Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by A.G.P / Alliance Global Partners
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Current profile metrics reflect a newer SEC ADV filing than the latest point shown in the historical chart. The chart will update once that filing is added to the ADV history dataset.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to A.G.P / Alliance Global Partners.
Reported ownership and control details
Form ADV · Filing date 2026-10-02 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | THOMAS JOSEPH HIGGINSPRINCIPAL OPERATIONS OFFICERIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | No | PRINCIPAL OPERATIONS OFFICER09/2018 | Schedule APDF page 47 |
| 2 | PHILLIP WILLIAM MICHALSCHIEF EXECUTIVE OFFICERIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | Yes | CHIEF EXECUTIVE OFFICER01/2019 | Schedule APDF page 48 |
| 3 | ANTHONY JOSEPH LAURIELLOMUNICIPAL SECURITIES PRINCIPALIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | No | MUNICIPAL SECURITIES PRINCIPAL02/2019 | Schedule APDF page 48 |
| 4 | JOHN JOSEPH VENEZIACHIEF COMPLIANCE OFFICER - BROKER DEALER, RIAIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER - BROKER DEALER, RIA05/2019 | Schedule APDF page 48 |
| 5 | CRAIG ERIN KLEINCFO, PRINCIPAL FINANCIAL OFFICERIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | Yes | CFO, PRINCIPAL FINANCIAL OFFICER10/2019 | Schedule APDF page 48 |
| 6 | RAFFAELE GAMBARDELLACOO/CHIEF RISK OFFICERIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | Yes | COO/CHIEF RISK OFFICER06/2020 | Schedule APDF page 48 |
| 7 | ALLIANCE GLOBAL HOLDINGS, INC.HOLDING COMPANYDomestic entity | A.G.P / ALLIANCE GLOBAL PARTNERS | 75% or moreCode E | Yes | HOLDING COMPANY07/2021 | Schedule APDF page 48 |
| 8 | TIMOTHY FRANCIS CASSIDYADMINISTRATION OFFICERIndividual | A.G.P / ALLIANCE GLOBAL PARTNERS | Less than 5%Code NA | No | ADMINISTRATION OFFICER08/2026 | Schedule APDF page 48 |
| 9 | PHILLIP WILLIAM MICHALSPARTNERIndividual | ALLIANCE GLOBAL HOLDINGS, INC. | 25% to less than 50%Code C | Yes | PARTNER07/2021 | Schedule BPDF page 48 |
| 10 | RAFFAELE GAMBARDELLAPARTNERIndividual | ALLIANCE GLOBAL HOLDINGS, INC. | 25% to less than 50%Code C | Yes | PARTNER07/2021 | Schedule BPDF page 48 |
| 11 | DAVID BOCCHI FAMILY TRUSTPARTNERDomestic entity | ALLIANCE GLOBAL HOLDINGS, INC. | 25% to less than 50%Code C | Yes | PARTNER07/2021 | Schedule BPDF page 48 |
| 12 | DAVID ARTHUR BOCCHITRUSTEEIndividual | DAVID BOCCHI FAMILY TRUST | 75% or moreCode E | Yes | TRUSTEE09/2020 | Schedule BPDF page 48 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 8/11/2026 11:16:08 AM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies1 Yes1 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?Yes
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions4 Yes1 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?Yes
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?Yes
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?Yes
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings4 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?No
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?No
Additional DRP filings 9 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
criminal · block 1PDF pages 45–46
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.A. or 11.B. of Form ADV. Criminal Check item(s) being responded to: 11.A(1) 11.A(2) 11.B(1) 11.B(2) 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. Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may result in more than one affirmative answer to the items listed above. 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: 5527482 This advisory affiliate is a Firm an Individual Registered: Yes No Name: CHARLOT, GREGORY (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. 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. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 2. Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case number). 3. Event Disclosure Detail (Use this for both organizational and individual charges.) A. Date First Charged (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: B. Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor, (3) plea for each charge, and (4) product type if charge is investment-related). C. Did any of the Charge(s) within the Event involve a felony? Yes No D. Current status of the Event? Pending On Appeal Final E. Event Status Date (complete unless status is Pending) (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: 4. Disposition Disclosure Detail: Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 5. Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was the subject of the charge(s) occurred. (Your response must fit within the space provided.)
