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Form ADV Part 1A Item 11D(3) · Answer type: yn · Item 11 - Disclosure Information
Item 11D(3) 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 been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted.
This question covers regulatory findings by authorities other than SEC and CFTC where these regulators determined that the firm or affiliated persons contributed to or caused another investment-related business to lose its regulatory permission to operate.
Cause means the firm or affiliate played a material role in triggering the regulatory action against another business. This goes beyond coincidental association to establish that their conduct, violations, or failures contributed directly to the authorization loss.
Yes
The firm reports that state, other federal, or foreign financial regulators have found the firm or advisory affiliates caused investment-related businesses to lose authorization.
No
The firm reports No under 11D(3). This answer applies only to this question.
11D(3) - Ever 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 11D covering regulatory findings by authorities other than SEC and CFTC, parallel to 11C(3) for federal securities regulators.
What 11D(3) does not reveal is the specific conduct that caused authorization loss, the nature of affected business, which regulators made findings, when findings occurred, or what remedial actions followed. The underlying conduct could range from technical violations to serious regulatory breaches.
Yes
Review detailed disclosures to understand what conduct caused authorization actions, which businesses were affected, the relationship to current firm operations, which regulators made findings, and when findings occurred.
No
The firm reports No under 11D(3). Review the other Item 11 rows separately because each question has its own scope.