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Rbc Capital Markets, LLC Institution

New York, NY

AUM $310B
Clients 1,893
Advisors 3972
Locations 698
Owners 11
Private funds 3
Filing snapshot

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

Regulatory AUM
$310B
Clients
1,893
Fiscal-year advisory clients
Investors
3,972
Across 698 offices
Clients per advisor
0.5
Low
Uses the rounded Item 5C count
Avg AUM per client
$164M
Regulatory AUM ÷ clients
HNW AUM share
32%
12,350 high-net-worth clients
Client mix
Individuals 263,588 $182B AUM High-net-worth individuals 12,350 $98.5B AUM Banks / thrifts 7 $55.6M AUM Pooled vehicles 17 $652M AUM Pension / profit-sharing plans 2,335 $2.67B AUM Charitable organizations 2,222 $10.8B AUM Corporations / businesses 215 $1.24B AUM Other investment advisers 105 $445M AUM Other 3,071 $13.8B AUM
At a Glance
Firm type
Registered
Registered
Jun 2, 1977
CRD #
31194
Regulatory AUM
$310,428,968,904
Advisors
3972
Locations
698
Locations 698
Location Advisors City State
101 NEW YORK NY
31 Philadelphia PA
9 WATERTOWN NY
36 STILLWATER MN
3 BRYN MAWR PA
19 PORTLAND ME
34 CONSHOHOCKEN PA
15 CHARLOTTE NC
202 MINNEAPOLIS MN
10 BOULDER CO
1 EDEN PRAIRIE MN
41 MINNEAPOLIS MN
37 SYRACUSE NY
17 PARAMUS NJ
20 GLASTONBURY CT
25 ST. PETERSBURG FL
26 KIRKLAND WA
32 CHICAGO IL
23 PHOENIX AZ
19 Westlake OH
9 CHADDS FORD PA
25 ALBUQUERQUE NM
22 SHOREVIEW MN
53 EDINA MN
18 ROCHESTER NY
15 ALBANY NY
109 FLORHAM PARK NJ
14 Miami FL
25 Sarasota FL
33 Frisco TX
38 ANNAPOLIS MD
28 Green Bay WI
11 FARGO ND
50 LEAWOOD KS
5 FREDERICK MD
55 SAN FRANCISCO CA
13 GREAT FALLS MT
2 Chapel Hill NC
7 TYLER TX
11 DANVERS MA
NEW YORK, NY • 101 advisors
Philadelphia, PA • 31 advisors
WATERTOWN, NY • 9 advisors
STILLWATER, MN • 36 advisors
BRYN MAWR, PA • 3 advisors
PORTLAND, ME • 19 advisors
CONSHOHOCKEN, PA • 34 advisors
CHARLOTTE, NC • 15 advisors
MINNEAPOLIS, MN • 202 advisors
BOULDER, CO • 10 advisors
EDEN PRAIRIE, MN • 1 advisor
MINNEAPOLIS, MN • 41 advisors
SYRACUSE, NY • 37 advisors
PARAMUS, NJ • 17 advisors
GLASTONBURY, CT • 20 advisors
ST. PETERSBURG, FL • 25 advisors
KIRKLAND, WA • 26 advisors
CHICAGO, IL • 32 advisors
PHOENIX, AZ • 23 advisors
Westlake, OH • 19 advisors
CHADDS FORD, PA • 9 advisors
ALBUQUERQUE, NM • 25 advisors
SHOREVIEW, MN • 22 advisors
EDINA, MN • 53 advisors
ROCHESTER, NY • 18 advisors
ALBANY, NY • 15 advisors
FLORHAM PARK, NJ • 109 advisors
Miami, FL • 14 advisors
Sarasota, FL • 25 advisors
Frisco, TX • 33 advisors
ANNAPOLIS, MD • 38 advisors
Green Bay, WI • 28 advisors
FARGO, ND • 11 advisors
LEAWOOD, KS • 50 advisors
FREDERICK, MD • 5 advisors
SAN FRANCISCO, CA • 55 advisors
GREAT FALLS, MT • 13 advisors
Chapel Hill, NC • 2 advisors
TYLER, TX • 7 advisors
DANVERS, MA • 11 advisors

Showing 40 of 698 locations.

Registered Advisors 3972

Showing 40 of 3972 advisors.

