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From the firm’s latest Form ADV. Clients are Item 5C advisory clients.
| Location | Advisors | City | State |
|---|---|---|---|
| 61 | NASHVILLE | TN | |
| 1 | Southold | NY | |
| 20 | LOS ANGELES | CA | |
| 5 | San Antonio | TX | |
| 1 | BOSTON | MA | |
| 102 | NEW YORK | NY | |
| 3 | CHICAGO | IL | |
| 11 | CHICAGO | IL | |
| 1 | Fair Lawn | NJ | |
| 5 | ATLANTA | GA | |
| 15 | MIAMI | FL | |
| 5 | CLEVELAND | OH | |
| 22 | Houston | TX | |
| 8 | MINNEAPOLIS | MN | |
| 1 | West Plam Beach | FL | |
| 2 | WASHINGTON | DC | |
| 9 | DENVER | CO | |
| 15 | PHILADELPHIA | PA | |
| 16 | New York | NY | |
| 1 | WEST PALM BEACH | FL | |
| 2 | Cleveland | OH | |
| 6 | Dallas | TX | |
| 1 | Atlanta | GA | |
| 5 | SEATTLE | WA | |
| 8 | Stamford | CT | |
| 1 | West Palm Beach | FL | |
| 6 | Los Angeles | CA | |
| 6 | Tampa | FL | |
| 1 | CCCCCCTAMPA | FL | |
| 2 | West Palm Beach | FL | |
| 3 | San Diego | CA | |
| 1 | Washington, DC | DC | |
| 2 | SAN FRANCISCO | CA | |
| 6 | Seattle | WA | |
| 4 | San Francisco | CA | |
| 10 | TAMPA | FL | |
| 4 | Boston | MA | |
| 4 | Nashville | TN | |
| 5 | Los Angeles | CA | |
| 3 | Boston | MA |
Showing 40 of 156 locations.
| Name |
|---|
Showing 40 of 538 advisors.
This firm answered Yes to 8 Form ADV Item 11 disclosure questions. Each line is from the firm’s SEC filing on this profile.
Advisors on this roster with disclosure categories marked Yes
Full Item 11 checklist is in the ADV form below. How to read Item 11
| Name | Title | Ownership | Schedule |
|---|---|---|---|
| ALLIANCEBERNSTEIN CORPORATION | GENERAL PARTNER | NA | A |
| ALLIANCEBERNSTEIN HOLDING L.P. | LIMITED PARTNER | C | A |
| MANLEY, MARK, RANDALL | GENERAL COUNSEL & CORPORATE SECRETARY | NA | A |
| PEARSON, MARK, (NMN) | DIRECTOR OF AB | NA | A |
| ALPHA UNITS HOLDINGS II, INC. | LIMITED PARTNER | B | A |
| BERNSTEIN, SETH, PERRY | CHIEF EXECUTIVE OFFICER | NA | A |
| KAYE, DANIEL, GEORGE | DIRECTOR OF ABC | NA | A |
| NARAYANDAS, DAS, (NMN) | DIRECTOR OF ABC | NA | A |
| EQUITABLE HOLDINGS, INC. | LIMITED PARTNER | C | A |
| ALPHA UNITS HOLDINGS, INC. | LIMITED PARTNER | C | A |
| STONEHILL, CHARLES, GERALD | DIRECTOR OF ABC THOROTON | NA | A |
| LANE, NICK, BURRITT | DIRECTOR OF ABC | NA | A |
| WALTHALL, TODD, KENYON | DIRECTOR OF ABC | NA | A |
| LAMM-TENNANT, JOAN, (NMN) | CHAIRMAN AND DIRECTOR OF ABC | NA | A |
| SPRULES, KARL, K | CHIEF OPERATING OFFICER | NA | A |
| HOLLEY, BRUCE, M | DIRECTOR OF ABC | NA | A |
| SIMEONE, THOMAS, RUDOLPH | CHIEF FINANCIAL OFFICER | NA | A |
| EMERSON, PAUL, ALAN | CHIEF COMPLIANCE OFFICER | NA | A |
| ERZAN, AHMET, ONUR | PRESIDENT | NA | A |
| RAJU, ROBIN, MATTHEW | DIRECTOR OF ABC | NA | A |
| Fund | Type | Gross assets |
|---|---|---|
| AB ARYA PARTNERS (LUXEMBOURG) FUND, SICAV-SIF S.C.SP | — | — |
| AB ARYA PARTNERS (CAYMAN) FUND, L.P. | — | 321674600 |
| AB COMMERCIAL REAL ESTATE DEBT FUND III, SICAV-SIF S.C.SP. | — | 326944841 |
