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Form ADV Part 1A Item 11C(5) · Answer type: yn · Item 11 - Disclosure Information
Item 11C(5) asks whether the SEC or CFTC has imposed a civil money penalty on the firm or any advisory affiliate, or ordered them to cease and desist from any activity.
This question covers two sanctions. A civil money penalty requires payment. A cease-and-desist order directs the firm or affiliate to stop or not repeat specified conduct.
The checkbox applies to the firm and the advisory affiliates covered by the Form ADV question. It does not give the amount, order terms, date, conduct, or affected person.
Yes
The firm reports that the SEC or CFTC imposed a covered penalty or cease-and-desist order on the firm or an advisory affiliate.
No
The firm reports No under 11C(5). This answer applies only to the sanctions described by this question.
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?
This appears in Item 11C covering SEC and CFTC enforcement actions and regulatory sanctions against investment advisers and associated persons.
A Yes identifies a completed SEC or CFTC sanction within this question. The checkbox alone does not explain the underlying conduct or how the order affects the firm's current activities.
Read the event narrative before comparing firms. The useful facts are the regulator, date, respondent, findings, penalty amount or order terms, and current status.
Yes
Open the Disclosures card and match the narrative to 11C(5). Record the respondent, conduct, date, penalty amount, cease-and-desist terms, and whether the order remains relevant to services you are reviewing. Then check 11C(2) and 11C(4) for related findings or orders.
No
The firm reports No under 11C(5). Review the other Item 11 rows separately because they cover different findings, orders, proceedings, and sanctions.