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Hightower Advisors, LLC Enterprise

Chicago, IL

AUM $199B
Clients 500
Advisors 1088
Locations 325
Owners 11
Private funds 1
Filing snapshot

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

Regulatory AUM
$199B
Clients
500
Fiscal-year advisory clients
Investors
1,088
Across 325 offices
Clients per advisor
0.5
Low
Uses the rounded Item 5C count
Avg AUM per client
$397M
Regulatory AUM ÷ clients
HNW AUM share
79%
29,177 high-net-worth clients
Client mix
Individuals 33,630 $21.5B AUM High-net-worth individuals 29,177 $157B AUM Banks / thrifts $20.1M AUM Pooled vehicles 1 $181M AUM Pension / profit-sharing plans 221 $796M AUM Charitable organizations 357 $2.78B AUM Corporations / businesses $36.0M AUM Other investment advisers 9 $42.4M AUM Other 640 $15.8B AUM
At a Glance
Firm type
Registered
Registered
Oct 3, 2008
CRD #
145323
Regulatory AUM
$198,577,009,283
Advisors
1088
Locations
325
Locations 325
Location Advisors City State
634 CHICAGO IL
2 BELLEVUE WA
7 Boca Raton FL
16 New York City NY
2 Alpharetta GA
1 MADISON CT
7 Wayne PA
37 Dallas TX
14 Houston TX
1 San Antonio TX
7 Colorado Springs CO
4 Williamsville NY
3 Marlton NJ
9 Marlton NJ
15 Los Angeles CA
25 New York NY
6 Aurora IL
5 Fort Myers FL
5 Arlington VA
2 CIncinnati OH
3 San Juan Capistrano CA
9 Portsmouth NH
1 Tampa FL
2 WATERTOWN NY
1 Tampa FL
12 Purchase NY
3 Scottsdale AZ
3 Fort Worth TX
4 Watertown NY
2 Westport CT
1 Colorado Springs CO
4 Los Angeles CA
1 WATERTOWN NY
6 SAN DIEGO CA
7 Orlando FL
8 Spokane WA
1 Mount Joy PA
3 Buffalo NY
1 PALM DESERT CA
13 Cleveland OH
CHICAGO, IL • 634 advisors
BELLEVUE, WA • 2 advisors
Boca Raton, FL • 7 advisors
New York City, NY • 16 advisors
Alpharetta, GA • 2 advisors
MADISON, CT • 1 advisor
Wayne, PA • 7 advisors
Dallas, TX • 37 advisors
Houston, TX • 14 advisors
San Antonio, TX • 1 advisor
Colorado Springs, CO • 7 advisors
Williamsville, NY • 4 advisors
Marlton, NJ • 3 advisors
Marlton, NJ • 9 advisors
Los Angeles, CA • 15 advisors
New York, NY • 25 advisors
Aurora, IL • 6 advisors
Fort Myers, FL • 5 advisors
Arlington, VA • 5 advisors
CIncinnati, OH • 2 advisors
San Juan Capistrano, CA • 3 advisors
Portsmouth, NH • 9 advisors
Tampa, FL • 1 advisor
WATERTOWN, NY • 2 advisors
Purchase, NY • 12 advisors
Scottsdale, AZ • 3 advisors
Fort Worth, TX • 3 advisors
Watertown, NY • 4 advisors
Westport, CT • 2 advisors
Colorado Springs, CO • 1 advisor
Los Angeles, CA • 4 advisors
WATERTOWN, NY • 1 advisor
SAN DIEGO, CA • 6 advisors
Orlando, FL • 7 advisors
Spokane, WA • 8 advisors
Mount Joy, PA • 1 advisor
Buffalo, NY • 3 advisors
PALM DESERT, CA • 1 advisor
Cleveland, OH • 13 advisors

Showing 40 of 325 locations.

Registered Advisors 1088

Showing 40 of 1088 advisors.

