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Wells Fargo Advisors Institution

Legal: Wells Fargo Clearing Services, LLC

St. Louis, MO

AUM $671B
Clients 5,302
Advisors 15274
Locations 3547
Owners 11
Filing snapshot

From the firm’s latest Form ADV. Clients are Item 5C advisory clients.

Regulatory AUM
$671B
Clients
5,302
Fiscal-year advisory clients
Investors
15,274
Across 3,547 offices
Clients per advisor
0.3
Low
Uses the rounded Item 5C count
Avg AUM per client
$127M
Regulatory AUM ÷ clients
HNW AUM share
74%
654,519 high-net-worth clients
Client mix
Individuals 644,097 $123B AUM High-net-worth individuals 654,519 $495B AUM Banks / thrifts 10 $13.9M AUM Pension / profit-sharing plans 9,346 $8.70B AUM Charitable organizations 5,564 $14.7B AUM Corporations / businesses 64 $823M AUM Other investment advisers 23 $393M AUM Other 10,435 $29.1B AUM Other 110 $96.3M AUM
At a Glance
Firm type
Registered
Registered
Oct 5, 1990
CRD #
19616
Regulatory AUM
$671,421,842,699
Advisors
15274
Locations
3547
Locations 3547
Location Advisors City State
446 ST. LOUIS MO
16 CONSHOHOCKEN PA
72 SAN JOSE CA
541 ST. LOUIS MO
13 SAN JOSE CA
3 CONCORD NC
39 RICHMOND VA
21 NAPERVILLE IL
19 ROCKFORD IL
12 BELLINGHAM WA
40 WOODLAND HILLS CA
4 PALM COAST FL
1 SUCCASUNNA NJ
36 HONOLULU HI
19 EAST LANSING MI
1 LARGO FL
33 DALLAS TX
53 BETHESDA MD
5 BILLINGS MT
3 DENTON TX
32 PASADENA CA
1 ST. JOSEPH MI
58 SHORT HILLS NJ
11 CHARLOTTE NC
22 CHARLOTTESVILLE VA
20 FARMINGTON HILLS MI
41 MCLEAN VA
35 BLOOMINGTON MN
1 PONTE VEDRA BEACH FL
3 LOS ANGELES CA
2 DURANGO CO
83 BOCA RATON FL
27 OAKHURST NJ
1 ATLANTIC IA
16 EDMOND OK
27 TAMPA FL
6 JOHNSON CITY TN
21 MANCHESTER NH
38 SCOTTSDALE AZ
26 BEVERLY MA
ST. LOUIS, MO • 446 advisors
CONSHOHOCKEN, PA • 16 advisors
SAN JOSE, CA • 72 advisors
ST. LOUIS, MO • 541 advisors
SAN JOSE, CA • 13 advisors
CONCORD, NC • 3 advisors
RICHMOND, VA • 39 advisors
NAPERVILLE, IL • 21 advisors
ROCKFORD, IL • 19 advisors
BELLINGHAM, WA • 12 advisors
WOODLAND HILLS, CA • 40 advisors
PALM COAST, FL • 4 advisors
SUCCASUNNA, NJ • 1 advisor
HONOLULU, HI • 36 advisors
EAST LANSING, MI • 19 advisors
LARGO, FL • 1 advisor
DALLAS, TX • 33 advisors
BETHESDA, MD • 53 advisors
BILLINGS, MT • 5 advisors
DENTON, TX • 3 advisors
PASADENA, CA • 32 advisors
ST. JOSEPH, MI • 1 advisor
SHORT HILLS, NJ • 58 advisors
CHARLOTTE, NC • 11 advisors
CHARLOTTESVILLE, VA • 22 advisors
FARMINGTON HILLS, MI • 20 advisors
MCLEAN, VA • 41 advisors
BLOOMINGTON, MN • 35 advisors
PONTE VEDRA BEACH, FL • 1 advisor
LOS ANGELES, CA • 3 advisors
DURANGO, CO • 2 advisors
BOCA RATON, FL • 83 advisors
OAKHURST, NJ • 27 advisors
ATLANTIC, IA • 1 advisor
EDMOND, OK • 16 advisors
TAMPA, FL • 27 advisors
JOHNSON CITY, TN • 6 advisors
MANCHESTER, NH • 21 advisors
SCOTTSDALE, AZ • 38 advisors
BEVERLY, MA • 26 advisors

Showing 40 of 3547 locations.

