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Form ADV Part 1A Item 11B(1) · Answer type: yn · Item 11 - Disclosure Information
Item 11B(1) asks whether the adviser firm or any supervised person has been convicted of, or pled guilty or nolo contendere ("no contest"), to a misdemeanor involving investments or an investment-related business, or any fraud, false statements, omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or conspiracy to commit these offenses.
This question targets lesser criminal offenses (misdemeanors) with specific relevance to financial services. Unlike felonies, misdemeanors typically carry penalties of less than one year in jail, but the SEC considers certain misdemeanors particularly relevant to advisory fitness.
The investment-related component captures misdemeanor convictions involving securities, investment advice, financial planning, or other advisory business activities. The honesty-related component captures character crimes that raise integrity concerns regardless of their connection to finance: fraud, perjury, bribery, theft, and related offenses.
Yes
The firm reports that investment-related or honesty-related misdemeanor convictions or accepted pleas involving the firm or supervised persons. This requires detailed disclosure of case specifics and current status.
No
The firm reports No under 11B(1). This answer applies only to this question.
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?
This detailed question appears in Item 11B, which covers misdemeanor criminal history with specific relevance to advisory services.
What 11B(1) does not tell you is the specific facts underlying the conviction, the sentence imposed, or what remedial actions the firm took. A misdemeanor conviction could represent anything from a minor paperwork violation to a significant fraud scheme prosecuted as a lesser charge.
Yes
Review the complete disclosure narrative on Form ADV to understand which supervised persons were involved, what specific crimes occurred, when convictions happened, and whether affected individuals still work at the firm.
No
The firm reports No under 11B(1). Review the other Item 11 rows separately because each question has its own scope.