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Synovus Securities, Inc. Multi-team

Columbus, GA

AUM $8.45B
Clients 100
Advisors 180
Locations 66
Owners 9
Filing snapshot

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

Regulatory AUM
$8.45B
Clients
100
Fiscal-year advisory clients
Investors
180
Across 66 offices
Clients per advisor
0.6
Low
Uses the rounded Item 5C count
Avg AUM per client
$84.5M
Regulatory AUM ÷ clients
HNW AUM share
59%
1,938 high-net-worth clients
Client mix
Individuals 10,026 $2.67B AUM High-net-worth individuals 1,938 $4.96B AUM Pension / profit-sharing plans 131 $99.0M AUM Charitable organizations 86 $174M AUM Other 230 $551M AUM
At a Glance
Firm type
Registered
Registered
Sep 1, 1983
CRD #
14023
Regulatory AUM
$8,445,083,014
Advisors
180
Locations
66
Locations 66
Location Advisors City State
9 COLUMBUS GA
2 STATESBORO GA
2 BRADENTON FL
29 NEWNAN GA
2 SUMTER SC
9 ATLANTA GA
12 ATLANTA GA
2 FORT MYERS FL
2 SAVANNAH GA
1 STUART FL
1 TIFTON GA
4 MACON GA
1 LEESBURG GA
2 CAPE CORAL FL
1 PERRY GA
6 Orlando F FL
1 TUCKER GA
9 ALPHARETTA GA
3 PENSACOLA FL
19 BIRMINGHAM AL
4 LAGRANGE GA
2 ATHENS GA
1 WARNER ROBINS GA
9 PORT CHARLOTTE FL
2 DOUGLASVILLE GA
5 HUNTSVILLE AL
1 MONTGOMERY AL
1 PINECREST FL
1 COLUMBIA SC
1 MIAMI FL
2 FORT LAUDERDALE FL
1 DAVIE FL
1 PEACHTREE CITY GA
1 NAPLES FL
1 STATESBORO GA
2 NASHVILLE TN
6 CHARLESTON SC
1 Tampa FL
1 MONROE GA
4 COLUMBIA SC
COLUMBUS, GA • 9 advisors
STATESBORO, GA • 2 advisors
BRADENTON, FL • 2 advisors
NEWNAN, GA • 29 advisors
SUMTER, SC • 2 advisors
ATLANTA, GA • 9 advisors
ATLANTA, GA • 12 advisors
FORT MYERS, FL • 2 advisors
SAVANNAH, GA • 2 advisors
STUART, FL • 1 advisor
TIFTON, GA • 1 advisor
MACON, GA • 4 advisors
LEESBURG, GA • 1 advisor
CAPE CORAL, FL • 2 advisors
PERRY, GA • 1 advisor
Orlando F, FL • 6 advisors
TUCKER, GA • 1 advisor
ALPHARETTA, GA • 9 advisors
PENSACOLA, FL • 3 advisors
BIRMINGHAM, AL • 19 advisors
LAGRANGE, GA • 4 advisors
ATHENS, GA • 2 advisors
WARNER ROBINS, GA • 1 advisor
PORT CHARLOTTE, FL • 9 advisors
DOUGLASVILLE, GA • 2 advisors
HUNTSVILLE, AL • 5 advisors
MONTGOMERY, AL • 1 advisor
PINECREST, FL • 1 advisor
COLUMBIA, SC • 1 advisor
MIAMI, FL • 1 advisor
FORT LAUDERDALE, FL • 2 advisors
DAVIE, FL • 1 advisor
PEACHTREE CITY, GA • 1 advisor
NAPLES, FL • 1 advisor
STATESBORO, GA • 1 advisor
NASHVILLE, TN • 2 advisors
CHARLESTON, SC • 6 advisors
Tampa, FL • 1 advisor
MONROE, GA • 1 advisor
COLUMBIA, SC • 4 advisors

Showing 40 of 66 locations.

Registered Advisors 180

Showing 40 of 180 advisors.