Disclosures

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

Owners & Control Persons 11
Name Title Ownership Schedule
HIGHTOWER HOLDING, LLC HOLDING COMPANY E A
BESSO, DOUGLAS, JOSEPH CHIEF TECHNOLOGY OFFICER NA A
COVIELLO, BARRY, ANTHONY NATIONAL DIRECTOR OF FIELD SUPERVISION NA A
BERG, DANIEL, JEREMY CHIEF FINANCIAL OFFICER NA A
SCHWARTZ, JARED, NOLAN CHIEF RISK OFFICER NA A
LOPEZ, BARRETT GENERAL COUNSEL CORPORATE AND M&A NA A
RESTIERI, LAWRENCE, JOSEPH CHIEF EXECUTIVE OFFICER NA A
Dunne, Patrick, James CHIEF OPERATING OFFICER NA A
San Juan, Jyothi EXECUTIVE DIRECTOR COMPLIANCE NA A
Bernardo, Michael CHIEF COMPLIANCE OFFICER NA A
HADLEY, SCOTT, ROLAND CHIEF ADVISORY OFFICER NA A
HIGHTOWER HOLDING, LLC
HOLDING COMPANY • Ownership E • Schedule A
BESSO, DOUGLAS, JOSEPH
CHIEF TECHNOLOGY OFFICER • Ownership NA • Schedule A
COVIELLO, BARRY, ANTHONY
NATIONAL DIRECTOR OF FIELD SUPERVISION • Ownership NA • Schedule A
BERG, DANIEL, JEREMY
CHIEF FINANCIAL OFFICER • Ownership NA • Schedule A
SCHWARTZ, JARED, NOLAN
CHIEF RISK OFFICER • Ownership NA • Schedule A
LOPEZ, BARRETT
GENERAL COUNSEL CORPORATE AND M&A • Ownership NA • Schedule A
RESTIERI, LAWRENCE, JOSEPH
CHIEF EXECUTIVE OFFICER • Ownership NA • Schedule A
Dunne, Patrick, James
CHIEF OPERATING OFFICER • Ownership NA • Schedule A
San Juan, Jyothi
EXECUTIVE DIRECTOR COMPLIANCE • Ownership NA • Schedule A
Bernardo, Michael
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
HADLEY, SCOTT, ROLAND
CHIEF ADVISORY OFFICER • Ownership NA • Schedule A
Private Funds 1
Fund Type Gross assets
TBG ALTERNATIVE INCOME SOLUTIONS LP Hedge Fund 181634713
TBG ALTERNATIVE INCOME SOLUTIONS LP
Hedge Fund • 181634713
Notice Filed 53
StateStatusDate
ME FILED 2009-02-13
AL FILED 2009-02-13
AK FILED 2009-02-13
AZ FILED 2008-10-03
AR FILED 2009-02-13
CA FILED 2008-10-03
CO FILED 2008-10-03
DE FILED 2008-10-15
DC FILED 2008-10-03
GA FILED 2008-10-03
ID FILED 2008-10-03
IL FILED 2008-10-03
IN FILED 2008-10-03
IA FILED 2008-10-09
KS FILED 2008-10-03
KY FILED 2008-10-03
LA FILED 2009-02-13
MD FILED 2008-10-03
MA FILED 2009-02-18
MI FILED 2008-10-03
MN FILED 2008-10-03
MS FILED 2008-10-29
NE FILED 2009-02-18
NV FILED 2008-10-03
NJ FILED 2008-10-14
NM FILED 2008-10-03
NY FILED 2008-10-03
NC FILED 2008-10-03
ND FILED 2009-02-18
OH FILED 2008-10-03
OK FILED 2009-02-18
OR FILED 2008-10-03
PA FILED 2008-10-03
PR FILED 2009-02-18
RI FILED 2008-11-28
SC FILED 2009-02-18
TN FILED 2009-02-19
UT FILED 2008-10-03
VA FILED 2008-11-28
WV FILED 2009-02-18
WI FILED 2008-10-03
WY FILED 2019-03-31
VI FILED 2026-04-09
MO FILED 2008-10-03
WA FILED 2008-10-03
TX FILED 2008-10-03
CT FILED 2008-10-03
VT FILED 2008-11-28
SD FILED 2009-02-18
HI FILED 2008-11-28
FL FILED 2008-10-03
NH FILED 2009-02-18
MT FILED 2009-02-18
ME
2009-02-13
FILED
AL
2009-02-13
FILED
AK
2009-02-13
FILED
AZ
2008-10-03
FILED
AR
2009-02-13
FILED
CA
2008-10-03
FILED
CO
2008-10-03
FILED
DE
2008-10-15
FILED
DC
2008-10-03
FILED
GA
2008-10-03
FILED
ID
2008-10-03
FILED
IL
2008-10-03
FILED
IN
2008-10-03
FILED
IA
2008-10-09
FILED
KS
2008-10-03
FILED
KY
2008-10-03
FILED
LA
2009-02-13
FILED
MD
2008-10-03
FILED
MA
2009-02-18
FILED
MI
2008-10-03
FILED
MN
2008-10-03
FILED
MS
2008-10-29
FILED
NE
2009-02-18
FILED
NV
2008-10-03
FILED
NJ
2008-10-14
FILED
NM
2008-10-03
FILED
NY
2008-10-03
FILED
NC
2008-10-03
FILED
ND
2009-02-18
FILED
OH
2008-10-03
FILED
OK
2009-02-18
FILED
OR
2008-10-03
FILED
PA
2008-10-03
FILED
PR
2009-02-18
FILED
RI
2008-11-28
FILED
SC
2009-02-18
FILED
TN
2009-02-19
FILED
UT
2008-10-03
FILED
VA
2008-11-28
FILED
WV
2009-02-18
FILED
WI
2008-10-03
FILED
WY
2019-03-31
FILED
VI
2026-04-09
FILED
MO
2008-10-03
FILED
WA
2008-10-03
FILED
TX
2008-10-03
FILED
CT
2008-10-03
FILED
VT
2008-11-28
FILED
SD
2009-02-18
FILED
HI
2008-11-28
FILED
FL
2008-10-03
FILED
NH
2009-02-18
FILED
MT
2009-02-18
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Oct 3, 2008
SEC #
801-69625
CRD #
145323
SEC Region
CHRO
Umbrella
N

