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Your Name _______________________________ CRD Number _______________

FORM ADV

Part 1A

Date _____________________________________ SEC 801-Number ____________

Page 13 of 16

Item 11

Disclosure Information

In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory

affiliates. We use this information to determine whether to grant your application for registration, to decide whether

to revoke your registration or to place limitations on your activities as an investment adviser, and to identify

potential problem areas to focus on during our on-site examinations. One event may result in “yes” answers to

more than one of the questions below.

Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical,

administrative, support or similar functions); (2) all of your officers, partners, or directors (or any person

performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you

are a “separately identifiable department or division” (SID) of a bank, see the Glossary of Terms to determine who

your advisory affiliates are.

If you are registered or registering with the SEC, you may limit your disclosure of any event listed in Item 11 to ten

years following the date of the event. If you are registered or registering with a state, you must respond to the

questions as posed; you may, therefore, limit your disclosure to ten years following the date of an event only in

responding to Items 11.A(1), 11.A(2), 11.B(1), 11.B(2), 11.D(4), and 11.H(1)(a). For purposes of calculating this

ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any

rights of appeal from preliminary orders, judgments, or decrees lapsed.

You must complete the appropriate Disclosure Reporting Page (“DRP”) for “yes” answers to the questions in this

Item 11.

For “yes” answers to the following questions, complete a Criminal Action DRP:

Yes

A. In the past ten years, have you or any advisory affiliate:

(1) been convicted of or pled guilty or nolo contendere (“no contest”) in a

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domestic, foreign, or military court to any felony?

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(2) been charged with any felony?

If you are registered or registering with the SEC, you may limit your response to Item 11.A(2) to charges

that are currently pending.

B. In the past ten years, have you or any advisory affiliate:

(1) been convicted of or pled guilty or nolo contendere (“no contest”) in a domestic,

foreign, or military court to a misdemeanor involving: investments or an

investment-related business, or any fraud, false statements, or omissions,

wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion,

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or a conspiracy to commit any of these offenses?

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(2) been charged with a misdemeanor listed in Item 11.B(1)?

If you are registered or registering with the SEC, you may limit your response to Item 11.B(2) to charges

that are currently pending.

Form Sec 1707 - Uniform Application For Investment Adviser Registration - Securities And Exchange Commission Page 13

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