Crews & Associates, Inc..

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
45985
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
CHITWOOD, RICHARD BOYD
(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) 
NATIONAL ASSOC OF SECURITIES DEALERS, INC.
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY FINE $5,000 JOINTLY AND SEVERALLY CREWS & ASSOCIATES, INC., L ADRON CREWS & RICHARD BOYD CHITWOOD.
3.
Date Initiated (MM/DD/YYYY): 
04/18/1985
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
NEW-506-AWC
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: 
DEBT MUNICIPALS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
VIOLATION OF ARTICLE III SECTION 1, 21 AND 27 "RULES OF FAIR PRACTICE", DURING PERIOD 06/21/83-08/16/83 PERTAINING TO DISTRIBUTION OF
DPP OFFERING; 02/28/85, 03/29/85, 04/12/85 DEPOSIT RELATING TO RESERVE 15C3-3 COMPUTATIONS; 11/01/84-04/18/85 - POSSESSION &
CONTROL

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):
08/29/1986
 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: $ 5,000.00
 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: 
$5,000.00 WAS FINED THE APPLICANT. THE AMOUNT WAS PAID BY APPLICANT ON RESOLUTION WITH NO PORTION 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).

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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)
2.
Principal Sanction:
Censure
Other Sanctions: 
MONETARY / FINE $27,500
3.
Date Initiated (MM/DD/YYYY): 
12/18/2007
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20050001121-02
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
DURING THE CALENDAR YEARS 2003 AND 2004 FINRA DECIDED THERE WERE 14 INSTANCES CREWS EXECUTED TRANSACTIONS WITH CUSTOMERS AT
PRICES DETERMINED BY FINRA TO BE UNFAIR AND UNREASONABLE WHILE TAKING INTO CONSIDERATION ALL RELEVANT FACTS SURROUNDING THE
MARKET FOR SUCH TRANSACTIONS IN VIOLATION OF MSRB RULES G-17 AND G-30. AS A RESULT OF THESE TRANSACTIONS, FINRA CITED THE FIRM FOR
FAILING TO MAINTAIN A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH MSRB RULE G-27. CREWS FAILED TO REPORT
CERTAIN MUNICIPAL SECURITIES TRANSACTIONS IN A TIMELY MANNER AS PRESCRIBED BY MSRB RULE G-14 RTRS 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):
12/18/2007
 Exact
 Explanation
If not exact, provide explanation:

12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 27,500.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS CENSURED, FINED $27,500 AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING FAIR
PRICING AND MARKUPS WITHIN 30 BUSINESS DAYS OF ACCEPTANCE OF THIS AWC BY THE NAC.
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).

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) 
FINANCIAL INDUSTRY REGULATORY AUTHORITY
2.
Principal Sanction:
Other
Other Sanctions: 
MONETARY FINE
3.
Date Initiated (MM/DD/YYYY): 
03/24/2010
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2008015489701
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASD RULES 2110, 6230(A), 6230(C)(8) - CREWS & ASSOCIATES, INC. FAILED TO REPORT TO THE TRADE REPORTING AND COMPLIANCE ENGINE
(TRACE) TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF THE TIME OF EXECUTION.
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):
03/24/2010
 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: $ 5,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, CREWS & ASSOCIATES, INC. CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY
OF FINDINGS THEREFORE, THE FIRM IS FINED $5,000
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).

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: 
3.
Date Initiated (MM/DD/YYYY): 
04/20/2012
 Exact
 Explanation
If not exact, provide explanation:

