIES REGISTRATION (FORM U4), DETAILS RELATED TO
CONTACTING THE CANDIDATE'S FORMER EMPLOYERS, AND FOR CREATING AND MAINTAINING DOCUMENTATION OF THE NEW HIRE INVESTIGATION.
HOWEVER, IN PRACTICE, THE FIRM DID NOT USE THIS CHECKLIST AND FAILED TO OTHERWISE MAINTAIN A SYSTEM REASONABLY DESIGNED TO
SUPERVISE THAT THE APPROPRIATE STEPS WERE TAKEN DURING THE HIRING PROCESS. FURTHER, THE FIRM FAILED TO ESTABLISH AND MAINTAIN A
SYSTEM REASONABLY DESIGNED TO KEEP APPROPRIATE DOCUMENTATION OF ITS INVESTIGATIONS AT HIRING, INCLUDING RECORDS OF BACKGROUND

CHECKS AND DISCLOSURE FORMS REQUIRED UNDER THE FIRM'S PROCEDURES.
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):
10/31/2025
 Exact
 Explanation
If not exact, provide explanation:
THE FIRM IS CENSURED AND FINED $80,000.
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 80,000.00
 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 FINE OF $80,000 ASSESSED AGAINST THE APPLICANT, TO BE PAID TO FINRA.
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 SETTLED THIS MATTER WITHOUT ADMITTING OR DENYING THE ALLEGATIONS TO AVOID THE UNCERTAINTIES OF LITIGATION.

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) 
NORTH CAROLINA DEPARTMENT OF INSURANCE
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/20/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
1000114587
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: 
MUTUAL FUNDS, INSURANCE
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO DISCLOSE FINRA ADMINISTRATIVE PROCEEDING ON 2021 NORTH CAROLINA LICENSE APPLICATION.
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):
11/20/2024
 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: $ 250.00
 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 PAID ON 11/14/2024
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).