Disclosures

This firm answered Yes to 9 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
RBC USA HOLDCO CORPORATION DIRECT OWNER E A
SAGISSOR, THOMAS STEVEN PRESIDENT OF RBC WEALTH MANAGEMENT NA A
THORNE, BRETT LANE PRESIDENT, RBC CLEARING & CUSTODY NA A
PENN, JOHN CHRISTOPHER GENERAL COUNSEL NA A
CARLESIMO, PAUL ADAM CHIEF COMPLIANCE OFFICER, RBC NA A
GLASSMAN, DORJE TSERING CO-HEAD OF U.S. CAPITAL MARKETS LAW GROUP NA A
ESPENAK, KRISTEN ELIZABETH CHIEF RISK OFFICER, USA NA A
SCHREINER, CINDY LOUISE US WEALTH MANAGEMENT PRINCIPAL OPERATIONS OFFICER NA A
SPERDUTO, VITO ANTONIO DIRECTOR, CEO OF U.S. CAPITAL MARKETS & CHAIRMAN OF THE BOARD NA A
O'CONNOR, SEAN WALTER CHIEF COMPLIANCE OFFICER, RBC NA A
RICATTI, JENNIFER LEE PRINCIPAL FINANCIAL OFFICER NA A
RBC USA HOLDCO CORPORATION
DIRECT OWNER • Ownership E • Schedule A
SAGISSOR, THOMAS STEVEN
PRESIDENT OF RBC WEALTH MANAGEMENT • Ownership NA • Schedule A
THORNE, BRETT LANE
PRESIDENT, RBC CLEARING & CUSTODY • Ownership NA • Schedule A
PENN, JOHN CHRISTOPHER
GENERAL COUNSEL • Ownership NA • Schedule A
CARLESIMO, PAUL ADAM
CHIEF COMPLIANCE OFFICER, RBC • Ownership NA • Schedule A
GLASSMAN, DORJE TSERING
CO-HEAD OF U.S. CAPITAL MARKETS LAW GROUP • Ownership NA • Schedule A
ESPENAK, KRISTEN ELIZABETH
CHIEF RISK OFFICER, USA • Ownership NA • Schedule A
SCHREINER, CINDY LOUISE
US WEALTH MANAGEMENT PRINCIPAL OPERATIONS OFFICER • Ownership NA • Schedule A
SPERDUTO, VITO ANTONIO
DIRECTOR, CEO OF U.S. CAPITAL MARKETS & CHAIRMAN OF THE BOARD • Ownership NA • Schedule A
O'CONNOR, SEAN WALTER
CHIEF COMPLIANCE OFFICER, RBC • Ownership NA • Schedule A
RICATTI, JENNIFER LEE
PRINCIPAL FINANCIAL OFFICER • Ownership NA • Schedule A
Private Funds 3
Fund Type Gross assets
CORUNDUM INCOME FUND QP LLC
CORUNDUM MANAGED EQUITY FUND AI LLC
CORUNDUM MANAGED EQUITY FUND QP LLC
CORUNDUM INCOME FUND QP LLC
CORUNDUM MANAGED EQUITY FUND AI LLC
CORUNDUM MANAGED EQUITY FUND QP LLC
Notice Filed 52
StateStatusDate
ME FILED 2002-01-30
AL FILED 1996-02-27
AK FILED 1996-02-08
AZ FILED 2001-08-16
AR FILED 1999-01-08
CA FILED 1997-07-08
CO FILED 1999-01-01
DE FILED 2003-08-21
DC FILED 1998-05-28
GA FILED 1998-01-02
ID FILED 1991-08-20
IL FILED 1990-08-03
IN FILED 2001-02-06
IA FILED 1999-01-01
KS FILED 1997-12-04
KY FILED 2001-01-11
LA FILED 2001-10-01
MD FILED 1996-08-09
MI FILED 1998-04-23
MN FILED 1998-03-05
MS FILED 1998-01-21
NE FILED 1999-03-25
NV FILED 1993-01-11
NJ FILED 1998-04-21
NM FILED 1996-05-17
NY FILED 1993-03-10
NC FILED 2001-01-11
ND FILED 1996-10-25
OH FILED 2000-06-16
OK FILED 1998-01-01
OR FILED 2001-08-20
PA FILED 2001-08-16
PR FILED 1998-04-22
RI FILED 1998-04-22
SC FILED 1996-07-15
TN FILED 1998-04-13
UT FILED 1995-04-11
VA FILED 1993-03-12
WV FILED 1998-04-23
WI FILED 1998-04-15
WY FILED 2017-07-05
VI FILED 2008-10-06
MO FILED 1990-07-11
WA FILED 1988-06-01
TX FILED 1998-01-20
CT FILED 1997-02-24
VT FILED 1998-04-23
SD FILED 1990-08-23
HI FILED 1998-04-21
FL FILED 2001-03-26
NH FILED 1996-08-12
MT FILED 1997-12-01
ME
2002-01-30
FILED
AL
1996-02-27
FILED
AK
1996-02-08
FILED
AZ
2001-08-16
FILED
AR
1999-01-08
FILED
CA
1997-07-08
FILED
CO
1999-01-01
FILED
DE
2003-08-21
FILED
DC
1998-05-28
FILED
GA
1998-01-02
FILED
ID
1991-08-20
FILED
IL
1990-08-03
FILED
IN
2001-02-06
FILED
IA
1999-01-01
FILED
KS
1997-12-04
FILED
KY
2001-01-11
FILED
LA
2001-10-01
FILED
MD
1996-08-09
FILED
MI
1998-04-23
FILED
MN
1998-03-05
FILED
MS
1998-01-21
FILED
NE
1999-03-25
FILED
NV
1993-01-11
FILED
NJ
1998-04-21
FILED
NM
1996-05-17
FILED
NY
1993-03-10
FILED
NC
2001-01-11
FILED
ND
1996-10-25
FILED
OH
2000-06-16
FILED
OK
1998-01-01
FILED
OR
2001-08-20
FILED
PA
2001-08-16
FILED
PR
1998-04-22
FILED
RI
1998-04-22
FILED
SC
1996-07-15
FILED
TN
1998-04-13
FILED
UT
1995-04-11
FILED
VA
1993-03-12
FILED
WV
1998-04-23
FILED
WI
1998-04-15
FILED
WY
2017-07-05
FILED
VI
2008-10-06
FILED
MO
1990-07-11
FILED
WA
1988-06-01
FILED
TX
1998-01-20
FILED
CT
1997-02-24
FILED
VT
1998-04-23
FILED
SD
1990-08-23
FILED
HI
1998-04-21
FILED
FL
2001-03-26
FILED
NH
1996-08-12
FILED
MT
1997-12-01
FILED
Registration
Firm Type
Registered
Status
APPROVED
Registered
Jun 2, 1977
SEC #
801-13059
CRD #
31194
SEC Region
NYRO
Umbrella
N