4.
Docket/Case Number:
2009019444401
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
MSRB RULES G-8, G-14 - CREWS & ASSOCIATES, INC. DID NOT ACCURATELY CAPTURE THE CORRECT EXECUTION TIME FOR CERTAIN MUNICIPAL
SECURITIES TRANSACTIONS AND, AS A RESULT, THE FIRM FAILED TO REPORT THE CORRECT TRADE TIME TO THE REAL-TIME TRANSACTION REPORTING
SYSTEM (RTRS) IN MUNICIPAL SECURITIES TRANSACTIONS; AND FAILED TO SHOW THE CORRECT EXECUTION TIME ON THE TRADE MEMORANDUM FOR
MUNICIPAL SECURITIES TRANSACTIONS.
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):
04/20/2012
 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: $ 5,000.00
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTION AND TO THE ENTRY OF FINDINGS;
THEREFORE, THE FIRM IS FINED $5,000 FOR MSRB RULE VIOLATIONS.
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).
IT WAS DETERMINED THAT THERE WERE 80 TRANSACTIONS WHICH WERE NOT IN SYNC WITH THE CONTRA-PARTIES' REPORTING TIMES. THE 80
TRADES WERE PART OF 2,736 REPORTED OVER A PERIOD OF 3 MONTHS. TO MITIGATE FUTURE MISMATCHES, CREWS CONDUCTED SPECIAL TRAINING
FOR ITS TRADERS AND ASSISTANTS TO RE-EMPHASIZE RESPONSIBILITY AND IMPORTANCE OF RECORDING AND REPORTING THE CORRECT TIME OF
EXECUTION FOR MUNICIPAL TRADES. TRAINING CONSISTED OF EACH TRADER TAKING OWNERSHIP OF THE 'TIME OF TRADE' (TOT) WITH THE CONTRA-
PARTY AND UNDERSTANDING EXACTLY HOW OUR INTERNAL TRADING SYSTEMS MANAGE DATA INPUT. WE ALSO SOLICITED AND ENCOURAGED THOSE
DEALERS WHICH PROVIDE ELECTRONIC NOTIFICATION TO TAKE RESPONSIBILITY FOR PROVIDING EMAIL NOTIFICATIONS TO TRADING AND SUPPORT
PERSONNEL WHEN THERE IS AN AUTOMATIC EXECUTION. ADDITIONALLY, THE 'TIME OF EXECUTION' FOR EACH MUNICIPAL TRANSACTION IS BEING
MONITORED DAILY BY CREWS MANAGEMENT AND OPERATIONS PERSONNEL USING THE MSRB DISCREPANCY ERROR CODE REPORT. IF ANY
TRANSACTION SHOWS A 'TIME OF EXECUTION' DIFFERENCE GREATER THAN 15 MINUTES, THE TRADER IS IMMEDIATELY CONTACTED BY HIS
SUPERVISOR AND REQUIRED TO PROVIDE A REASON FOR THE DIFFERENCE TO COMPLIANCE.

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: 
MONETARY/FINE
3.
Date Initiated (MM/DD/YYYY): 
07/30/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
2014039416301
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:

Debt - Municipal
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 ERRONEOUSLY
BELIEVED THAT THE LIST OFFERING PRICE/TAKEDOWN SPECIAL CONDITION INDICATOR (SCI) WAS ONLY NECESSARY FOR TRADES REPORTED OUTSIDE
OF THE GENERAL 15-MINUTE REQUIREMENT. CONSEQUENTLY, BETWEEN JANUARY 1, 2013 AND DECEMBER 31, 2013, THE FIRM REPORTED 197 LIST
OFFERING PRICE/TAKEDOWN TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD'S (MSRB) REAL-TIME TRANSACTION REPORTING
SYSTEM (RTRS) WITHIN 15 MINUTES OF EXECUTION, BUT WITHOUT THE REQUIRED SPECIAL CONDITION INDICATOR. THE FINDINGS STATED THAT
BETWEEN OCTOBER 1, 2013 AND DECEMBER 31, 2013, THE FIRM INCORRECTLY STATED ITS CAPACITY ON 50 CUSTOMER CONFIRMATIONS. IN ALL
INSTANCES, THE FIRM INCORRECTLY STATED THE CAPACITY AS "BROKER ONLY" WHEN THE CAPACITY SHOULD HAVE BEEN STATED AS "PRINCIPAL."
THE FINDINGS ALSO STATED THAT IN 2012, THE FIRM RECEIVED A LETTER OF CAUTION WITH REGARDS TO INACCURATE CAPACITY REPORTING TO
MSRB'S RTRS. ALTHOUGH THE FIRM CORRECTED THE TRADE REPORTING OF ITS CAPACITY, THE FIRM NEVER CONDUCTED ANY TESTING OF THE
ACCURACY OF ITS CUSTOMER CONFIRMATIONS. THE FIRM SHOULD HAVE HAD CONTROLS IN PLACE TO TEST ITS OWN CONFIRMATION PROCESS TO
ENSURE THE ACCURACY OF INFORMATION ON THE CONFIRMATIONS AND ITS COMPLIANCE WITH MSRB RULE G-15.
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):
07/30/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 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: 
THE FIRM WAS CENSURED AND FINED $15,000
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).