Registered Advisors 15274

Showing 40 of 15274 advisors.

Disclosures

This firm answered Yes to 23 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

Owners & Control Persons 11
Name Title Ownership Schedule
WACHOVIA SECURITIES SOLE MEMBER FINANCIAL HOLDINGS, LLC E A
KARANIK, ERIK ANTHONY BOARD OF MANAGERS NA A
SOMMERS, BARRY CHIEF EXECUTIVE OFFICER / BOARD OF MANAGERS NA A
CRONK, DARRELL HEAD OF INVESTMENT SOLUTIONS / WIM CHIEF INVESTMENT OFFICER / BOARD OF MANAGERS / CONTROL PRINCIPAL NA A
GINDI, SOL PRESIDENT / HEAD OF WIM DISTRIBUTION / BOARD OF MANAGERS / CONTROL PRINCIPAL NA A
SAUNDERS, DAVID WARD DESIGNATED STATE PRINCIPAL NA A
PATEL, RAKESH CHIEF FINANCIAL OFFICER / BOARD OF MANAGERS NA A
LACEY, PAUL PRINCIPAL OPERATIONS OFFICER / CONTROL PRINCIPAL NA A
TSAMADIAS, CHRISTOS G CHIEF COMPLIANCE OFFICER NA A
SOMESHWAR, PRASANNA HEAD OF BANKING, LENDING & TRUST / CONTROL PRINCIPAL NA A
TA, KIMBERLY CROWDER WEALTH CLIENT MANAGEMENT SENIOR EXECUTIVE/CONTROL PRINCIPAL NA A
WACHOVIA SECURITIES
SOLE MEMBER FINANCIAL HOLDINGS, LLC • Ownership E • Schedule A
KARANIK, ERIK ANTHONY
BOARD OF MANAGERS • Ownership NA • Schedule A
SOMMERS, BARRY
CHIEF EXECUTIVE OFFICER / BOARD OF MANAGERS • Ownership NA • Schedule A
CRONK, DARRELL
HEAD OF INVESTMENT SOLUTIONS / WIM CHIEF INVESTMENT OFFICER / BOARD OF MANAGERS / CONTROL PRINCIPAL • Ownership NA • Schedule A
GINDI, SOL
PRESIDENT / HEAD OF WIM DISTRIBUTION / BOARD OF MANAGERS / CONTROL PRINCIPAL • Ownership NA • Schedule A
SAUNDERS, DAVID WARD
DESIGNATED STATE PRINCIPAL • Ownership NA • Schedule A
PATEL, RAKESH
CHIEF FINANCIAL OFFICER / BOARD OF MANAGERS • Ownership NA • Schedule A
LACEY, PAUL
PRINCIPAL OPERATIONS OFFICER / CONTROL PRINCIPAL • Ownership NA • Schedule A
TSAMADIAS, CHRISTOS G
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
SOMESHWAR, PRASANNA
HEAD OF BANKING, LENDING & TRUST / CONTROL PRINCIPAL • Ownership NA • Schedule A
TA, KIMBERLY CROWDER
WEALTH CLIENT MANAGEMENT SENIOR EXECUTIVE/CONTROL PRINCIPAL • Ownership NA • Schedule A
Notice Filed 52
StateStatusDate
ME FILED 1993-08-13
AL FILED 1992-01-02
AK FILED 1991-06-11
