IF THE ANSWER TO ANY OF THE QUESTIONS IN ITEMS 6A – 6J AND 6M IS "YES," PROVIDE DETAILS OF ALL EVENTS OR PROCEEDINGS ON THE APPROPRIATE DISCLOSURE REPORTING PAGES (DRPs).
One event or proceeding may result in the requirement to answer "Yes" to more than one question below.
Refer to the Glossary of Terms for definitions or descriptions of italicized terms.
CRIMINAL ACTION DISCLOSURE
If the answer is "Yes" to any question below in Item 6A or 6B, complete a Criminal Action DRP.
Item 6A.
(1) Has the individual ever:
(a) been convicted of any felony, or pled guilty or nolo contendere ("no contest") to any charge of a felony in a domestic, foreign, or military court?
YES
NO
(b) been charged with any felony?
YES
NO
(2) Based upon activities that occurred while the individual exercised control over it, has an organization ever:
(a) been convicted of any felony or pled guilty or nolo contendere ("no contest") in a domestic or foreign court to any charge of a felony?
YES
NO
(b) been charged with any felony?
YES
NO
Item 6B.
(1) Has the individual ever:
(a) been convicted of any misdemeanor or pled guilty or nolo contendere ("no contest") in a domestic, foreign or military court to any charge of a misdemeanor involving: municipal advisory activities or a municipal advisor-related or investment-related business or any fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
YES
NO
(b) been charged with any misdemeanor of the kind described in 6B(1)(a)?
YES
NO
(2) Based upon activities that occurred while the individual exercised
control over it, has an organization ever:
(a) been convicted of any misdemeanor or pled guilty or nolo contendere ("no contest") in a domestic or foreign court to any charge of a misdemeanor of the kind specified in 6B(1)(a)?
YES
NO
(b) been charged with any misdemeanor of the kind specified in 6B(1)(a)?
YES
NO
REGULATORY ACTION DISCLOSURE
If the answer is "Yes" to any question below in Items 6C-6G(1), complete a Regulatory Action DRP.
Item 6C.
Has the SEC or the CFTC ever:
(1) found the individual to have made a false statement or omission?
YES
NO
(2) found the individual to have been involved in a violation of any SEC or CFTC regulation or statute?
YES
NO
(3) found the individual to have been a cause of a denial, suspension, revocation, or restriction of the authorization of a municipal advisor-related business or investment-related business to operate?
YES
NO
(4) entered an order against the individual in connection with municipal advisor-related or investment-related activity?
YES
NO
(5) imposed a civil money penalty on the individual, or ordered the individual to cease and desist from any activity?
YES
NO
(6) found the individual to have willfully violated any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB, or found the individal to have been unable to comply with any provision of such Acts, rules or regulations?
YES
NO
(7) found the individual to have willfully aided, abetted, counseled, commanded, induced, or procured the violation by any person of any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB?
YES
NO
(8) found the individual to have failed reasonably to supervise another person subject to his or her supervision, with a view to preventing the violation of any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB?
YES
NO
Item 6D.
(1) Has any other federal regulatory agency or any state regulatory agency or foreign financial regulatory authority ever:
(a) found the individual to have made a false statement or omission or to have been dishonest, unfair or unethical?
YES
NO
(b) found the individual to have been involved in a violation of municipal advisor-related or investment-related regulation(s) or statute(s)?
YES
NO
(c) found the individual to have been a cause of a denial, suspension, revocation, or restriction of the authorization of a municipal advisor-related or investment-related business to operate?
YES
NO
(d) entered an order against the individual in connection with a municipal advisor-related or investment-related activity?
YES
NO
(e) denied, suspended, or revoked the individual's registration or license or otherwise, by order, prevented the individual from associating with a municipal advisor-related or investment-related business or restricted his or her activities?
YES
NO
(2) Has the individual ever been subject to any final order of a state securities commission (or any agency or office performing like functions), a state authority that supervises or examines banks, savings associations, or credit unions, a state insurance commission (or any agency or office performing like functions), a federal banking agency, or the National Credit Union Administration, that:
(a) bars the individual from association with an entity regulated by such commission, authority, agency, or office, or from engaging in the business of securities, insurance, banking, savings association activities, or credit union activities; or
YES
NO
(b) is based on violations of any laws or regulations that prohibit fraudulent, manipulative, or deceptive conduct?
YES
NO
Item 6E.
Has any self-regulatory organization or commodities exchange ever:
(1) found the individual to have made a false statement or omission?
YES
NO
(2) found the individual 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)?
YES
NO
(3) found the individual to have been a cause of a denial, suspension, revocation, or restriction of the authorization of a municipal advisor-related or investment-related business to operate?