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) 
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/30/2015
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
3-16865
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
SEC ADMIN RELEASES 33-9953; 34-76050; SEPTEMBER 30, 2015: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE
PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED AGAINST CREWS &
ASSOCIATES, INC., ("RESPONDENT"). RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES
VIOLATIONS OF AN ANTIFRAUD PROVISION OF THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN
MUNICIPAL SECURITIES OFFERINGS. RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN
OFFERINGS AND AS A RESULT, FAILED TO FORM A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS
IN OFFICIAL STATEMENTS ISSUED IN CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL
SECURITIES ON THE BASIS OF MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE

COMMISSION PURSUANT TO THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC)
INITIATIVE.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
09/30/2015
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 250,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)
(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $250,000.00 AND COMPLY WITH THE UNDERTAKINGS ENUMERATED
IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN ANTICIPATION OF THESE PROCEEDINGS, RESPONDENT SUBMITTED AN OFFER OF SETTLEMENT (THE "OFFER") WHICH THE COMMISSION HAS
DETERMINED TO ACCEPT. SOLELY FOR THE PURPOSE OF THESE PROCEEDINGS AND ANY OTHER PROCEEDINGS BROUGHT BY OR ON BEHALF OF THE
COMMISSION, OR TO WHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING OR DENYING THE FINDINGS, EXCEPT AS TO THE COMMISSION'S
JURISDICTION OVER IT AND THE SUBJECT MATTER OF THESE PROCEEDINGS, WHICH ARE ADMITTED, RESPONDENT CONSENTED TO THE ENTRY OF THIS
ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND
SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST
ORDER. IN VIEW OF THE FOREGOING, THE COMMISSION DEEMED IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS ALREADY
AGREED TO IN OUR OFFER. RESPONDENT WILL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
17(A)(2)OF THE SECURITIES ACT; RESPONDENT PAID A CIVIL MONEY PENALTY IN THE AMOUNT OF $250,000.00 TO THE COMMISSION; AND RETAINED
AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF RESPONDENT'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES
UNDERWRITING DUE DILIGENCE.

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) 
ARKANSAS SECURITIES DEPARTMENT
2.
Principal Sanction:
Other
Other Sanctions: 
RETENTION OF COMPLIANCE EXPERT TO REVIEW SUPERVISORY PROCEDURES AND PROVIDE RECOMMENDATIONS. OTHER SANCTIONS/RELIFE SOUGHT:
CEASE & DESIST.
3.
Date Initiated (MM/DD/YYYY): 
07/09/2013
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-10-0060-13-OR03
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Debt - Corporate
Other Product Types: 
OIL & GAS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
A CONSENT ORDER ("ORDER") APPROVED BY THE ARKANSAS SECURITIES COMMISSIONER ON JULY 9, 2013, FOUND THAT CREWS & ASSOCIATES, INC.
("CREWS") (CRD# 8052) VIOLATED THE ARKANSAS SECURITIES ACT ("ACT"), THE RULES OF THE ARKANSAS SECURITIES COMMISSIONER ("RULES"),
AND CERTAIN FINRA RULES IN ITS RECOMMENDATION OF AND ROLE SPECIFICALLY AS THE PLACEMENT AGENT FOR PRIVATE PLACEMENT SECURITIES
OFFERINGS REGARDING DEBENTURES FOR BAMCO GAS, LLC ("BAMCO"), IN 2005 ("SENIOR DEBENTURE OFFERING") AND 2008 ("SUBORDINATE
DEBENTURE OFFERING"). CREWS NEITHER ADMITTED NOR DENIED THE FINDINGS OF FACT OR CONCLUSIONS OF LAW IN THE ORDER. THE ORDER
FOUND THAT CREWS VIOLATED NASD CONDUCT RULE 2310 (RECOMMENDATIONS TO CUSTOMERS ­ SUITABILITY), ARK. CODE ANN. § 23­42­308(A)(2)

