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Form ADV Part 1A Item 11C(2) · Answer type: yn · Item 11 - Disclosure Information
Item 11C(2) asks whether the SEC or CFTC has found the firm or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes.
This question captures formal regulatory findings where federal securities or commodities regulators determined that the firm or affiliated persons violated specific laws, regulations, or rules governing investment advisory activities or related financial services.
SEC violations can include breaches of the Investment Advisers Act, Securities Act, Securities Exchange Act, or related regulations covering advisory conduct, fiduciary duties, disclosure requirements, recordkeeping, or client protection. CFTC violations involve commodities trading rules, disclosure requirements, or other regulations under that agency's jurisdiction.
Yes
The firm reports SEC or CFTC findings of regulatory or statutory violations involving the firm or advisory affiliates.
No
The firm reports No under 11C(2). This answer applies only to this question.
11C(2) - Found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
This checkbox appears in Item 11C alongside other SEC and CFTC regulatory findings categories.
What 11C(2) does not reveal is the specific regulations violated, their severity or materiality, when violations occurred, or what remedial measures followed. Violations can range from minor technical issues to serious fiduciary breaches.
Yes
Review detailed disclosure narratives to understand which regulations were violated, when findings occurred, which affiliates were involved, and what sanctions or remedial actions resulted.
No
The firm reports No under 11C(2). Review the other Item 11 rows separately because each question has its own scope.