regulatory · block 1PDF pages 46–48
- Regulator name — filed text
- NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION
- Monetary/Fine Amount — filed text
- $ 1,250.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THIS SITUATION WAS THE RESULT OF CLERICAL ERROR AND PERSONNEL TRANSITION.
Other filed details
Description of allegations — filed text
EURO PACIFIC FAILED TO PAY PENALTY OF $1625.00 TO NEW HAMPSHIRE FOR LATE FINANCIAL STATEMENTS
Sanction detail — filed text
SAME AS ABOVE
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CEASE AND DESIST 3. Date Initiated (MM/DD/YYYY): 04/30/2015 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: INV2015-0003 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): EURO PACIFIC FAILED TO PAY PENALTY OF $1625.00 TO NEW HAMPSHIRE FOR LATE FINANCIAL STATEMENTS 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): 06/02/2015 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: $ 1,250.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: PENALTY $1625.00 Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: SAME AS ABOVE 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THIS SITUATION WAS THE RESULT OF CLERICAL ERROR AND PERSONNEL TRANSITION.
regulatory · block 2PDF pages 48–50
- Regulator name — filed text
- SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BY THE SEC, AND WHICH CALLS FOR A CENSURE, CEASE AND DESIST, CIVIL MONETARY PENALTY OF $100,000, AND DISGORGEMENT OF $11,369.00 (PLUS $2,407 IN PREJUDGMENT INTEREST).
Other filed details
Description of allegations — filed text
THE SEC ALLEGED THAT BETWEEN FEBRUARY 2019 AND FEBRUARY 2021, THE FIRM PUBLISHED QUOTES ON A DAILY BASIS FOR BETWEEN 4,300 AND 6,500 DIFFERENT MUNICIPAL BONDS AT ABOVE-MARKET PRICES FOR A CUSTOMER THAT WAS A SOPHISTICATED MUNICIPAL MARKET PROFESSIONAL, WITHOUT INDEPENDENTLY EVALUATING THE FAIR MARKET VALUES OF THE BONDS AT THE TIME IT MADE THE QUOTATIONS. THE SEC ALSO ALLEGED THAT ON 204 OCCASSIONS, THE FIRM, ACTING IN A PRINCIPAL CAPACITY, FACILITATED THE SALES OF THE BONDS ATTRIBUTABLE TO THE QUOTES WITHOUT EVALUATING THE PREVAILING MARKET PRICES FOR THE BONDS. THE SEC ALSO ALLEGED THAT ON 51 OCCASSIONS, THE FIRM FAILED TO REPORT THESE TRANSACTIONS AS "AWAY FROM THE MARKET TRADES. BASED ON THE FOREGOING, THE SEC ALLEGED THAT THE FIRM VIOLATED MSRB RULES G-13, G-14, G-17, G-27 AND G-30 AND, AS A RESULT, SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934.
