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Form ADV Part 1A Item 11D(1) · Answer type: yn · Item 11 - Disclosure Information
Item 11D(1) asks whether any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority has ever found the firm or an advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical.
This question covers regulatory findings by authorities other than the SEC and CFTC (which are covered in Item 11C). "Other federal agencies" include banking regulators, insurance commissioners, or other federal bodies overseeing financial services. State agencies include securities regulators, insurance departments, or banking authorities in any state. Foreign authorities include financial regulators in other countries.
False statements include any materially incorrect information provided to regulators or in official contexts. Omissions mean failing to disclose material facts required by regulations or important for regulatory decision-making. Dishonest, unfair, or unethical conduct includes character violations beyond pure factual accuracy.
Yes
The firm reports that state, other federal, or foreign financial regulators have made findings of false statements, omissions, or unethical conduct involving the firm or advisory affiliates.
No
The firm reports No under 11D(1). This answer applies only to this question.
11D(1) - Ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
This appears in Item 11D covering regulatory findings by authorities other than SEC and CFTC.
What this question does not reveal is the specific nature of findings, their severity, when they occurred, or what remedial actions resulted. Findings can range from technical compliance issues to serious character violations.
Yes
Review detailed disclosures to understand which regulators made findings, what specific conduct was involved, when findings occurred, and which affiliates were affected. Focus on whether findings involved current personnel and client-facing activities.
No
The firm reports No under 11D(1). Review the other Item 11 rows separately because each question has its own scope.