Firm profile

A.G.P / Alliance Global Partners

WESTPORT, CTCRD 8361Registration Status: ApprovedEffective since June 15, 2009SEC # 801-70276Latest ADV October 2, 2026

A.G.P / Alliance Global Partners is an SEC registered investment adviser organized as a limited liability company with a primary office location in Westport, CT. Its latest Form ADV filing, dated September 30, 2026, reports $2.9B in regulatory assets under management, 332 employees, 20 offices, and 7,490 accounts.

Assets Under Management
$2.9B
Employees
332
Offices
20 offices
Total Clients
6,959

Associated firm names

24 names listed
  • A.G.P / ALLIANCE GLOBAL PARTNERS
  • VAN PELT & COMPANY
  • THE A.I.D. GROUP
  • SHILLIN WEALTH MANAGEMENT

Leadership

4 roles identified
CEOPhillip William Michals
CCOJohn Joseph Venezia
CFOCraig Erin Klein

Advisory services offered

5 types reported
Financial Planning Services
Portfolio management for businesses
Portfolio management for individuals and small businesses

Fee models offered

3 types reported
Asset based fees
Hourly charges
Other fee arrangements

Offices & Contact

Primary office

WESTPORT, Connecticut, United States

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Primary office regionOther reported regions

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

Connecticut

WESTPORTPrimary office

Arizona

SCOTTSDALE

California

SANTA MONICA · NEWPORT BEACH

District of Columbia

WASHINGTON

Florida

AVENTURA · BOCA RATON

Illinois

CHICAGO

Maryland

ANNAPOLIS

Montana

KALISPELL

New Jersey

HOLMDEL · ROCHELLE PARK · RIDGEWOOD

New York

LYNBROOK · NEW YORK

North Carolina

CHARLOTTE

South Carolina

CLEMSON · HILTON HEAD

20 office records listed · 20 total offices reported. Counts can use different reporting dates. SEC filers may list only their largest 25 additional offices.

Contact and digital presence

ADV profile links

Regulatory Assets Under Management Breakdown

Total regulatory assets under management$2.9Bas of October 2, 2026
Discretionary83.4%
$2.5B
83% of total RAUM83.4%
Non-discretionary16.6%
$490M
17% of total RAUM16.6%
Regulatory assets under management are split between discretionary and non-discretionary assets.

Client Coverage Demographics

Top client segmentIndividuals represent 89.2% of total clients.
Top client categories% of clientsClients
1
Individuals
89.2%
6,208
2
HNWI
6.1%
427
3
Pension Plans
3.0%
209
4
Corporations
1.5%
106
5
Charitable
0.1%
8
Additional categories (<0.1%)
Pooled Investment Vehicles<5 clients

Assets under management Growth by Quarter

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

Total AUM$2.9B
Total Accounts7,490
10Y AUM Change+$2.4B (+488.4%)

Private Funds

Private funds reported by A.G.P / Alliance Global Partners

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Employee Growth by Quarter

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

Total Employees332
Clients per Employee21:1
10Y Employee Change+273 (+462.7%)

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

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

Reported ownership ranges

Highlighted bands show the percentage range reported in Form ADV.

0%25%50%75%100%
ALLIANCE GLOBAL HOLDINGS, INC.Direct owner · Schedule AInterest in A.G.P / ALLIANCE GLOBAL PARTNERS
75%+
DAVID ARTHUR BOCCHIIndirect owner · Schedule BInterest in DAVID BOCCHI FAMILY TRUST
75%+
PHILLIP WILLIAM MICHALSIndirect owner · Schedule BInterest in ALLIANCE GLOBAL HOLDINGS, INC.
25% to < 50%
RAFFAELE GAMBARDELLAIndirect owner · Schedule BInterest in ALLIANCE GLOBAL HOLDINGS, INC.
25% to < 50%
DAVID BOCCHI FAMILY TRUSTIndirect owner · Schedule BInterest in ALLIANCE GLOBAL HOLDINGS, INC.
25% to < 50%

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

12 entries
#Owner / person & roleInterest in entityReported interestControl personTitle / status acquiredSource
1THOMAS JOSEPH HIGGINSPRINCIPAL OPERATIONS OFFICERIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NANoPRINCIPAL OPERATIONS OFFICER09/2018Schedule APDF page 47
2PHILLIP WILLIAM MICHALSCHIEF EXECUTIVE OFFICERIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NAYesCHIEF EXECUTIVE OFFICER01/2019Schedule APDF page 48
3ANTHONY JOSEPH LAURIELLOMUNICIPAL SECURITIES PRINCIPALIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NANoMUNICIPAL SECURITIES PRINCIPAL02/2019Schedule APDF page 48
4JOHN JOSEPH VENEZIACHIEF COMPLIANCE OFFICER - BROKER DEALER, RIAIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NAYesCHIEF COMPLIANCE OFFICER - BROKER DEALER, RIA05/2019Schedule APDF page 48
5CRAIG ERIN KLEINCFO, PRINCIPAL FINANCIAL OFFICERIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NAYesCFO, PRINCIPAL FINANCIAL OFFICER10/2019Schedule APDF page 48
6RAFFAELE GAMBARDELLACOO/CHIEF RISK OFFICERIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NAYesCOO/CHIEF RISK OFFICER06/2020Schedule APDF page 48
7ALLIANCE GLOBAL HOLDINGS, INC.HOLDING COMPANYDomestic entityA.G.P / ALLIANCE GLOBAL PARTNERS75% or moreCode EYesHOLDING COMPANY07/2021Schedule APDF page 48
8TIMOTHY FRANCIS CASSIDYADMINISTRATION OFFICERIndividualA.G.P / ALLIANCE GLOBAL PARTNERSLess than 5%Code NANoADMINISTRATION OFFICER08/2026Schedule APDF page 48
9PHILLIP WILLIAM MICHALSPARTNERIndividualALLIANCE GLOBAL HOLDINGS, INC.25% to less than 50%Code CYesPARTNER07/2021Schedule BPDF page 48
10RAFFAELE GAMBARDELLAPARTNERIndividualALLIANCE GLOBAL HOLDINGS, INC.25% to less than 50%Code CYesPARTNER07/2021Schedule BPDF page 48
11DAVID BOCCHI FAMILY TRUSTPARTNERDomestic entityALLIANCE GLOBAL HOLDINGS, INC.25% to less than 50%Code CYesPARTNER07/2021Schedule BPDF page 48
12DAVID ARTHUR BOCCHITRUSTEEIndividualDAVID BOCCHI FAMILY TRUST75% or moreCode EYesTRUSTEE09/2020Schedule 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.

RIA or supervised-person involvementThe RIA reported that one or more events below involve the firm or its supervised persons.RIA responseYes
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.

* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.