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Form ADV Part 1A Item 11E(2) · Answer type: yn · Item 11 - Disclosure Information
Item 11E(2) asks whether any self-regulatory organization or commodities exchange has found the firm or an advisory affiliate to have been involved in a violation of its rules: other than a violation designated as a "minor rule violation" under a plan approved by the SEC.
Self-regulatory organizations include FINRA, NYSE, NASDAQ, MSRB, and other industry bodies that regulate securities professionals. Commodities exchanges include CME Group, ICE, and other organized futures and commodities markets with regulatory authority over participants.
The minor rule violation exclusion is significant. SROs can designate certain technical violations as "minor" under SEC-approved plans, exempting them from disclosure requirements. 11E(2) captures more serious violations that fall outside these minor violation categories.
Yes
The firm reports that SROs or commodities exchanges have found the firm or advisory affiliates involved in non-minor rule violations.
No
The firm reports No under 11E(2). This answer applies only to this question.
11E(2) - Found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?
This appears in Item 11E with specific exclusion for minor violations, focusing disclosure on more serious industry regulatory compliance failures.
What 11E(2) does not reveal is the specific rules violated, their severity or impact, which SROs made findings, when violations occurred, or what sanctions or remedial measures resulted. Violations can range from supervision failures to serious client harm.
Yes
Review detailed disclosure narratives to understand which rules were violated, which organizations made findings, when violations occurred, which affiliates were involved, and what sanctions or corrective actions resulted.
No
The firm reports No under 11E(2). Review the other Item 11 rows separately because each question has its own scope.