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Captrust Institution

Legal: Capfinancial Partners, LLC

Raleigh, NC

AUM $1.24T
Advisors 963
Locations 211
Owners 16
Private funds 28
Filing snapshot

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

Regulatory AUM
$1.24T
Investors
963
Across 211 offices
HNW AUM share
7%
18,154 high-net-worth clients
Client mix
Individuals 19,698 $6.61B AUM High-net-worth individuals 18,154 $89.4B AUM Pooled vehicles 17 $224M AUM Pension / profit-sharing plans 3,523 $1.07T AUM Charitable organizations 232 $25.1B AUM Corporations / businesses 49 $36.5B AUM Other investment advisers 10 $1.38B AUM Other 67 $5.91B AUM
At a Glance
Firm type
Registered
Registered
Jul 11, 2003
CRD #
175112
Regulatory AUM
$1,236,704,853,633
Advisors
963
Locations
211
Locations 211
Location Advisors City State
129 RALEIGH NC
6 Alpharetta GA
22 Boston MA
16 ALLENTOWN PA
15 GREENVILLE SC
16 Uniontown OH
11 Warren NJ
15 Alexandria VA
2 Carbondale CO
15 Salt Lake City UT
4 STOCKBRIDGE GA
4 San Ramon CA
11 CHARLOTTE NC
2 Houston TX
7 Wichita KS
7 Folsom CA
9 San Antonio TX
8 Overland Park KS
6 Houston TX
23 Tampa FL
2 Las Vegas NV
6 San Antonio TX
3 Pasadena CA
1 Pearl MS
3 Lake Mary FL
17 Dallas TX
18 Costa Mesa CA
1 WEST DES MOINE IA
1 Naples FL
7 Greensburg PA
29 Brentwood TN
2 Harrisonburg VA
19 Minnetonka MN
6 Tampa FL
15 Leawood KS
24 Phoenix AZ
4 New Orleans LA
20 Sacramento CA
1 Greensboro GA
14 Chicago IL
RALEIGH, NC • 129 advisors
Alpharetta, GA • 6 advisors
Boston, MA • 22 advisors
ALLENTOWN, PA • 16 advisors
GREENVILLE, SC • 15 advisors
Uniontown, OH • 16 advisors
Warren, NJ • 11 advisors
Alexandria, VA • 15 advisors
Carbondale, CO • 2 advisors
Salt Lake City, UT • 15 advisors
STOCKBRIDGE, GA • 4 advisors
San Ramon, CA • 4 advisors
CHARLOTTE, NC • 11 advisors
Houston, TX • 2 advisors
Wichita, KS • 7 advisors
Folsom, CA • 7 advisors
San Antonio, TX • 9 advisors
Overland Park, KS • 8 advisors
Houston, TX • 6 advisors
Tampa, FL • 23 advisors
Las Vegas, NV • 2 advisors
San Antonio, TX • 6 advisors
Pasadena, CA • 3 advisors
Pearl, MS • 1 advisor
Lake Mary, FL • 3 advisors
Dallas, TX • 17 advisors
Costa Mesa, CA • 18 advisors
WEST DES MOINE, IA • 1 advisor
Naples, FL • 1 advisor
Greensburg, PA • 7 advisors
Brentwood, TN • 29 advisors
Harrisonburg, VA • 2 advisors
Minnetonka, MN • 19 advisors
Tampa, FL • 6 advisors
Leawood, KS • 15 advisors
Phoenix, AZ • 24 advisors
New Orleans, LA • 4 advisors
Sacramento, CA • 20 advisors
Greensboro, GA • 1 advisor
Chicago, IL • 14 advisors

Showing 40 of 211 locations.

Registered Advisors 963

Showing 40 of 963 advisors.

