11C(3) Cause of denied, suspended, revoked, or restricted authorization (SEC / CFTC)

Form ADV Part 1A Item 11C(3) · Answer type: yn · Item 11 - Disclosure Information

What this means

Item 11C(3) asks whether the SEC or CFTC has found the firm 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.

This question captures situations where federal regulators determined that the firm or affiliated persons contributed to or caused another investment-related business to lose its regulatory permission to operate. The "caused" standard means the firm or affiliate played a role in triggering the regulatory action, not merely that they worked there when it occurred.

Authorization to do business includes licenses, registrations, memberships, or other regulatory permissions required to conduct investment-related activities. This covers broker-dealer registrations, investment adviser registrations, individual representative licenses, or other credentials required for financial services.

Yes

The firm reports SEC or CFTC findings that the firm or an advisory affiliate caused an investment-related business to lose its authorization. This indicates regulatory determination that the firm or affiliate contributed to serious regulatory sanctions.

No

The firm reports No under 11C(3). This answer applies only to this question.

Official Form ADV question

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?

This appears in Item 11C covering SEC and CFTC regulatory findings against investment advisers and related persons.

Why it matters

What 11C(3) does not tell you is the specific conduct that caused authorization loss, the nature of the affected business, when findings occurred, or what remedial actions followed. The underlying conduct could range from technical violations to serious regulatory breaches.

How to read a firm's answer

Yes

Review detailed disclosures to understand what conduct caused the authorization action, which business was affected, the relationship to the current firm, and when findings occurred.

No

The firm reports No under 11C(3). Review the other Item 11 rows separately because each question has its own scope.

Related questions

• 11C(2) - SEC/CFTC regulation violations - direct regulatory violations by the firm
• 11C(4) - SEC/CFTC orders - regulatory enforcement orders
• 11C(5) - Civil money penalties - regulatory financial sanctions
• Item 11 - Disclosure Information - complete disclosure framework

Sources

• Form ADV Part 1A, Item 11C(3) (Disclosure Information)
• Firm Disclosures card and ADV form on Best Investors