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Btg Pactual Asset Management Us , LLC Enterprise

New York, NY

AUM $30.1B
Clients 18
Advisors 67
Locations 12
Owners 6
Private funds 43
Filing snapshot

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

Regulatory AUM
$30.1B
Clients
18
Fiscal-year advisory clients
Investors
67
Across 12 offices
Clients per advisor
0.3
Low
Uses the rounded Item 5C count
Avg AUM per client
$1.67B
Regulatory AUM ÷ clients
HNW AUM share
4%
139 high-net-worth clients
Client mix
Individuals 77 $34.6M AUM High-net-worth individuals 139 $1.10B AUM Pooled vehicles 57 $20.0B AUM Insurance companies $7.27B AUM Other 343 $1.67B AUM
At a Glance
Firm type
Registered
Registered
Jan 19, 2010
CRD #
152538
Regulatory AUM
$30,107,889,463
Advisors
67
Locations
12
Locations 12
NEW YORK, NY • 45 advisors
Miami, FL • 4 advisors
Miami, FL • 8 advisors
Miami, FL • 13 advisors
Miami, FL • 2 advisors
Miami, FL • 2 advisors
Miami, FL • 3 advisors
Guatemala • 1 advisor
MIAMI, FL • 1 advisor
Registered Advisors 67

Showing 40 of 67 advisors.

Disclosures

This firm answered Yes to 1 Form ADV Item 11 disclosure question. 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 6
Name Title Ownership Schedule
FATH, JOHN, JOSEPH MANAGING PARTNER NA A
ROSE, WILLIAM, GLISSON CHIEF OPERATING OFFICER NA A
DIXIT, NANDIKESH, ANILKUMAR CHIEF LEGAL OFFICER NA A
MARON, ALEXIS, GONTOW CHIEF FINANCIAL OFFICER NA A
BTG PACTUAL BANCORP LLC SOLE MEMBER E A
FRANKOWSKA, DAGMARA, KATARZYNA CHIEF COMPLIANCE OFFICER NA A
FATH, JOHN, JOSEPH
MANAGING PARTNER • Ownership NA • Schedule A
ROSE, WILLIAM, GLISSON
CHIEF OPERATING OFFICER • Ownership NA • Schedule A
DIXIT, NANDIKESH, ANILKUMAR
CHIEF LEGAL OFFICER • Ownership NA • Schedule A
MARON, ALEXIS, GONTOW
CHIEF FINANCIAL OFFICER • Ownership NA • Schedule A
BTG PACTUAL BANCORP LLC
SOLE MEMBER • Ownership E • Schedule A
FRANKOWSKA, DAGMARA, KATARZYNA
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
Private Funds 43
Fund Type Gross assets
AURORA MIDWEST INDUSTRIAL HOLDINGS LP
AURORA MIDWEST INDUSTRIAL HOLDINGS CAYMAN FEEDER LP 104101425
BTF II CO-INVEST, LP 43276039
BTF II, LP 185582540
BTF II-A, LP 274123310
BTF II-B, LP
BTF II-C CO-INVEST, LP 72885295
BTF II-C, LP 99728010
BTF II-D CO-INVEST, LP 55435755
BTF III, LP 80878462
BTG PACTUAL ABSOLUTE RETURN MASTER FUND, LP 3558801000
BTG PACTUAL BRAZIL TIMBERLAND FUND I, LP 287530680
BTG PACTUAL GLOBAL RATES MASTER FUND, LP 5002627000
BTG PACTUAL PNW FUND III LLC 235003020
BTG PACTUAL PNW FUND IV LLC 193466602
BTG PACTUAL RATES MASTER FUND LTD
BTG PACTUAL RATES FUND, LLC
BTG PACTUAL RATES FUND, LTD. 6698617000
BTG PACTUAL STRATEGIC CAPITAL FUND A, L.P. 387831916