Sanction detail — filed text
THE FIRM AGREED TO PAY DISGORGEMENT OF $11,369.00, PREJUDGMENT INTEREST OF $2,407.38, AND A CIVIL PENALTY OF $100,000.00.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: DISGORGEMENT AND PREJUDGMENT INTEREST.CEASE AND DESIST ORDER. 3. Date Initiated (MM/DD/YYYY): 10/16/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 3-22255 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): THE SEC ALLEGED THAT BETWEEN FEBRUARY 2019 AND FEBRUARY 2021, THE FIRM PUBLISHED QUOTES ON A DAILY BASIS FOR BETWEEN 4,300 AND 6,500 DIFFERENT MUNICIPAL BONDS AT ABOVE-MARKET PRICES FOR A CUSTOMER THAT WAS A SOPHISTICATED MUNICIPAL MARKET PROFESSIONAL, WITHOUT INDEPENDENTLY EVALUATING THE FAIR MARKET VALUES OF THE BONDS AT THE TIME IT MADE THE QUOTATIONS. THE SEC ALSO ALLEGED THAT ON 204 OCCASSIONS, THE FIRM, ACTING IN A PRINCIPAL CAPACITY, FACILITATED THE SALES OF THE BONDS ATTRIBUTABLE TO THE QUOTES WITHOUT EVALUATING THE PREVAILING MARKET PRICES FOR THE BONDS. THE SEC ALSO ALLEGED THAT ON 51 OCCASSIONS, THE FIRM FAILED TO REPORT THESE TRANSACTIONS AS "AWAY FROM THE MARKET TRADES. BASED ON THE FOREGOING, THE SEC ALLEGED THAT THE FIRM VIOLATED MSRB RULES G-13, G-14, G-17, G-27 AND G-30 AND, AS A RESULT, SECTION 15B(C)(1) OF THE SECURITIES EXCHANGE ACT OF 1934. 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: Decision & Order of Offer of Settlement 11. Resolution Date (MM/DD/YYYY): 10/16/2024 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: $ 100,000.00 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 AGREED TO PAY DISGORGEMENT OF $11,369.00, PREJUDGMENT INTEREST OF $2,407.38, AND A CIVIL PENALTY OF $100,000.00. 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). WITHOUT ADMITTING OR DENYING THE SEC'S FINDINGS, THE FIRM SUBMITTED AN OFFER OF SETTLEMENT WHICH WAS ACCEPTED BY THE SEC, AND WHICH CALLS FOR A CENSURE, CEASE AND DESIST, CIVIL MONETARY PENALTY OF $100,000, AND DISGORGEMENT OF $11,369.00 (PLUS $2,407 IN PREJUDGMENT INTEREST).
regulatory · block 3PDF pages 50–52
- Regulator name — filed text
- NASDAQ STOCK MARKET
- Monetary/Fine Amount — filed text
- $ 12,500.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS, AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO). THE FINDINGS STATED THAT THE VIOLATIONS OCCURRED BECAUSE APPLICANT FAILED TO SET UP THE AUTOMATED QUOTE REFRESH FUNCTION IN ITS ORDER MANAGEMENT SYSTEM FOR EACH SECURITY IT WAS IN AS A MARKET MAKER. THE FINDINGS ALSO STATED THAT APPLICANT'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ QUOTING OBLIGATIONS.
Sanction detail — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, AND WAS CENSURED AND FINED $12,500. BECAUSE APPLICANT HAS ALREADY ENHANCED ITS WRITTEN SUPERVISORY PROCEDURES AND IMPLEMENTED NEW REVIEWS TO ENSURE COMPLIANCE WITH ITS QUOTING OBLIGATIONS, AN UNDERTAKING IS NOT BEING ORDERED FOR THIS MATTER.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDAQ STOCK MARKET 2. Principal Sanction: Civil and Administrative Penalt(ies) /Fine(s) Other Sanctions: CENSURE 3. Date Initiated (MM/DD/YYYY): 05/21/2018 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016051138801 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: UNSPECIFIED SECURITIES 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING INTEREST DURING REGULAR MARKET HOURS, AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO). THE FINDINGS STATED THAT THE VIOLATIONS OCCURRED BECAUSE APPLICANT FAILED TO SET UP THE AUTOMATED QUOTE REFRESH FUNCTION IN ITS ORDER MANAGEMENT SYSTEM FOR EACH SECURITY IT WAS IN AS A MARKET MAKER. THE FINDINGS ALSO STATED THAT APPLICANT'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ QUOTING OBLIGATIONS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 05/21/2018 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 12,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: WITHOUT ADMITTING OR DENYING THE FINDINGS, APPLICANT CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS, AND WAS CENSURED AND FINED $12,500. BECAUSE APPLICANT HAS ALREADY ENHANCED ITS WRITTEN SUPERVISORY PROCEDURES AND IMPLEMENTED NEW REVIEWS TO ENSURE COMPLIANCE WITH ITS QUOTING OBLIGATIONS, AN UNDERTAKING IS NOT BEING ORDERED FOR THIS MATTER. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided).
