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11D(4) Order in past ten years (other regulators)

Form ADV Part 1A field explainer

Form ADV Part 1A Item 11D(4) · Answer type: yn · Item 11 - Disclosure Information

What this means

Item 11D(4) asks whether any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority has, in the past ten years, entered an order against the firm or any advisory affiliate in connection with an investment-related activity.

This question captures formal regulatory orders issued by authorities other than SEC and CFTC within the last decade. Unlike some Item 11 questions with unlimited time frames, 11D(4) focuses on relatively recent regulatory enforcement actions that may be more relevant to current operations.

Orders include administrative orders, enforcement orders, cease-and-desist orders, suspension orders, consent orders, or other formal regulatory directives. These are official documents with legal force that typically address specific violations, impose restrictions, or establish regulatory findings.

Yes

The firm reports that state, other federal, or foreign regulators have entered orders against the firm or advisory affiliates in connection with investment-related activities within the past ten years.

No

The firm reports No under 11D(4). This answer applies only to this question.

Official Form ADV question

11D(4) - In the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?

This appears in Item 11D with a specific ten-year limitation, distinguishing it from other Item 11 questions with unlimited time frames.

Why it matters

What 11D(4) does not reveal is the specific nature of orders, underlying violations, when within the ten-year period they occurred, which specific regulators issued them, or what compliance changes resulted. Orders can range from minor technical directives to serious enforcement actions.

How to read a firm's answer

Yes

Review detailed disclosure narratives to understand what orders were issued, their underlying violations, when they occurred within the ten-year window, which regulators issued them, and what compliance requirements resulted.

No

The firm reports No under 11D(4). Review the other Item 11 rows separately because each question has its own scope.

Related questions

Sources

  • Form ADV Part 1A, Item 11D(4) (Disclosure Information)
  • Firm Disclosures card and ADV form on Best Investors