BTG PACTUAL STRATEGIC CAPITAL FUND B, L.P. 30615548
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY MASTER FUND, L.P.
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY FUND
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY FUND LLC 356081000
BTG PACTUAL U.S. DIRECT LENDING L.P. Liquidity Fund 320030644
BTG PACTUAL U.S. PRIVATE CREDIT INVESTMENTS L.P. Liquidity Fund 445868622
FAZENDA TURMALINA HOLDINGS, LLC 1412
GAB ACCESS FUND LP - SERIES 2 10950045
GAB ACCESS FUND LP - SERIES 3 6315156
GAB ACCESS FUND LP - SERIES 4 3376654
GAB ACCESS FUND LP - SERIES 5 22343045
GAB ACCESS FUND LP - SERIES 6 6783231
GAB ACCESS FUND LP - SERIES 7 8898394
GAB ACCESS FUND LP - SERIES 8 5933402
PROJECT BLAZERS CO-INVESTORS, L.P. 855208
PROJECT CONNECT CO-INVESTORS, L.P. 3437387
PROJECT KELLY CO-INVESTORS A, L.P. 401650
PROJECT KELLY CO-INVESTORS B, L.P. 879831
PROJECT KELLY CO-INVESTORS C, L.P. 350135
PROJECT LONGHORN AGGREGATOR, L.P.
PROJECT LONGHORN CO-INVESTORS II, L.P.
AURORA MIDWEST INDUSTRIAL HOLDINGS LP
AURORA MIDWEST INDUSTRIAL HOLDINGS CAYMAN FEEDER LP
• 104101425
BTF II CO-INVEST, LP
• 43276039
BTF II, LP
• 185582540
BTF II-A, LP
• 274123310
BTF II-B, LP
BTF II-C CO-INVEST, LP
• 72885295
BTF II-C, LP
• 99728010
BTF II-D CO-INVEST, LP
• 55435755
BTF III, LP
• 80878462
BTG PACTUAL ABSOLUTE RETURN MASTER FUND, LP
• 3558801000
BTG PACTUAL BRAZIL TIMBERLAND FUND I, LP
• 287530680
BTG PACTUAL GLOBAL RATES MASTER FUND, LP
• 5002627000
BTG PACTUAL PNW FUND III LLC
• 235003020
BTG PACTUAL PNW FUND IV LLC
• 193466602
BTG PACTUAL RATES MASTER FUND LTD
BTG PACTUAL RATES FUND, LLC
BTG PACTUAL RATES FUND, LTD.
• 6698617000
BTG PACTUAL STRATEGIC CAPITAL FUND A, L.P.
• 387831916
BTG PACTUAL STRATEGIC CAPITAL FUND B, L.P.
• 30615548
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY MASTER FUND, L.P.
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY FUND
BTG PACTUAL STRUCTURED CREDIT OPPORTUNITY FUND LLC
• 356081000
BTG PACTUAL U.S. DIRECT LENDING L.P.
Liquidity Fund • 320030644
BTG PACTUAL U.S. PRIVATE CREDIT INVESTMENTS L.P.
Liquidity Fund • 445868622
FAZENDA TURMALINA HOLDINGS, LLC
• 1412
GAB ACCESS FUND LP - SERIES 2
• 10950045
GAB ACCESS FUND LP - SERIES 3
• 6315156
GAB ACCESS FUND LP - SERIES 4
• 3376654
GAB ACCESS FUND LP - SERIES 5
• 22343045
GAB ACCESS FUND LP - SERIES 6
• 6783231
GAB ACCESS FUND LP - SERIES 7
• 8898394
GAB ACCESS FUND LP - SERIES 8
• 5933402
PROJECT BLAZERS CO-INVESTORS, L.P.
• 855208
PROJECT CONNECT CO-INVESTORS, L.P.
• 3437387
PROJECT KELLY CO-INVESTORS A, L.P.
• 401650
PROJECT KELLY CO-INVESTORS B, L.P.
• 879831
PROJECT KELLY CO-INVESTORS C, L.P.
• 350135
PROJECT LONGHORN AGGREGATOR, L.P.
PROJECT LONGHORN CO-INVESTORS II, L.P.