regulatory · block 4PDF pages 52–53
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 10,000.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
ON APRIL 11, 2019, FINRA APPROVED A LETTER OF ACCEPTANCE WAIVER AND CONSENT WHICH NEITHER ADMITTED NOR DENIED THE ALLEGATION THAT WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER HAD BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010. THE AWC PROVIDED FOR SANCTIONS CONSISTING OF A CENSURE AND A $10,000 FINE.
Other filed details
Description of allegations — filed text
WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER WAS ALLEGED TO HAVE BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010.
Sanction detail — filed text
FINE WAS $10,000, LEVIED AGAINST APPLICANT AND PAID ON 3/6/2019.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Censure Other Sanctions: CIVIL AND ADMINISTRATIVE PENALTY(IES)/FINE(S) 3. Date Initiated (MM/DD/YYYY): 04/11/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2016048551101 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): WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER WAS ALLEGED TO HAVE BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 04/11/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 10,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FINE WAS $10,000, LEVIED AGAINST APPLICANT AND PAID ON 3/6/2019. 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). ON APRIL 11, 2019, FINRA APPROVED A LETTER OF ACCEPTANCE WAIVER AND CONSENT WHICH NEITHER ADMITTED NOR DENIED THE ALLEGATION THAT WHILE UNDER PRIOR OWNERSHIP AS EURO PACIFIC CAPITAL IN JANUARY 2016, A CORPORATE CUSTOMER HAD BEEN CHARGED $6,000 FOR FILING A FORM 211 IN VIOLATION OF FINRA RULE 5250 AND 2010. THE AWC PROVIDED FOR SANCTIONS CONSISTING OF A CENSURE AND A $10,000 FINE.
regulatory · block 5PDF pages 53–55
- Regulator name — filed text
- CALIFORNIA DEPARTMENT OF INSURANCE
- How was matter resolved — filed text
- Order
Action status / disposition — filed text
AGP INADVERTENTLY FAILED TO SEPARATELY NOTIFY THE CALIFORNIA INSURANCE DEPARTMENT (THE "DEPARTMENT") OF CERTAIN REGULATORY EVENTS, ALL OF WHICH HAD BEEN FULLY DISCLOSED ON THE FIRM'S PUBLICLY AVAILABLE RECORD AS MAINTAINED BY THE CENTRAL REGISTRATION DEPOSITORY (CRD), IN CONNECTION WITH AN APPLICATION TO ACT AS A LIFE ONLY AGENT WITH VARIABLE CONTRACT AUTHORITY. DOCUMENTS FROM THE DEPARTMENT REQUESTING INFORMATION IN RELATION TO THAT APPLICATION WERE MISHANDLED BY AN ASSISTANT IN AGP'S CHICAGO OFFICE AND A DEFAULT ORDER DENYING AGP'S APPLICATION FOR THE INSURANCE LICENSE WAS ENTERED. THE FIRM IS EXPLORING POSSIBLE OPTIONS TO VACATE THE DEFAULT ORDER.