| AB COMMERCIAL REAL ESTATE DEBT FUND IV, SICAV-SIF S.C.SP. | — | 353293849 |
| AB COMMERCIAL REAL ESTATE DEBT FUND, SICAV-SIF S.C.SP. | — | 49681631 |
| AB FINANCIAL SERVICES OPPORTUNITIES MASTER FUND L.P. | — | — |
| AB FINANCIAL SERVICES OPPORTUNITIES CAYMAN FUND, L.P | — | — |
| AB FINANCIAL SERVICES OPPORTUNITIES DELAWARE FUND, L.P. | — | 1582013914 |
| AB INTERNATIONAL CONCENTRATED GROWTH HARVESTING SERIES T | — | 65662761 |
| AB MERGER ARBITRAGE (MASTER) FUND, L.P. | — | 135853002 |
| AB REAL ESTATE EQUITY PLUS (TAXABLE) FUND L.P. | — | 576208210 |
| AB RESIDENTIAL MORTGAGE ASSETS FUND LP | — | 316159510 |
| AB SYSTEMATIC MACRO (MASTER) FUND, L.P | — | 287373784 |
| AB U.S. REAL ESTATE (HNW) FUND III, L.P. | — | 332634585 |
| AB U.S. REAL ESTATE (HNW) FUND IV, L.P. | — | 31663269 |
| AB U.S. REAL ESTATE (NON-U.S.) FUND III, L.P. | — | 3464145 |
| AB U.S. REAL ESTATE (NON-US) FUND IV, L.P. | — | 794965 |
| AB U.S. REAL ESTATE (TAX EXEMPT) FUND IV, L.P. | — | 3594739 |
| AB U.S. REAL ESTATE (TAX-EXEMPT) FUND III, L.P. | — | 49824072 |
| AB US REAL ESTATE PARTNERS (REIT AIV) L.P. | — | 21588282 |
| AB-LSV PARTNERS I (CAYMAN), L.P. | — | 24641804 |
| AB-LSV PARTNERS I (DELAWARE), L.P. | — | 317847205 |
| AB-LSV PARTNERS II (CAYMAN), L.P. | — | 32454910 |
| AB-LSV PARTNERS II (DELAWARE), L.P. | — | 348927888 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB EMERGING MARKETS STRATEGIC CORE EQUITY SERIES | Hedge Fund | 197988768 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB GLOBAL CORE EQUITY SERIES | Hedge Fund | 65239658 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB GLOBAL DISRUPTORS SERIES | Hedge Fund | 86270473 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB GLOBAL RESEARCH INSIGHTS SERIES | Hedge Fund | 696784499 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB GLOBAL RESEARCH INSIGHTS SERIES II | Hedge Fund | 224441414 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB INTERNATIONAL RESEARCH INSIGHTS HARVESTING SERIES T | Hedge Fund | 70199159 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB INTERNATIONAL RESEARCH INSIGHTS SERIES | Hedge Fund | 199676657 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - AB INTERNATIONAL STRATEGIC EQUITIES SERIES | Hedge Fund | 214974691 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - ALLIANCEBERNSTEIN EUROPEAN OPPORTUNITIES SERIES | Hedge Fund | 752236476 |
| ALLIANCEBERNSTEIN DELAWARE BUSINESS TRUST - ALLIANCEBERNSTEIN FUNDAMENTAL INTERNATIONAL SMALL CAP SERIES | Hedge Fund | 178601863 |
| ALLIANCEBERNSTEIN GROUP TRUST - EMERGING MARKETS FUND | Hedge Fund | 188310930 |
| ALLIANCEBERNSTEIN SECURITIZED ASSETS MASTER FUND, L.P. | — | — |
| ALLIANCEBERNSTEIN SECURITIZED ASSETS FUND (CAYMAN), L.P. | — | — |
| ALLIANCEBERNSTEIN SECURITIZED ASSETS FUND (DELAWARE), L.P. | — | 1282562289 |
| ALLIANCEBERNSTEIN SELECT US EQUITY HOLDINGS LP | — | — |
| ALLIANCEBERNSTEIN SELECT US EQUITY (BVI) LIMITED | — | — |
Showing 40 of 62 private funds.