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Filed: 2026-08-19 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 132
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 549300UM3O7J0JIVIN7
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: 1,983
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 953
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 598
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 1,011
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 338
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 77
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 500
5C(2) Approximately what percentage of your clients are non-United States persons 10
5DClient Types & Assets Under Management
Client Type # Clients Regulatory AUM
(a) Individuals (other than high net worth) 33,630 $21,497,189,895.00
(b) High net worth individuals 29,177 $157,427,049,195.00
(c) Banking or thrift institutions $20,095,760.00
(f) Pooled investment vehicles 1 $180,634,816.00
(g) Pension and profit sharing plans 221 $795,927,811.00
(h) Charitable organizations 357 $2,783,886,100.00
(i) State or municipal government entities $35,967,619.00
(k) Insurance companies 9 $42,403,003.00
(m) Corporations or other businesses 640 $15,793,855,084.00
5ECompensation Arrangements
5E(1) A percentage of assets under your management Yes
5E(2) Hourly charges Yes
5E(3) Subscription fees (for a newsletter or periodical) No
5E(4) Fixed fees (other than subscription fees) Yes
5E(5) Commissions No
5E(6) Performance-based fees No
5E(7) Other Yes
5E(7) Other (specify) RETAINER OR SERVICE FEES OR SOME COMBINATION OF 1, 2, 4, 5 & 7
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 $190,403,937,582.00 210,830
Non-Discretionary $8,173,071,701.00 9,392
Total 5F(2)(c) $198,577,009,283.00 220,222

AUM attributable to non-U.S. persons: $20,368,385,370.00

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) 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 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) TREASURY MANAGEMENT FOR CORPORATE 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 More than 500
5H If more than 500, how many (rounded) 24,000
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 $50,440,075,115.00
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)) 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)) 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 No
5L(4) Do any of your advertisements include predecessor performance No
6Other Business Activities
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) No
7A(7) Futures commission merchant No
7A(8) Banking or thrift institution No
7A(9) Trust company Yes
7A(10) Accountant or accounting firm Yes
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) 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) No
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) 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 Yes
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 $1,231,760,008.00
9A(2b) Number of clients 645
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 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 No
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 No
9E Surprise examination date 2025-01
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 15
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 Yes
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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