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Filed: 2026-08-24 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 382
1I Do you have one or more websites Yes
1M Are you registered with a foreign financial regulatory authority Yes
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 More than $50 billion
1P Legal Entity Identifier 549300LCO2FLSSVFFR64
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

OCTOBER

Organized Under Laws Of

MN, United States

5AEmployees
Total Employees: 8,781
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 5,908
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 6,457
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 3,750
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 2,595
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 39
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 1893
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) 263,588 $182,247,279,546.00
(b) High net worth individuals 12,350 $98,498,809,440.00
(c) Banking or thrift institutions 7 $55,561,030.00
(d) Investment companies 0
(e) Business development companies 0
(f) Pooled investment vehicles 17 $651,533,555.00
(g) Pension and profit sharing plans 2,335 $2,670,518,609.00
(h) Charitable organizations 2,222 $10,797,612,893.00
(i) State or municipal government entities 215 $1,243,218,500.00
(j) Other investment advisers 0
(k) Insurance companies 105 $445,270,565.00
(l) Sovereign wealth funds 0
(m) Corporations or other businesses 3,071 $13,819,164,766.00
(n) Other 0
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 No
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 $235,345,268,053.00 417,652
Non-Discretionary $75,083,700,851.00 94,219
Total 5F(2)(c) $310,428,968,904.00 511,871

AUM attributable to non-U.S. persons: $1,574,901,330.00

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 Yes
5G(12) Other Yes
5G(12) Other (specify) SERVICE PUBLIC & PRIVATE EMPLOYEE BENEFIT PLANS, ENDOWMENT FUNDS, FOUNDATIONS, FAMILY TRUSTS & VARIOUS CAPITAL/OPERATING FUNDS
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 $75,083,700,851.00
5I(2b)AUM as portfolio manager
5I(2c)AUM as sponsor and portfolio manager $235,345,268,053.00
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 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 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 Yes
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 Yes
6A(10) Registered security-based swap dealer Yes
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 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 No
7A(15) Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles Yes
7A(16) Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Yes
7B Are you an adviser to any private fund Yes
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) 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 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 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 Yes
9A(1)(b) Securities Yes
9A(2a) Dollar amount in custody $308,854,067,574.00
9A(2b) Number of clients 282,307
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 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 Yes
9E Surprise examination date 2025-06
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 36
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 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 Yes
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 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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