Owners & Control Persons 16
Name Title Ownership Schedule
MILLER, JAMES, FIELDING CHIEF EXECUTIVE OFFICER NA A
THE CAPFINANCIAL GROUP, LLC MEMBER E A
HOYLE, WILSON, SMITH MANAGING DIRECTOR NA A
GOLDSTEIN, BENJAMIN, STUART PRESIDENT NA A
BUCHANAN, DENISE, MCGEE SENIOR DIRECTOR COMPLIANCE NA A
SHOFF, DERICK, DON MANAGING DIRECTOR NA A
MATHESON, SCOTT, THOMAS MANAGING DIRECTOR NA A
Markell-Balleza, Christina MANAGING DIRECTOR GENERAL COUNSEL NA A
Meyer, Jonathan, Seth CHIEF TECHNOLOGY OFFICER NA A
VOGELZANG, MICHAEL, JAMES MANAGING DIRECTOR CHIEF INVESTMENT OFFICER NA A
MILLER, ROBERT, A CHIEF FINANCIAL OFFICER NA A
Welch, Edward, Virgil MANAGING DIRECTOR NA A
Leddy, Ann CHIEF COMPLIANCE OFFICER NA A
DENISE, KAREN, OLIVIA SENIOR DIRECTOR NA A
WUNDERLI, MICHAEL, ARM MANAGING DIRECTOR NA A
SAMPSON, KATELYN, NICOLE CHIEF HUMAN RESOURCES OFFICER NA A
MILLER, JAMES, FIELDING
CHIEF EXECUTIVE OFFICER • Ownership NA • Schedule A
THE CAPFINANCIAL GROUP, LLC
MEMBER • Ownership E • Schedule A
HOYLE, WILSON, SMITH
MANAGING DIRECTOR • Ownership NA • Schedule A
GOLDSTEIN, BENJAMIN, STUART
PRESIDENT • Ownership NA • Schedule A
BUCHANAN, DENISE, MCGEE
SENIOR DIRECTOR COMPLIANCE • Ownership NA • Schedule A
SHOFF, DERICK, DON
MANAGING DIRECTOR • Ownership NA • Schedule A
MATHESON, SCOTT, THOMAS
MANAGING DIRECTOR • Ownership NA • Schedule A
Markell-Balleza, Christina
MANAGING DIRECTOR GENERAL COUNSEL • Ownership NA • Schedule A
Meyer, Jonathan, Seth
CHIEF TECHNOLOGY OFFICER • Ownership NA • Schedule A
VOGELZANG, MICHAEL, JAMES
MANAGING DIRECTOR CHIEF INVESTMENT OFFICER • Ownership NA • Schedule A
MILLER, ROBERT, A
CHIEF FINANCIAL OFFICER • Ownership NA • Schedule A
Welch, Edward, Virgil
MANAGING DIRECTOR • Ownership NA • Schedule A
Leddy, Ann
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
DENISE, KAREN, OLIVIA
SENIOR DIRECTOR • Ownership NA • Schedule A
WUNDERLI, MICHAEL, ARM
MANAGING DIRECTOR • Ownership NA • Schedule A
SAMPSON, KATELYN, NICOLE
CHIEF HUMAN RESOURCES OFFICER • Ownership NA • Schedule A
Private Funds 28
Fund Type Gross assets
CAPTRUST 2022 HOMECOURT FUND LP Real Estate Fund 19188839
CCA ALOJICA INVESTORS, LP 5509000
CCA BAYVIEW INVESTORS, LP 6280399
CCA CITYGATE HOTEL INVESTORS QP, LP 9726674
CCA CITYGATE HOTEL INVESTORS, LP 9726674
CCA MEXICO OPPORTUNITIES, LP 12685667
CCA NASHVILLE INVESTORS QP, LP 9838145
CCA NASHVILLE INVESTORS, LP 9838145
CCA PINECREST INVESTORS, LP 11279195
CCA RESIDENTIAL OPPORTUNITIES 2025, LP 10390943
COBBLESTONE PRIVATE CREDIT FUND, LP Private Equity Fund 5771963
COBBLESTONE PRIVATE INCOME FUND, LP Private Equity Fund 5771963
COBBLESTONE PRIVATE REAL ESTATE FUND 2 QP, LP 18476811
COBBLESTONE PRIVATE REAL ESTATE FUND 2, LP 27702685
COBBLESTONE PRIVATE REAL ESTATE FUND, LP 22730182
ONE BRICK SELECT PRIVATE EQUITY 2024, L.P. 20950000
ONE BRICK SELECT PRIVATE REAL ESTATE 2025, L.P. 17165000
COVENANT GLOBAL EQUITIES FUND SERIES INTERESTS OF THE SALI MULTI-SERIES FUND II 3(C)(1), LP
COVENANT GLOBAL EQUITIES FUND SERIES INTERESTS OF THE SALI MULTI-SERIES FUND II, L.P.
MR INVESTMENT FUND I, LLC-CLASS 1
MRA CREDIT STRATEGIES FUND I-A, LP
MRA CREDIT STRATEGIES FUND I-B, LP
MRA OPPORTUNITIES FUND I-A, LP
MRA OPPORTUNITIES FUND I-B, LP (CLASS 1 & 2)
ONE BRICK SELECT PRIVATE CREDIT FUND I, LP
ONE BRICK SELECT PRIVATE CREDIT QUALIFIED FUND LP
TRUSTCORE PRIVATE OPPORTUNITIES FUND LP
VEGA MULTI-STRATEGY FUND SERIES OF THE SALI MULTI-SERIES FUND, L.P
CAPTRUST 2022 HOMECOURT FUND LP
Real Estate Fund • 19188839
CCA ALOJICA INVESTORS, LP
• 5509000
CCA BAYVIEW INVESTORS, LP