(G), AND RULES 308.01(D) AND (X) OF THE RULES BY RECOMMENDING ITS CUSTOMERS PURCHASE THE BAMCO DEBENTURES AFTER CREWS FAILED TO
CONDUCT A REASONABLE DUE DILIGENCE INVESTIGATION FOR THE SENIOR DEBENTURE OFFERING OR THE SUBORDINATE DEBENTURE OFFERING.
CREWS DID NOT HAVE AN ADEQUATE AND REASONABLE BASIS FOR BELIEVING THAT THE RECOMMENDATIONS OF THE BAMCO DEBENTURES WERE
SUITABLE FOR AT LEAST SOME CUSTOMERS OF CREWS. AS A RESULT, THE BAMCO DEBENTURES WERE NOT SUITABLE FOR CREWS' CUSTOMERS UNDER
A REASONABLE-BASIS SUITABILITY ANALYSIS. FURTHER, CREWS VIOLATED ARK. CODE ANN. § 23­42­308(A)(2)(G) AND RULE 308.01(Y) OF THE RULES
WHEN CREWS FAILED TO DISCLOSE CERTAIN INFORMATION ABOUT BAMCO, BAMCO'S CONTROL PERSONS, AND THE BAMCO DEBENTURES IN THE
PRIVATE PLACEMENT MEMORANDA FOR THE BAMCO DEBENTURES, WHICH WERE DRAFTED BY CREWS, CREWS' OUTSIDE COUNSEL, AND BAMCO. ON
THIS OFFERING CREWS FAILED TO ENFORCE A SUPERVISORY SYSTEM REASONABLY DESIGNED TO ENABLE CREWS AND ITS AGENTS TO ACHIEVE
COMPLIANCE WITH APPLICABLE SECURITIES LAWS, RULES, AND REGULATIONS IN THE BAMCO DEBENTURE OFFERINGS. CREWS' VIOLATIONS
RESULTED, IN PART, FROM CREWS' SUPERVISORY FAILURES. CREWS' FAILURE TO REASONABLY SUPERVISE THE BAMCO DEBENTURE OFFERINGS WAS
FOUND TO BE IN VIOLATION OF NASD CONDUCT RULE 3010 (SUPERVISION), ARK. CODE ANN. § 23­42­308(A)(2)(G) AND (J), AND RULE 308.01(X) OF
THE RULES. PURSUANT TO ARK. CODE ANN. § 23­42­209(A)(1)(A), CREWS WAS ORDERED TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF ARK.
CODE ANN. § 23­42­308(A)(2)(G) AND (J); AND RULE 308.01(D), (X), AND (Y) OF THE RULES. IN RECOGNITION OF CREWS' SUCCESSFUL EFFORTS TO
REPURCHASE THE BAMCO DEBENTURES FROM ITS CUSTOMERS AND ITS DONATION OF $150,000.00 ON JULY 8, 2013, TO THE NORTH AMERICAN
SECURITIES ADMINISTRATORS ASSOCIATION ("NASAA") TO ADVANCE THE TRAINING AND INVESTOR-PROTECTION PROGRAMS OFFERED BY NASAA, NO
FINE WAS LEVIED AGAINST CREWS. CREWS WAS FURTHER ORDERED TO, UPON REQUEST BY THE DEPARTMENT, NOTIFY THE DEPARTMENT IN WRITING
OF ANY PRIVATE PLACEMENT OFFERINGS FOR WHICH IT ACTS AS THE PLACEMENT AGENT AND PROVIDE CERTAIN SUPPORTING DOCUMENTATION TO
THE DEPARTMENT. ADDITIONALLY, CREWS WAS ORDERED TO RETAIN AN INDEPENDENT BROKER-DEALER SUPERVISORY COMPLIANCE EXPERT TO
EVALUATE AND SUBMIT AN OPINION THAT THE PORTION OF CREWS' WRITTEN SUPERVISORY PROCEDURES ADDRESSING PRIVATE PLACEMENT
OFFERINGS IS IN A FORM CONSISTENT WITH INDUSTRY STANDARDS AND COMPLIANT WITH RELEVANT FINRA CONDUCT RULES, THE ACT, AND THE
RULES.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
07/09/2013
 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: 
WITHOUT ADMITTING OR DENYING THE FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE ORDER, PURSUANT TO ARK. CODE ANN. § 23­42­
209(A)(1)(A), CREWS WAS ORDERED TO CEASE AND DESIST FROM FURTHER VIOLATIONS OF ARK. CODE ANN. § 23­42­308(A)(2)(G) AND (J); AND
RULE 308.01(D), (X), AND (Y) OF THE RULES. CREWS WAS FURTHER ORDERED TO, UPON REQUEST BY THE DEPARTMENT, NOTIFY THE
DEPARTMENT IN WRITING OF ANY PRIVATE PLACEMENT OFFERINGS FOR WHICH IT ACTS AS THE PLACEMENT AGENT AND PROVIDE CERTAIN
SUPPORTING DOCUMENTATION TO THE DEPARTMENT. ADDITIONALLY, CREWS WAS ORDERED TO RETAIN AN INDEPENDENT BROKER-DEALER
SUPERVISORY COMPLIANCE EXPERT TO EVALUATE AND SUBMIT AN OPINION THAT THE PORTION OF CREWS' WRITTEN SUPERVISORY
PROCEDURES ADDRESSING PRIVATE PLACEMENT OFFERINGS IS IN A FORM CONSISTENT WITH INDUSTRY STANDARDS AND COMPLIANT WITH
RELEVANT FINRA CONDUCT RULES, THE ACT, AND THE RULES.
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).