Showing 40 of 43 private funds.

Notice Filed 53
StateStatusDate
ME FILED 2024-11-26
AL FILED 2024-11-26
AK FILED 2024-11-26
AZ FILED 2024-11-26
AR FILED 2024-11-26
CA FILED 2024-11-26
CO FILED 2024-11-26
DE FILED 2024-11-26
DC FILED 2024-11-26
GA FILED 2014-03-31
ID FILED 2024-11-26
IL FILED 2024-11-26
IN FILED 2024-11-26
IA FILED 2024-11-26
KS FILED 2024-11-26
KY FILED 2024-11-26
LA FILED 2024-11-26
MD FILED 2024-11-26
MA FILED 2024-11-26
MI FILED 2024-11-26
MN FILED 2024-11-26
MS FILED 2024-11-26
NE FILED 2024-11-26
NV FILED 2024-11-26
NJ FILED 2024-11-26
NM FILED 2024-11-26
NY FILED 2010-01-19
NC FILED 2024-11-26
ND FILED 2024-11-26
OH FILED 2024-11-26
OK FILED 2024-11-26
OR FILED 2024-11-26
PA FILED 2024-11-26
PR FILED 2024-11-26
RI FILED 2024-11-26
SC FILED 2024-11-26
TN FILED 2024-11-26
UT FILED 2024-11-26
VA FILED 2024-11-26
WV FILED 2024-11-26
WI FILED 2024-11-26
WY FILED 2024-11-26
VI FILED 2024-11-26
MO FILED 2024-11-26
WA FILED 2024-03-28
TX FILED 2024-11-26
CT FILED 2014-03-31
VT FILED 2024-11-26
SD FILED 2024-11-26
HI FILED 2024-11-26
FL FILED 2014-03-31
NH FILED 2024-11-26
MT FILED 2023-03-31
ME
2024-11-26
FILED
AL
2024-11-26
FILED
AK
2024-11-26
FILED
AZ
2024-11-26
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AR
2024-11-26
FILED
CA
2024-11-26
FILED
CO
2024-11-26
FILED
DE
2024-11-26
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DC
2024-11-26
FILED
GA
2014-03-31
FILED
ID
2024-11-26
FILED
IL
2024-11-26
FILED
IN
2024-11-26
FILED
IA
2024-11-26
FILED
KS
2024-11-26
FILED
KY
2024-11-26
FILED
LA
2024-11-26
FILED
MD
2024-11-26
FILED
MA
2024-11-26
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MI
2024-11-26
FILED
MN
2024-11-26
FILED
MS
2024-11-26
FILED
NE
2024-11-26
FILED
NV
2024-11-26
FILED
NJ
2024-11-26
FILED
NM
2024-11-26
FILED
NY
2010-01-19
FILED
NC
2024-11-26
FILED
ND
2024-11-26
FILED
OH
2024-11-26
FILED
OK
2024-11-26
FILED
OR
2024-11-26
FILED
PA
2024-11-26
FILED
PR
2024-11-26
FILED
RI
2024-11-26
FILED
SC
2024-11-26
FILED
TN
2024-11-26
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UT
2024-11-26
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VA
2024-11-26
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WV
2024-11-26
FILED
WI
2024-11-26
FILED
WY
2024-11-26
FILED
VI
2024-11-26
FILED
MO
2024-11-26
FILED
WA
2024-03-28
FILED
TX
2024-11-26
FILED
CT
2014-03-31
FILED
VT
2024-11-26
FILED
SD
2024-11-26
FILED
HI
2024-11-26
FILED
FL
2014-03-31
FILED
NH
2024-11-26
FILED
MT
2023-03-31
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Jan 19, 2010
SEC #
801-71004
CRD #
152538
SEC Region
NYRO
Umbrella
Y

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Filed: 2026-03-31 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 10
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 No
1P Legal Entity Identifier 549300H3WT9MK7RPEQ50
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: 180
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 108
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 60
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 68
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 0
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 23
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 18
5C(2) Approximately what percentage of your clients are non-United States persons 83
5DClient Types & Assets Under Management
Client Type # Clients Regulatory AUM
(a) Individuals (other than high net worth) 77 $34,617,400.00
(b) High net worth individuals 139 $1,098,196,044.00
(c) Banking or thrift institutions 0
(d) Investment companies 0
(e) Business development companies 0
(f) Pooled investment vehicles 57 $20,033,083,302.00
(g) Pension and profit sharing plans 0
(h) Charitable organizations 0
(i) State or municipal government entities
(j) Other investment advisers 0
(k) Insurance companies 0
(l) Sovereign wealth funds $7,267,712,093.00
(m) Corporations or other businesses 343 $1,674,280,624.00
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 Yes
5E(7) Other Yes
5E(7) Other (specify) ANNUAL FIXED ADVISORY RETAINER FOR INSTITUTIONAL ADVISORY WORK
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 $29,717,389,137.00 563
Non-Discretionary $390,500,326.00 58
Total 5F(2)(c) $30,107,889,463.00 621

AUM attributable to non-U.S. persons: $27,824,888,732.00

5GAdvisory Services Provided
5G(1) Financial planning services No
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) 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 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) CONSULTING FOR FINANCIAL INSTITUTIONS
5IWrap Fee Programs
5I(1) Sponsor the wrap fee program Yes
5I(2a)AUM as sponsor
5I(2b)AUM as portfolio manager
5I(2c)AUM as sponsor and portfolio manager $95,420,881.00
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 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 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 Yes
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)) Yes
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 Yes
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) 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
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 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 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 No
7A(14) Real estate broker or dealer No
7A(15) Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles No
7A(16) Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Yes
7B Are you an adviser to any private fund Yes
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) No
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 No
8I Do you or any related person, directly or indirectly, receive compensation from any person for client referrals No
9Custody
9A(1)(a) Cash or bank accounts Yes
9A(1)(b) Securities Yes
9A(2a) Dollar amount in custody $19,500,374,774.00
9A(2b) Number of clients 51
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 No
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
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 25
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 No
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 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 No
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 No
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 No
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 No
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 No
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 No
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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