AZ FILED 2002-03-28
AR FILED 1991-05-23
CA FILED 1997-07-08
CO FILED 1999-02-23
DE FILED 2003-07-31
DC FILED 1996-01-01
GA FILED 1992-01-16
ID FILED 1992-06-01
IL FILED 1999-05-21
IN FILED 2000-10-18
IA FILED 1999-03-01
KS FILED 1997-12-15
KY FILED 2002-03-28
LA FILED 2001-10-05
MD FILED 1992-03-31
MI FILED 2002-03-28
MN FILED 1991-04-30
MS FILED 1998-05-22
NE FILED 1998-04-14
NV FILED 1994-08-30
NJ FILED 1992-12-14
NM FILED 1996-01-16
NY FILED 1993-01-14
NC FILED 2000-10-18
ND FILED 2002-03-28
OH FILED 2001-04-19
OK FILED 2001-04-19
OR FILED 2002-03-28
PA FILED 2002-03-28
PR FILED 2002-08-02
RI FILED 1998-10-09
SC FILED 2000-10-18
TN FILED 1997-10-02
UT FILED 1991-04-22
VA FILED 1992-08-20
WV FILED 1993-01-05
WI FILED 1991-05-13
WY FILED 2017-07-03
VI FILED 2005-06-24
MO FILED 1991-04-01
WA FILED 1991-12-05
TX FILED 1989-11-01
CT FILED 1998-03-11
VT FILED 2002-03-28
SD FILED 1992-12-01
HI FILED 1991-07-22
FL FILED 1994-11-23
NH FILED 1993-01-01
MT FILED 1997-12-18
ME
1993-08-13
FILED
AL
1992-01-02
FILED
AK
1991-06-11
FILED
AZ
2002-03-28
FILED
AR
1991-05-23
FILED
CA
1997-07-08
FILED
CO
1999-02-23
FILED
DE
2003-07-31
FILED
DC
1996-01-01
FILED
GA
1992-01-16
FILED
ID
1992-06-01
FILED
IL
1999-05-21
FILED
IN
2000-10-18
FILED
IA
1999-03-01
FILED
KS
1997-12-15
FILED
KY
2002-03-28
FILED
LA
2001-10-05
FILED
MD
1992-03-31
FILED
MI
2002-03-28
FILED
MN
1991-04-30
FILED
MS
1998-05-22
FILED
NE
1998-04-14
FILED
NV
1994-08-30
FILED
NJ
1992-12-14
FILED
NM
1996-01-16
FILED
NY
1993-01-14
FILED
NC
2000-10-18
FILED
ND
2002-03-28
FILED
OH
2001-04-19
FILED
OK
2001-04-19
FILED
OR
2002-03-28
FILED
PA
2002-03-28
FILED
PR
2002-08-02
FILED
RI
1998-10-09
FILED
SC
2000-10-18
FILED
TN
1997-10-02
FILED
UT
1991-04-22
FILED
VA
1992-08-20
FILED
WV
1993-01-05
FILED
WI
1991-05-13
FILED
WY
2017-07-03
FILED
VI
2005-06-24
FILED
MO
1991-04-01
FILED
WA
1991-12-05
FILED
TX
1989-11-01
FILED
CT
1998-03-11
FILED
VT
2002-03-28
FILED
SD
1992-12-01
FILED
HI
1991-07-22
FILED
FL
1994-11-23
FILED
NH
1993-01-01
FILED
MT
1997-12-18
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Oct 5, 1990
SEC #
801-37967
CRD #
19616
SEC Region
CHRO
Umbrella
N