YES
NO
(4) disciplined the individual by expelling or suspending him or her from membership, barring or suspending the individual's association with its members, or restricting the individual's activities?
YES
NO
(5) found the individual to have willfully violated any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB, or found the individual to have been unable to comply with any provision of such Acts, rules or regulations?
YES
NO
(6) found the individual to have willfully aided, abetted, counseled, commanded, induced, or procured the violation by any person of any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB?
YES
NO
(7) found the individual to have failed reasonably to supervise another person subject to your supervision, with a view to preventing the violation of any provision of the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Advisers Act of 1940, the Investment Company Act of 1940, the Commodity Exchange Act, or any rule or regulation under any of such Acts, or any of the rules of the MSRB?
YES
NO
Item 6F.
Has the individual ever had an authorization to act as an attorney, accountant or federal contractor that was revoked or suspended?
YES
NO
Item 6G.
Has the individual been notified, in writing, that he or she is currently the subject of any:
(1) regulatory complaint or proceeding that could result in a "Yes" answer to any part of 6C, D or E?
YES
NO
INVESTIGATION DISCLOSURE
If the answer is "Yes" to Item 6G(2) below, complete an Investigation DRP.
(2) investigation that could result in a "Yes" answer to any part of 6A, B, C, D or E? (If "Yes," complete the Investigation Disclosure Reporting Page.)
YES
NO
CIVIL JUDICIAL ACTION DISCLOSURE
If the answer is "Yes" to any question below in Item 6H, complete a Civil Judicial Action DRP.
Item 6H.
(1) Has any domestic or foreign court ever:
(a) enjoined the individual in connection with any municipal advisor-related or investment-related activity?
YES
NO
(b) found that the individual was involved in a violation of any municipal advisor-related or investment-related statute(s) or regulation(s)?
YES
NO
(c) dismissed, pursuant to a settlement agreement, a municipal advisor-related or investment-related civil action brought against the individual by a domestic jurisdiction or foreign financial regulatory authority?
YES
NO
(2) Is the individual named in any currently pending civil proceeding that could result in a "Yes" answer to any part of 6H(1)?
YES
NO
CUSTOMER COMPLAINT/ARBITRATION/CIVIL LITIGATION DISCLOSURE
If the answer is "Yes" to any question below in Item 6I, complete a Customer Complaint/Arbitration/Civil Litigation DRP.
Item 6I.
(1) Has the individual ever been the subject of a
municipal advisor-related or
investment-related, customer-initiated (written or oral) complaint that alleged that he or she was
involved in fraud, false statements, omissions, theft, embezzlement, wrongful taking of property, bribery, forgery, counterfeiting, extortion, or dishonest, unfair or unethical practices, which:
(a) is still pending, or;
YES
NO
(b) was settled?
YES
NO
(2) Has the individual ever been the subject of a
municipal advisor-related or
investment-related, customer-initiated arbitration or civil litigation that alleged that he or she was
involved in fraud, false statements, omissions, theft, embezzlement, wrongful taking of property, bribery, forgery, counterfeiting, extortion, or dishonest, unfair or unethical practices, which:
(a) is still pending, or;
YES
NO
(b) resulted in an arbitration award or civil judgment against the individual, regardless of amount, or;
YES
NO
(c) was settled?
YES
NO
TERMINATION DISCLOSURE
If the answer is "Yes" to any question below in Item 6J, complete a Termination DRP.
Item 6J.
Has the individual ever voluntarily resigned, been discharged or permitted to resign after allegations were made that accused him or her of:
(1) violating municipal advisor-related or investment-related statutes, regulations, rules, or industry standards of conduct?
YES
NO
(2) fraud or the wrongful taking of property?
YES
NO
(3) failure to supervise in connection with municipal advisor-related or investment-related statutes, regulations, rules or industry standards of conduct?
YES
NO
FINANCIAL DISCLOSURE
Item 6K.
Within the past 10 years:
(1) has the individual made a compromise with creditors, filed a bankruptcy petition or been the subject of an involuntary bankruptcy petition?
YES
NO
(2) based upon events that occurred while the individual exercised control over it, has an organization made a compromise with creditors, filed a bankruptcy petition or been the subject of an involuntary bankruptcy petition?
YES
NO
(3) based upon events that occurred while the individual exercised control over it, has a broker or dealer been the subject of an involuntary bankruptcy petition, had a trustee appointed, or had a direct payment procedure initiated under the Securities Investor Protection Act?
YES
NO
Item 6L.
Has a bonding company ever denied, paid out on, or revoked a bond for the individual?
YES
NO
JUDGMENT/LIEN DISCLOSURE
If the answer is "Yes" to any question below in Item 6M, complete a Judgment/Lien DRP.
Item 6M.
Are there currently any unsatisfied judgments or liens against the individual?
YES
NO