| State | Status | Date |
|---|---|---|
| ME | FILED | 1999-11-08 |
| AL | FILED | 1997-07-25 |
| AK | FILED | 1999-11-01 |
| AZ | FILED | 1999-10-27 |
| AR | FILED | 1999-10-27 |
| CA | FILED | 1999-10-27 |
| CO | FILED | 2003-03-28 |
| DE | FILED | 2003-09-02 |
| DC | FILED | 1999-11-02 |
| GA | FILED | 1999-10-27 |
| ID | FILED | 1999-12-07 |
| IL | FILED | 1999-10-27 |
| IN | FILED | 1993-07-20 |
| IA | FILED | 1999-10-27 |
| KS | FILED | 1999-11-18 |
| KY | FILED | 1993-09-28 |
| LA | FILED | 2014-03-31 |
| MD | FILED | 1999-11-12 |
| MA | FILED | 1999-10-27 |
| MI | FILED | 1999-01-20 |
| MN | FILED | 1999-11-16 |
| MS | FILED | 2001-03-27 |
| NE | FILED | 2000-11-13 |
| NV | FILED | 1999-10-27 |
| NJ | FILED | 1999-11-01 |
| NM | FILED | 1999-10-28 |
| NY | FILED | 1999-12-07 |
| NC | FILED | 2001-03-27 |
| ND | FILED | 2001-05-22 |
| OH | FILED | 1999-11-04 |
| OK | FILED | 1999-11-23 |
| OR | FILED | 1993-06-30 |
| PA | FILED | 1999-11-18 |
| PR | FILED | 1999-10-27 |
| RI | FILED | 1993-07-23 |
| SC | FILED | 1999-10-28 |
| TN | FILED | 1998-06-08 |
| UT | FILED | 1999-10-28 |
| VA | FILED | 1999-12-07 |
| WV | FILED | 1999-10-29 |
| WI | FILED | 2001-05-22 |
| MO | FILED | 1999-10-28 |
| WA | FILED | 1992-11-03 |
| TX | FILED | 1999-10-29 |
| CT | FILED | 1999-10-27 |
| VT | FILED | 1999-12-31 |
| SD | FILED | 1999-10-28 |
| HI | FILED | 1999-10-27 |
| FL | FILED | 2000-04-19 |
| NH | FILED | 1999-10-27 |
| MT | FILED | 2000-01-01 |
| 1F(5) | Total number of offices, other than your Principal Office and place of business | 59 |
| 1I | Do you have one or more websites | Yes |
| 1M | Are you registered with a foreign financial regulatory authority | No |
| 1N | Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934 | Yes |
| 1O | Did you have $1 billion or more in assets on the last day of your most recent fiscal year | Yes |
| 1O | If yes, approx. amount of assets | More than $50 billion |
| 1P | Legal Entity Identifier | 0JK55UGWSWNF3X7KLQ85 |
SEC Registration Basis (Item 2A)
| 2A(1) | Are a large advisory firm that either: (a) has regulatory assets under management of $100 million (in U.S. dollars) or more, or (b) is SEC-registered and is submitting an annual updating amendment and has regulatory assets under management of $90 million (in U.S. dollars) or more | Yes |
| 2A(2) | Are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S. dollars) and you are either: (a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of business, or (b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business | No |
| 2A(4) | Have your principal office and place of business outside the United States | No |
| 2A(5) | Are an investment adviser (or sub-adviser) to an investment company registered under the Investment Company Act of 1940 | Yes |
| 2A(6) | Are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management | No |
| 2A(7) | Are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule 203A-2 | No |
| 2A(8) | Are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with the SEC, and your principal office and place of business is the same as the registered adviser | No |
| 2A(9) | Are a newly formed adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days | No |
| 2A(10) | Are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d) | No |
| 2A(11) | Are an Internet adviser relying on rule 203A-2(e) | No |
| 2A(12) | Have received an SEC order exempting you from the prohibition against registration with the SEC | No |
| 2A(13) | Are no longer eligible to remain registered with the SEC | No |
Organization Type
Limited Partnership
Fiscal Year End
DECEMBER
Organized Under Laws Of
DE, United States
| 5B(1) | Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) | 1,616 |
| 5B(2) | Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer | 1,146 |
| 5B(3) | Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives | 507 |
| 5B(4) | Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives for an investment adviser other than you | 0 |
| 5B(5) | Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency | 16 |
| 5B(6) | Approximately how many firms or other persons solicit advisory clients on your behalf | 30 |
| Client Type | # Clients | Regulatory AUM | |
|---|---|---|---|
| (a) | Individuals (other than high net worth) | 0 | — |
| (b) | High net worth individuals | 25,513 | $77,345,000,000.00 |
| (c) | Banking or thrift institutions | 0 | — |
| (d) | Investment companies | 158 | $208,189,000,000.00 |
| (e) | Business development companies | 0 | — |
| (f) | Pooled investment vehicles | 412 | $215,323,000,000.00 |
| (g) | Pension and profit sharing plans | 539 | $13,226,000,000.00 |
| (h) | Charitable organizations | 2,289 | $5,886,000,000.00 |
| (i) | State or municipal government entities | 49 | $56,312,000,000.00 |
| (j) | Other investment advisers | 59 | $44,571,000,000.00 |
| (k) | Insurance companies | 35 | $114,322,000,000.00 |