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) 
ARKANSAS SECURITIES DEPARTMENT
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
04/12/2019
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
S-19-0005
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):
IN THE MATTER OF CREWS & ASSOCIATES, INC.; ARKANSAS SECURITIES DEPARTMENT CASE NO. S-19-0005; ORDER NO. S-19-0005-19-OR01. CONSENT
ORDER ENTERED WITH CREWS & ASSOCIATES, INC. FOR CERTAIN BOOKS AND RECORDS VIOLATIONS OF THE ARKANSAS SECURITIES ACT AND THE
RULES OF THE ARKANSAS SECURITIES COMMISSIONER. CREWS SELF-REPORTED CRD FILING ISSUES TO THE STAFF OF THE ARKANSAS SECURITIES
DEPARTMENT WHICH HAD CAUSED ITS APPLICATIONS FOR REGISTRATION IN ARKANSAS FOR TWO NON-SALES, FINRA-REGISTERED BROKER-DEALER
AGENTS TO BE UNTIMELY FILED AFTER THE AGENTS PASSED THE SERIES 63 EXAMINATION. THE DEPARTMENT APPROVED THE APPLICATIONS OF BOTH
AGENTS UPON ENTRY OF THIS CONSENT ORDER WITH CREWS.
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):
04/12/2019
 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: $ 5,000.00
 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 $5,000.00 PAID TO THE ARKANSAS SECURITIES DEPARTMENT DATED APRIL 11, 2019.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN THE MATTER OF CREWS & ASSOCIATES, INC.; ARKANSAS SECURITIES DEPARTMENT CASE NO. S-19-0005; ORDER NO. S-19-0005-19-OR01. CONSENT
ORDER ENTERED WITH CREWS & ASSOCIATES, INC. FOR CERTAIN BOOKS AND RECORDS VIOLATIONS OF THE ARKANSAS SECURITIES ACT AND THE
RULES OF THE ARKANSAS SECURITIES COMMISSIONER. CREWS SELF-REPORTED CRD FILING ISSUES TO THE STAFF OF THE ARKANSAS SECURITIES
DEPARTMENT WHICH HAD CAUSED ITS APPLICATIONS FOR REGISTRATION IN ARKANSAS FOR TWO NON-SALES, FINRA-REGISTERED BROKER-DEALER
AGENTS TO BE UNTIMELY FILED AFTER THE AGENTS PASSED THE SERIES 63 EXAMINATION. THE DEPARTMENT APPROVED THE APPLICATIONS OF BOTH
AGENTS UPON ENTRY OF THIS CONSENT ORDER WITH CREWS.

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) 
SEC
2.
Principal Sanction:
Cease and Desist
Other Sanctions: 
CENSURE; DISGORGEMENT OF $34,631 PLUS INTEREST OF $9,441; CIVIL MONEY PENALTY OF $200,000
3.
Date Initiated (MM/DD/YYYY): 
08/26/2021
 Exact
 Explanation
If not exact, provide explanation:
ORDER INSTITUTING ADMINISTRATIVE AND CEASE-AND DESIST PROCEEDINGS, PURSUANT TO SECTIONS 15(B), 15B(C) AND 21C OF THE SECURITIES
EXCHANGE ACT OF 1934, MAKING FINDINGS, AND IMPOSING REMEDIAL SANCTIONS AND A CEASE AND-DESIST ORDER. THE ORDER INSTITUTES AND
RESOLVES THE PROCEEDING ON THE SAME DAY.
4.
Docket/Case Number:
3-20480
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6.
Principal Product Type:
Debt - Municipal
Other Product Types: 
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
WILLFULL VIOLATION OF MSRB RULES G-17 AND G-27 AND BY REASON THEREOF, SECTION 15B(C)(1) OF THE EXCHANGE ACT.

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:
N/A
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):
08/26/2021
 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: $ 200,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
DISGORGEMENT OF $34,631 AND PREJUDGMENT INTEREST OF $9,441"
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
N/A
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
CIVIL MONEY PENALTY AND DISGORGEMENT PAID IN FULL ON AUGUST 26, 2021.