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Filed: 2026-08-28 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 5,038
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 No
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 $10 billion - $50 billion
1P Legal Entity Identifier 88KRVSOEKUGQZJ3DKW55
2SEC Registration / Reporting

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 No
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
3Form of Organization

Organization Type

Limited Liability Company

Fiscal Year End

DECEMBER

Organized Under Laws Of

DE, United States

5AEmployees
Total Employees: 18,895
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 7,957
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 18,895
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 15,038
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 15
5B(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency 13,779
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 155
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 5302
5C(2) Approximately what percentage of your clients are non-United States persons 1
5DClient Types & Assets Under Management
Client Type # Clients Regulatory AUM
(a) Individuals (other than high net worth) 644,097 $122,514,556,616.00
(b) High net worth individuals 654,519 $495,074,796,828.00
(c) Banking or thrift institutions 10 $13,931,688.00
(d) Investment companies 0
(e) Business development companies 0
(f) Pooled investment vehicles 0
(g) Pension and profit sharing plans 9,346 $8,702,088,459.00
(h) Charitable organizations 5,564 $14,669,916,487.00
(i) State or municipal government entities 64 $823,111,400.00
(j) Other investment advisers 0
(k) Insurance companies 23 $392,769,566.00
(l) Sovereign wealth funds 0
(m) Corporations or other businesses 10,435 $29,134,401,850.00
(n) Other 110 $96,269,805.00
5ECompensation Arrangements
5E(1) A percentage of assets under your management Yes
5E(2) Hourly charges No
5E(3) Subscription fees (for a newsletter or periodical) No
5E(4) Fixed fees (other than subscription fees) Yes
5E(5) Commissions Yes
5E(6) Performance-based fees No
5E(7) Other No
5FRegulatory Assets Under Management
5F(1) Do you provide continuous and regular supervisory or management services to securities portfolios Yes
U.S. Dollar Amount Total Accounts
Discretionary $478,834,872,430.00 987,321
Non-Discretionary $192,586,970,269.00 336,847
Total 5F(2)(c) $671,421,842,699.00 1,324,168

AUM attributable to non-U.S. persons: $23,765,388.00

5GAdvisory Services Provided
5G(1) Financial planning services Yes
5G(2) Portfolio management for individuals and/or small businesses Yes
5G(3) Portfolio management for investment companies No
5G(4) Portfolio management for pooled investment vehicles (other than investment companies) No
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 Yes
5G(7) Selection of other advisers Yes
5G(8) Publication of periodicals or newsletters No
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) INVESTMENT CONSULTING SERVICES TO INSTITUTIONAL CLIENTS
5HFinancial Planning Clients
5H If you provide financial planning services, to how many clients did you provide these services during your last fiscal year 51-100
5IWrap Fee Programs
5I(1) Sponsor the wrap fee program Yes
5I(2a)AUM as sponsor $192,586,970,269.00
5I(2b)AUM as portfolio manager
5I(2c)AUM as sponsor and portfolio manager $478,834,872,430.00
5J-KInvestment Types & Separately Managed Accounts
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 Yes
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 Yes
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 No
5LMarketing & Advertising
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)) No
5L(1)(d) Do any of your advertisements include endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii)) Yes
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 No
6Other Business Activities

You or any related person are registered as or qualified as any of the following (Item 6A)

6A(1) Broker-dealer (registered or unregistered) Yes
6A(2) Registered representative of a broker-dealer No
6A(3) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) No
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 Yes
6A(14) Other (specify) INSURANCE PRODUCT SALES
6B(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice) Yes
6B(2) If yes, is this other business your primary business No
6B(3) Do you sell products or provide services other than investment advice to your advisory clients Yes
7Financial Industry Affiliations

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 Yes
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 Yes
7A(8) Banking or thrift institution Yes
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 Yes
7A(14) Real estate broker or dealer Yes
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 No
8Participation or Interest in Client Transactions
8A(1) Buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions) Yes
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 Yes
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 No
8E Do you or any related person recommend brokers or dealers to clients No
8F If you answer "yes" to 8E, are any of the brokers or dealers related persons No
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 No
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 No
8I Do you or any related person, directly or indirectly, receive compensation from any person for client referrals Yes
9Custody
9A(1)(a) Cash or bank accounts Yes
9A(1)(b) Securities Yes
9A(2a) Dollar amount in custody $665,667,968,512.00
9A(2b) Number of clients 1,306,709
9B(1)(a) Cash or bank accounts No
9B(1)(b) Securities No
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 No
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 Yes
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 No
9E Surprise examination date 2025-08
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
10Control Persons
10A Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies Yes
11Disclosure Information
This firm has one or more disciplinary disclosures on record.
11 Do any of the events below involve you or any of your supervised persons Yes
11A(1) Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony Yes
11A(2) Been charged with any felony Yes
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 Yes
11B(2) Been charged with a misdemeanor listed in 11.B(1) Yes
11C(1) Found you or any advisory affiliate to have made a false statement or omission Yes
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 Yes
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 Yes
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 Yes
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 Yes
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 Yes
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 Yes
11H(1)(a) The past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity Yes
11H(1)(b) Ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations Yes
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 Yes
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) Yes

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