| (l) | Sovereign wealth funds | 12 | $15,400,000,000.00 |
| (m) | Corporations or other businesses | 1,219 | $12,827,000,000.00 |
| (n) | Other | 0 | — |
| U.S. Dollar Amount | Total Accounts | |
|---|---|---|
| Discretionary | $750,281,000,000.00 | 75,555 |
| Non-Discretionary | $13,120,000,000.00 | 401 |
| Total 5F(2)(c) | $763,401,000,000.00 | 75,956 |
AUM attributable to non-U.S. persons: $211,840,000,000.00
| 5G(1) | Financial planning services | Yes |
| 5G(2) | Portfolio management for individuals and/or small businesses | Yes |
| 5G(3) | Portfolio management for investment companies | Yes |
| 5G(4) | Portfolio management for pooled investment vehicles (other than investment companies) | Yes |
| 5G(5) | Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles and) | Yes |
| 5G(6) | Pension consulting services | No |
| 5G(7) | Selection of other advisers | Yes |
| 5G(8) | Publication of periodicals or newsletters | Yes |
| 5G(9) | Security ratings or pricing services | No |
| 5G(10) | Market timing services | No |
| 5G(11) | Educational seminars/workshops | No |
| 5G(12) | Other | Yes |
| 5G(12) | Other (specify) | ASSET ALLOCATION |
| 5H | If you provide financial planning services, to how many clients did you provide these services during your last fiscal year | More than 500 |
| 5H | If more than 500, how many (rounded) | 36,500 |
| 5I(1) | Sponsor the wrap fee program | Yes |
| 5I(2a) | AUM as sponsor | — |
| 5I(2b) | AUM as portfolio manager | $61,319,000,000.00 |
| 5I(2c) | AUM as sponsor and portfolio manager | — |
| 5J | In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of investments | No |
| 5J(2) | Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory assets under management? | No |
| 5K(1) | Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account clients) | Yes |
| 5K(2) | Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise | No |
| 5K(3) | Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise | Yes |
| 5K(4) | After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten percent or more of this remaining amount of regulatory assets under management | Yes |
| 5L(1)(a) | Do any of your advertisements include performance results | Yes |
| 5L(1)(b) | Do any of your advertisements include a reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5)) | No |
| 5L(1)(c) | Do any of your advertisements include testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii)) | Yes |
| 5L(1)(d) | Do any of your advertisements include endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii)) | No |
| 5L(1)(e) | Do any of your advertisements include third-party ratings | Yes |
| 5L(2) | Do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in connection with the use of testimonials, endorsements, or third-party ratings | Yes |
| 5L(3) | Do any of your advertisements include hypothetical performance | Yes |
| 5L(4) | Do any of your advertisements include predecessor performance | Yes |
You or any related person are registered as or qualified as any of the following (Item 6A)
| 6A(1) | Broker-dealer (registered or unregistered) | No |
| 6A(2) | Registered representative of a broker-dealer | No |
| 6A(3) | Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) | Yes |
| 6A(4) | Futures commission merchant | No |
| 6A(5) | Real estate broker, dealer, or agent | No |
| 6A(6) | Insurance broker or agent | No |
| 6A(7) | Bank (including a separately identifiable department or division of a bank) | No |
| 6A(8) | Trust company | No |
| 6A(9) | Registered municipal advisor | No |
| 6A(10) | Registered security-based swap dealer | No |
| 6A(11) | Major security-based swap participant | No |
| 6A(12) | Accountant or accounting firm | No |
| 6A(13) | Lawyer or law firm | No |
| 6A(14) | Other financial product salesperson | No |
| 6B(1) | Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice) | No |
| 6B(3) | Do you sell products or provide services other than investment advice to your advisory clients | No |
Related persons that are (Item 7A)
| 7A(1) | Broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) | Yes |
| 7A(2) | Other investment adviser (including financial planners) | Yes |
| 7A(3) | Registered municipal advisor | No |
| 7A(4) | Registered security-based swap dealer | No |
| 7A(5) | Major security-based swap participant | No |
| 7A(6) | Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) | Yes |
| 7A(7) | Futures commission merchant | No |
| 7A(8) | Banking or thrift institution | No |
| 7A(9) | Trust company | Yes |
| 7A(10) | Accountant or accounting firm | No |
| 7A(11) | Lawyer or law firm | No |
| 7A(12) | Insurance company or agency | Yes |
| 7A(13) | Pension consultant | No |
| 7A(14) | Real estate broker or dealer | No |
| 7A(15) | Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles | Yes |
| 7A(16) | Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles | Yes |
| 7B | Are you an adviser to any private fund | Yes |