• 6280399
CCA CITYGATE HOTEL INVESTORS QP, LP
• 9726674
CCA CITYGATE HOTEL INVESTORS, LP
• 9726674
CCA MEXICO OPPORTUNITIES, LP
• 12685667
CCA NASHVILLE INVESTORS QP, LP
• 9838145
CCA NASHVILLE INVESTORS, LP
• 9838145
CCA PINECREST INVESTORS, LP
• 11279195
CCA RESIDENTIAL OPPORTUNITIES 2025, LP
• 10390943
COBBLESTONE PRIVATE CREDIT FUND, LP
Private Equity Fund • 5771963
COBBLESTONE PRIVATE INCOME FUND, LP
Private Equity Fund • 5771963
COBBLESTONE PRIVATE REAL ESTATE FUND 2 QP, LP
• 18476811
COBBLESTONE PRIVATE REAL ESTATE FUND 2, LP
• 27702685
COBBLESTONE PRIVATE REAL ESTATE FUND, LP
• 22730182
ONE BRICK SELECT PRIVATE EQUITY 2024, L.P.
• 20950000
ONE BRICK SELECT PRIVATE REAL ESTATE 2025, L.P.
• 17165000
COVENANT GLOBAL EQUITIES FUND SERIES INTERESTS OF THE SALI MULTI-SERIES FUND II 3(C)(1), LP
COVENANT GLOBAL EQUITIES FUND SERIES INTERESTS OF THE SALI MULTI-SERIES FUND II, L.P.
MR INVESTMENT FUND I, LLC-CLASS 1
MRA CREDIT STRATEGIES FUND I-A, LP
MRA CREDIT STRATEGIES FUND I-B, LP
MRA OPPORTUNITIES FUND I-A, LP
MRA OPPORTUNITIES FUND I-B, LP (CLASS 1 & 2)
ONE BRICK SELECT PRIVATE CREDIT FUND I, LP
ONE BRICK SELECT PRIVATE CREDIT QUALIFIED FUND LP
TRUSTCORE PRIVATE OPPORTUNITIES FUND LP
VEGA MULTI-STRATEGY FUND SERIES OF THE SALI MULTI-SERIES FUND, L.P
Notice Filed 53
StateStatusDate
ME FILED 2006-12-15
AL FILED 2007-09-07
AK FILED 2018-03-30
AZ FILED 2007-09-11
AR FILED 2009-03-30
CA FILED 2007-05-04
CO FILED 2009-04-21
DE FILED 2012-03-01
DC FILED 2007-05-04
GA FILED 2003-07-31
ID FILED 2017-12-12
IL FILED 2007-05-17
IN FILED 2008-03-25
IA FILED 2011-01-03
KS FILED 2009-03-30
KY FILED 2007-05-02
LA FILED 2003-07-31
MD FILED 2007-05-02
MA FILED 2008-01-08
MI FILED 2007-05-04
MN FILED 2009-03-30
MS FILED 2003-07-31
NE FILED 2012-03-01
NV FILED 2010-03-29
NJ FILED 2003-09-15
NM FILED 2013-11-11
NY FILED 2003-07-31
NC FILED 2003-07-11
ND FILED 2018-04-05
OH FILED 2007-05-04
OK FILED 2012-03-01
OR FILED 2018-04-05
PA FILED 2007-01-05
PR FILED 2019-09-30
RI FILED 2012-03-01
SC FILED 2003-07-31
TN FILED 2007-05-07
UT FILED 2012-03-01
VA FILED 2003-07-31
WV FILED 2013-11-11
WI FILED 2008-03-25
WY FILED 2017-07-12
VI FILED 2026-05-14
MO FILED 2009-03-30
WA FILED 2009-03-30
TX FILED 2003-08-12
CT FILED 2008-02-14
VT FILED 2007-05-02
SD FILED 2017-07-17
HI FILED 2011-09-07
FL FILED 2003-07-28
NH FILED 2007-05-02
MT FILED 2017-12-12
ME
2006-12-15
FILED
AL
2007-09-07
FILED
AK
2018-03-30
FILED
AZ
2007-09-11
FILED
AR
2009-03-30
FILED
CA
2007-05-04
FILED
CO
2009-04-21
FILED
DE
2012-03-01
FILED
DC
2007-05-04
FILED
GA
2003-07-31
FILED
ID
2017-12-12
FILED
IL
2007-05-17
FILED
IN
2008-03-25
FILED
IA
2011-01-03
FILED
KS
2009-03-30
FILED
KY
2007-05-02
FILED
LA
2003-07-31
FILED
MD
2007-05-02
FILED
MA
2008-01-08
FILED
MI
2007-05-04
FILED
MN
2009-03-30
FILED
MS
2003-07-31
FILED
NE
2012-03-01
FILED
NV
2010-03-29
FILED
NJ
2003-09-15
FILED
NM
2013-11-11
FILED
NY
2003-07-31
FILED
NC
2003-07-11
FILED
ND
2018-04-05
FILED
OH
2007-05-04
FILED
OK
2012-03-01
FILED
OR
2018-04-05
FILED
PA
2007-01-05
FILED
PR
2019-09-30
FILED
RI
2012-03-01
FILED
SC
2003-07-31
FILED
TN
2007-05-07
FILED
UT
2012-03-01
FILED
VA
2003-07-31
FILED
WV
2013-11-11
FILED
WI
2008-03-25
FILED
WY
2017-07-12
FILED
VI
2026-05-14
FILED
MO
2009-03-30
FILED
WA
2009-03-30
FILED
TX
2003-08-12
FILED
CT
2008-02-14
FILED
VT
2007-05-02
FILED
SD
2017-07-17
FILED
HI
2011-09-07
FILED
FL
2003-07-28
FILED
NH
2007-05-02
FILED
MT
2017-12-12
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Jul 11, 2003
SEC #
801-62193
CRD #
175112
SEC Region
ARO
Umbrella
N