Other filed details
Description of allegations — filed text
DEFAULT ORDER INDICATING FIRM HAD VIOLATED SECTIONS 1668(B), 1668(E), 1668(H), AND 1668(J) OF CALIFORNIA INSURANCE CODE.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CALIFORNIA DEPARTMENT OF INSURANCE 2. Principal Sanction: Denial Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 05/13/2022 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: PLBS 13370-A 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Insurance Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): DEFAULT ORDER INDICATING FIRM HAD VIOLATED SECTIONS 1668(B), 1668(E), 1668(H), AND 1668(J) OF CALIFORNIA INSURANCE CODE. 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: HOWEVER, FIRM IS ATTEMPTING TO HAVE THE DEFAULT ORDER VACATED. 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): 06/12/2022 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). AGP INADVERTENTLY FAILED TO SEPARATELY NOTIFY THE CALIFORNIA INSURANCE DEPARTMENT (THE "DEPARTMENT") OF CERTAIN REGULATORY EVENTS, ALL OF WHICH HAD BEEN FULLY DISCLOSED ON THE FIRM'S PUBLICLY AVAILABLE RECORD AS MAINTAINED BY THE CENTRAL REGISTRATION DEPOSITORY (CRD), IN CONNECTION WITH AN APPLICATION TO ACT AS A LIFE ONLY AGENT WITH VARIABLE CONTRACT AUTHORITY. DOCUMENTS FROM THE DEPARTMENT REQUESTING INFORMATION IN RELATION TO THAT APPLICATION WERE MISHANDLED BY AN ASSISTANT IN AGP'S CHICAGO OFFICE AND A DEFAULT ORDER DENYING AGP'S APPLICATION FOR THE INSURANCE LICENSE WAS ENTERED. THE FIRM IS EXPLORING POSSIBLE OPTIONS TO VACATE THE DEFAULT ORDER.
Show 3 more source blocks
regulatory · block 6PDF pages 55–57
- Regulator name — filed text
- FINRA
- Monetary/Fine Amount — filed text
- $ 88,079.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
THE FINE WAS PAID ON 1/12/2026.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT DID NOT FILE, OR FILED UNTIMELY OR INACCURATE, NOTIFICATIONS WITH FINRA IN CONNECTION WITH ITS PARTICIPATION IN 47 DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE ITS COMPLIANCE WITH RULE 101 OF REGULATION M AND FINRA RULE 5190.
Sanction detail — filed text
FINE OF 88079.00 PAID ON 1/12/2026.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) FINRA 2. Principal Sanction: Censure Other Sanctions: A FINE AND AN UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 12/30/2025 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2020068424201 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: UNSPECIFIED SECURITIES 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 DID NOT FILE, OR FILED UNTIMELY OR INACCURATE, NOTIFICATIONS WITH FINRA IN CONNECTION WITH ITS PARTICIPATION IN 47 DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO REASONABLY SUPERVISE ITS COMPLIANCE WITH RULE 101 OF REGULATION M AND FINRA RULE 5190. 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): 12/30/2025 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: $ 88,079.00 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: FINE OF 88079.00 PAID ON 1/12/2026. 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 FINE WAS PAID ON 1/12/2026.
regulatory · block 7PDF pages 57–59
- Regulator name — filed text
- NASDAQ STOCK MARKET
- Monetary/Fine Amount — filed text
- $ 56,921.00
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
FINE DEBITED AS PER NASDAQ INSTRUCTIONS AND DEEMED PAID.
Other filed details
Description of allegations — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED NASDAQ RULE EQUITY 2, SECTION 10(E) AND ITS PREDECESSOR, NASDAQ RULE 4619(E),1 AND NASDAQ RULE GENERAL 9, SECTION 1(A) BY FAILING TO FILE, OR FILING UNTIMELY, RESTRICTED PERIOD NOTIFICATIONS AND TRADING NOTIFICATIONS IN CONNECTION WITH ITS PARTICIPATION IN EIGHT DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S NOTIFICATION RULES RELATED TO REGULATION M.