| 8A(1) | Buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions) | No |
| 8A(2) | Buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients | Yes |
| 8A(3) | Recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A(1) or (2)) | Yes |
| 8B(1) | As a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer (agency cross transactions) | Yes |
| 8B(2) | Recommend purchase of securities to advisory clients for which you or any related person serves as underwriter, general or managing partner, or purchaser representative | No |
| 8B(3) | Recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt of sales commissions as a broker or registered representative of a broker-dealer) | Yes |
| 8C(1) | Securities to be bought or sold for a client's account | Yes |
| 8C(2) | Amount of securities to be bought or sold for a client's account | Yes |
| 8C(3) | Broker or dealer to be used for a purchase or sale of securities for a client's account | Yes |
| 8C(4) | Commission rates to be paid to a broker or dealer for a client's securities transactions | Yes |
| 8D | If you answer "yes" to 8C.(3), are any of the brokers or dealers related persons | Yes |
| 8E | Do you or any related person recommend brokers or dealers to clients | Yes |
| 8F | If you answer "yes" to 8E, are any of the brokers or dealers related persons | Yes |
| 8G(1) | Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions | Yes |
| 8G(2) | If "yes" to G.(1), are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section 28(e) of the Securities Exchange Act of 1934 | Yes |
| 8H(1) | Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals | Yes |
| 8H(2) | Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients | Yes |
| 8I | Do you or any related person, directly or indirectly, receive compensation from any person for client referrals | No |
| 9A(1)(a) | Cash or bank accounts | Yes |
| 9A(1)(b) | Securities | Yes |
| 9A(2a) | Dollar amount in custody | $39,599,193,440.00 |
| 9A(2b) | Number of clients | 117 |
| 9B(1)(a) | Cash or bank accounts | Yes |
| 9B(1)(b) | Securities | Yes |
| 9C(1) | A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage | No |
| 9C(2) | An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are distributed to the investors in the pools | Yes |
| 9C(3) | An independent public accountant conducts an annual surprise examination of client funds and securities | Yes |
| 9C(4) | An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified custodians for client funds and securities | Yes |
| 9D(1) | You act as a qualified custodian | No |
| 9D(2) | Do you or your related persons act as qualified custodians for your clients in connection with advisory services you provide to clients your related persons act as qualified custodians | Yes |
| 9E | Surprise examination date | 2025-12 |
| 9F | If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients | 1 |
| 10A | Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies | No |
| 11A(1) | Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony | No |
| 11A(2) | Been charged with any felony | No |
| 11B(1) | Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses | No |
| 11B(2) | Been charged with a misdemeanor listed in 11.B(1) | No |
| 11C(1) | Found you or any advisory affiliate to have made a false statement or omission | No |
| 11C(2) | Found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes | Yes |
| 11C(3) | Found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted | No |
| 11C(4) | Entered an order against you or any advisory affiliate in connection with investment-related activity | Yes |
| 11C(5) | Imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity | Yes |
| 11D(1) | Ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical | No |
| 11D(2) | Ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes | Yes |
| 11D(3) | Ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted | No |
| 11D(4) | In the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity | Yes |
| 11D(5) | Ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity | Yes |
| 11E(1) | Found you or any advisory affiliate to have made a false statement or omission | No |
| 11E(2) | Found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC) | Yes |
| 11E(3) | Found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted | No |
| 11E(4) | Disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities | No |
| 11F | Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended | No |
| 11G | Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E | No |
| 11H(1)(a) | The past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity | No |
| 11H(1)(b) | Ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations | No |
| 11H(1)(c) | Ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority | No |
| 11H(2) | Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1) | No |
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