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Filed: 2026-05-27 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 96
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 $1 billion - $10 billion
1P Legal Entity Identifier 254900D9JN5AS48QKE02
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

NC, United States

5AEmployees
Total Employees: 1,841
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 885
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 422
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 885
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 5
5B(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency 181
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 25
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 0
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) 19,698 $6,609,218,504.00
(b) High net worth individuals 18,154 $89,355,583,796.00
(f) Pooled investment vehicles 17 $224,431,228.00
(g) Pension and profit sharing plans 3,523 $1,071,600,410,597.00
(h) Charitable organizations 232 $25,076,916,036.00
(i) State or municipal government entities 49 $36,546,135,626.00
(k) Insurance companies 10 $1,382,914,861.00
(m) Corporations or other businesses 67 $5,909,242,985.00
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 Yes
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 $320,175,961,012.00 128,474
Non-Discretionary $916,528,892,621.00 18,303
Total 5F(2)(c) $1,236,704,853,633.00 146,777

AUM attributable to non-U.S. persons: $565,363,250.00

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 Yes
5G(9) Security ratings or pricing services No
5G(10) Market timing services No
5G(11) Educational seminars/workshops Yes
5G(12) Other No
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) 2,500
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 $8,309,390,183.00
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 No
5K(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise No
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)) Yes
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 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) No
6A(4) Futures commission merchant No
6A(5) Real estate broker, dealer, or agent No
6A(6) Insurance broker or agent Yes
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 Yes
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 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 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 No
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) 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 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 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 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 Yes
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 No
9A(1)(b) Securities No
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 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 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 2024-07
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 40
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
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) No
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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