Owners & Control Persons 9
Name Title Ownership Schedule
SEXTON, GUY LEONARD EVP/DIRECTOR NA A
VARNER, ROBERT PARKER PRESIDENT NA A
GUNDERSON, GENE FREDERICK DIRECTOR OF COMPLIANCE, TRUST & BROKERAGE NA A
LAW, ROBERT WARD PRESIDENT - CFG DIVISION NA A
KIRK, LEAH JEANETTE CHIEF OPERATIONS OFFICER NA A
MCKENZIE, MICHELLE JESSUP ROP NA A
BROOKS, WILLIAM THOMAS CHIEF COMPLIANCE OFFICER NA A
ELEAM, JENNA KELLEY CHIEF FINANCIAL OFFICER / FINOP NA A
PINNACLE FINANCIAL PARTNERS INC. SYNOVUS SECURITIES E A
SEXTON, GUY LEONARD
EVP/DIRECTOR • Ownership NA • Schedule A
VARNER, ROBERT PARKER
PRESIDENT • Ownership NA • Schedule A
GUNDERSON, GENE FREDERICK
DIRECTOR OF COMPLIANCE, TRUST & BROKERAGE • Ownership NA • Schedule A
LAW, ROBERT WARD
PRESIDENT - CFG DIVISION • Ownership NA • Schedule A
KIRK, LEAH JEANETTE
CHIEF OPERATIONS OFFICER • Ownership NA • Schedule A
MCKENZIE, MICHELLE JESSUP
ROP • Ownership NA • Schedule A
BROOKS, WILLIAM THOMAS
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
ELEAM, JENNA KELLEY
CHIEF FINANCIAL OFFICER / FINOP • Ownership NA • Schedule A
PINNACLE FINANCIAL PARTNERS INC.
SYNOVUS SECURITIES • Ownership E • Schedule A
Notice Filed 52
StateStatusDate
ME FILED 2018-03-09
AL FILED 1991-03-14
AK FILED 2021-07-15
AZ FILED 2002-08-20
AR FILED 1997-08-07
CA FILED 2002-05-21
CO FILED 2005-09-02
DE FILED 2007-07-13
DC FILED 2014-01-02
GA FILED 1989-05-03
ID FILED 2019-12-18
IL FILED 1985-12-11
IN FILED 2010-11-30
IA FILED 2004-09-13
KS FILED 2010-11-30
KY FILED 2005-01-19
LA FILED 2008-12-17
MD FILED 2010-11-30
MA FILED 2010-11-30
MI FILED 2015-09-01
MN FILED 2007-08-04
MS FILED 2006-06-23
NE FILED 2004-09-02
NV FILED 2004-10-04
NJ FILED 1996-03-01
NM FILED 2004-12-06
NY FILED 2005-07-13
NC FILED 2001-10-24
ND FILED 2020-07-24
OH FILED 2005-05-05
OK FILED 2002-09-19
OR FILED 2015-07-31
PA FILED 2014-01-02
RI FILED 2010-11-30
SC FILED 1998-12-16
TN FILED 1998-04-30
UT FILED 2005-01-31
VA FILED 2004-12-08
WV FILED 2017-07-24
WI FILED 2010-11-30
WY FILED 2018-06-19
VI FILED 2020-11-20
MO FILED 2006-07-17
WA FILED 2006-05-16
TX FILED 1990-06-29
CT FILED 2017-06-13
VT FILED 2010-12-06
SD FILED 2010-11-30
HI FILED 2014-01-02
FL FILED 1988-01-11
NH FILED 2015-11-24
MT FILED 2008-07-01
ME
2018-03-09
FILED
AL
1991-03-14
FILED
AK
2021-07-15
FILED
AZ
2002-08-20
FILED
AR
1997-08-07
FILED
CA
2002-05-21
FILED
CO
2005-09-02
FILED
DE
2007-07-13
FILED
DC
2014-01-02
FILED
GA
1989-05-03
FILED
ID
2019-12-18
FILED
IL
1985-12-11
FILED
IN
2010-11-30
FILED
IA
2004-09-13
FILED
KS
2010-11-30
FILED
KY
2005-01-19
FILED
LA
2008-12-17
FILED
MD
2010-11-30
FILED
MA
2010-11-30
FILED
MI
2015-09-01
FILED
MN
2007-08-04
FILED
MS
2006-06-23
FILED
NE
2004-09-02
FILED
NV
2004-10-04
FILED
NJ
1996-03-01
FILED
NM
2004-12-06
FILED
NY
2005-07-13
FILED
NC
2001-10-24
FILED
ND
2020-07-24
FILED
OH
2005-05-05
FILED
OK
2002-09-19
FILED
OR
2015-07-31
FILED
PA
2014-01-02
FILED
RI
2010-11-30
FILED
SC
1998-12-16
FILED
TN
1998-04-30
FILED
UT
2005-01-31
FILED
VA
2004-12-08
FILED
WV
2017-07-24
FILED
WI
2010-11-30
FILED
WY
2018-06-19
FILED
VI
2020-11-20
FILED
MO
2006-07-17
FILED
WA
2006-05-16
FILED
TX
1990-06-29
FILED
CT
2017-06-13
FILED
VT
2010-12-06
FILED
SD
2010-11-30
FILED
HI
2014-01-02
FILED
FL
1988-01-11
FILED
NH
2015-11-24
FILED
MT
2008-07-01
FILED
Mailing Address