Sanction detail — filed text
FINE OF 56921.00 DEBITED AS PER NASDAQ INSTRUCTIONS AND DEEMED PAID.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDAQ STOCK MARKET 2. Principal Sanction: Censure Other Sanctions: A FINE AND AN UNDERTAKING 3. Date Initiated (MM/DD/YYYY): 12/30/2025 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2020068424202 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Other Other Product Types: UNSPECIFIED SECURITIES 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 VIOLATED NASDAQ RULE EQUITY 2, SECTION 10(E) AND ITS PREDECESSOR, NASDAQ RULE 4619(E),1 AND NASDAQ RULE GENERAL 9, SECTION 1(A) BY FAILING TO FILE, OR FILING UNTIMELY, RESTRICTED PERIOD NOTIFICATIONS AND TRADING NOTIFICATIONS IN CONNECTION WITH ITS PARTICIPATION IN EIGHT DISTRIBUTIONS OF SECURITIES SUBJECT TO REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH AND MAINTAIN A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH NASDAQ'S NOTIFICATION RULES RELATED TO REGULATION M. 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): 12/30/2025 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: $ 56,921.00 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: FINE OF 56921.00 DEBITED AS PER NASDAQ INSTRUCTIONS AND DEEMED PAID. 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 DEBITED AS PER NASDAQ INSTRUCTIONS AND DEEMED PAID.
regulatory · block 8PDF pages 59–60
- Regulator name — filed text
- NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES
- Monetary/Fine Amount — filed text
- $ 7,500.00
- How was matter resolved — filed text
- Stipulation and Consent
Action status / disposition — filed text
THE VIOLATIONS WERE INADVERTENT AND THE FIRM PAID THE $7,500.00 FINE TO RESOLVE THE MATTER.
Other filed details
Description of allegations — filed text
AGP FAILED TO REPORT TO THE SUPERINTENDENT OF NY DEPARTMENT OF FINANCIAL SERVICES WITHIN 30 DAYS OF THE FINAL DISPOSITION OF THE MATTER, AN ADMINISTRATIVE ACTION BROUGHT BY THE INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA IN VIOLATION OF SECTION 2110(I) OF NY INSURANCE LAW; FROM APRIL 2019 TO SEPTEMBER 2025 THE AGP WEBSITE USED INSURANCE COMPANY LOGOS WITHOUT THE FULL NAME AND PRINCIPAL ADDRESS OF EACH INSURER IN VIOLATION OF SECTION 2122(B) OF NY INSURANCE LAW; AGP FAILED TO REGISTER A SATELLITE OFFICE IN VIOLATION OF SECTION 2129 OF THE INSURANCE LAW AND REGULATION 125.
Sanction detail — filed text
FINE OF $7,500.00 WAS PAID ON NOVEMBER 25, 2025.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE 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) NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES 2. Principal Sanction: Censure Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 11/25/2025 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: STIPULATION #2025-0394-S 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Insurance Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): AGP FAILED TO REPORT TO THE SUPERINTENDENT OF NY DEPARTMENT OF FINANCIAL SERVICES WITHIN 30 DAYS OF THE FINAL DISPOSITION OF THE MATTER, AN ADMINISTRATIVE ACTION BROUGHT BY THE INSURANCE COMMISSIONER OF THE STATE OF CALIFORNIA IN VIOLATION OF SECTION 2110(I) OF NY INSURANCE LAW; FROM APRIL 2019 TO SEPTEMBER 2025 THE AGP WEBSITE USED INSURANCE COMPANY LOGOS WITHOUT THE FULL NAME AND PRINCIPAL ADDRESS OF EACH INSURER IN VIOLATION OF SECTION 2122(B) OF NY INSURANCE LAW; AGP FAILED TO REGISTER A SATELLITE OFFICE IN VIOLATION OF SECTION 2129 OF THE INSURANCE LAW AND REGULATION 125. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Stipulation and Consent 11. Resolution Date (MM/DD/YYYY): 11/25/2025 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: $ 7,500.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FINE OF $7,500.00 WAS PAID ON NOVEMBER 25, 2025. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE VIOLATIONS WERE INADVERTENT AND THE FIRM PAID THE $7,500.00 FINE TO RESOLVE THE MATTER.
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