P.O. BOX 2628

COLUMBUS, GA 31902-2628

United States

Registration
Firm Type
Registered
Status
APPROVED
Registered
Sep 1, 1983
SEC #
801-19690
CRD #
14023
SEC Region
ARO
Umbrella
N

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Filed: 2026-01-28 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 64
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
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

Corporation

Fiscal Year End

DECEMBER

Organized Under Laws Of

GA, United States

5AEmployees
Total Employees: 280
5B(1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research) 184
5B(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer 229
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 184
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 163
5B(6) Approximately how many firms or other persons solicit advisory clients on your behalf 13
5CClients
5C(1) To approximately how many clients did you provide investment advisory services during your most recently completed fiscal year 100
5C(2) Approximately what percentage of your clients are non-United States persons 0
5DClient Types & Assets Under Management
Client Type # Clients Regulatory AUM
(a) Individuals (other than high net worth) 10,026 $2,665,938,456.00
(b) High net worth individuals 1,938 $4,955,358,972.00
(c) Banking or thrift institutions 0
(d) Investment companies 0
(e) Business development companies 0
(f) Pooled investment vehicles 0
(g) Pension and profit sharing plans 131 $99,012,171.00
(h) Charitable organizations 86 $173,907,192.00
(i) State or municipal government entities 0
(j) Other investment advisers 0
(k) Insurance companies 0
(l) Sovereign wealth funds 0
(m) Corporations or other businesses 230 $550,866,223.00
(n) Other 0
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 Yes
5E(6) Performance-based fees No
5E(7) Other No
5FRegulatory Assets Under Management
5F(1) Do you provide continuous and regular supervisory or management services to securities portfolios Yes
U.S. Dollar Amount Total Accounts
Discretionary $4,987,877,578.00 5,799
Non-Discretionary $3,457,205,436.00 6,612
Total 5F(2)(c) $8,445,083,014.00 12,411

AUM attributable to non-U.S. persons: $38,599,406.00

5GAdvisory Services Provided
5G(1) Financial planning services Yes
5G(2) Portfolio management for individuals and/or small businesses Yes
5G(3) Portfolio management for investment companies No
5G(4) Portfolio management for pooled investment vehicles (other than investment companies) No
5G(5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles and) Yes
5G(6) Pension consulting services No
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 Yes
5G(12) Other (specify) TAX RELATED SERVICES, ADMINISTRATIVE SERVICES
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) 1,500
5IWrap Fee Programs
5I(1) Sponsor the wrap fee program Yes
5I(2a)AUM as sponsor $5,888,695,171.00
5I(2b)AUM as portfolio manager
5I(2c)AUM as sponsor and portfolio manager
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 Yes
5LMarketing & Advertising
5L(1)(a) Do any of your advertisements include performance results No
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 No
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

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

6A(1) Broker-dealer (registered or unregistered) Yes
6A(2) Registered representative of a broker-dealer No
6A(3) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) No
6A(4) Futures commission merchant No
6A(5) Real estate broker, dealer, or agent No
6A(6) Insurance broker or agent 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 No
6A(11) Major security-based swap participant No
6A(12) Accountant or accounting firm No
6A(13) Lawyer or law firm No
6A(14) Other financial product salesperson Yes
6A(14) Other (specify) TAX RELATED SERVICES
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) No
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 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 No
7B Are you an adviser to any private fund No
8Participation or Interest in Client Transactions
8A(1) Buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions) Yes
8A(2) Buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients Yes
8A(3) Recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership) interest (other than those mentioned in Items 8.A(1) or (2)) No
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 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 No
8C(4) Commission rates to be paid to a broker or dealer for a client's securities transactions No
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 No
8G(1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar benefits") in connection with client securities transactions No
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 No
8H(1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals Yes
8H(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients No
8I Do you or any related person, directly or indirectly, receive compensation from any person for client referrals Yes
9Custody
9A(1)(a) Cash or bank accounts Yes
9A(1)(b) Securities Yes
9A(2a) Dollar amount in custody $8,445,083,014.00
9A(2b) Number of clients 12,411
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 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
9E Surprise examination date 2025-08
9F If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as qualified custodians for your clients in connection with advisory services you provide to clients 1
10Control Persons
10A Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies 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 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 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 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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