AUMdb

Manulife Investment Management Timberland And Agriculture Inc

SEC-registered Private Fund Manager · Mid-sized ($1B–$10B) CRD 109641 · SEC file 801-57981 · Boston, MA · www.manulifeim.com
☆ Save with Pro ADV data as of Mar 31, 2026
Regulatory AUM
$6.7B
Discretionary
$3.9B
Clients
20
Avg AUM / client
$337M
Accounts
27
Employees
660

AUM over time

$1.2B $9.5B
Dec 2011 Dec 2025

Annual snapshots from Form ADV filings · as of Mar 31, 2026

Who they serve

Client typeClientsAUM% of AUM
Pooled investment vehicles (non-investment companies) 13 $5.2B 77.0%
Pension and profit sharing plans Fewer than 5 clients $130M 1.92%
State or municipal government entities 7 $717M 10.6%
Insurance companies Fewer than 5 clients $371M 5.5%
Sovereign wealth funds and foreign official institutions Fewer than 5 clients $337M 4.99%

Private funds (4)

Reported in Form ADV Section 7.B.(1), filing of Nov 2024 · $1.9B combined gross assets

FundTypeDomicileGross assetsOwners
Hancock Timberland And Farmland Fund Lp Other Private Fund Delaware $1.4B 61
Hancock Timberland Xii Lp Other Private Fund Delaware $321M 15
Manulife Permanent Cropland Plus Fund Lp Other Private Fund Delaware $137M 5
Manulife Forest Climate Fund Lp master Other Private Fund Delaware $24.9M 13

People (9)

NameRole / titleCredentialsWith firm sinceOwnership
Lambert, Daniel, Christopher Vice President, Chief Compliance Officer Jul 2010 (16y) Less than 5%
Mundy, Patricia, Wall Senior Vice President, General Counsel Aug 2018 (8y) Less than 5%
Sarno, Thomas, Gerald Head Of Timberland, Chief Investment Officer May 2020 (6y) Less than 5%
Williams, Oliver, Spencer Head Of Agriculture, Chief Investment Officer May 2020 (6y) Less than 5%
Ghai, Vipon Director Jun 2021 (5y) Less than 5%
Peterson, Gerald, John Director Jun 2023 (3y) Less than 5%
Taylor Jones, Michelle, Marie Director Jun 2023 (3y) Less than 5%
Nataupsky, Jeffrey, Howard Vice President, Chief Financial Officer Dec 2023 (3y) Less than 5%
Valentine Andrews, Anne, Louise Chair Jun 2024 (2y) Less than 5%

Entity owners (Schedule A/B)

EntityTitle / statusSinceSch.Ownership
John Hancock Subsidiaries Llc Shareholder Dec 1994 A 75% or more
Manulife Financial Corporation Shareholder Sep 1999 B ≈ 13.35% – 100% via Manufacturers Life Insurance Company
John Hancock Financial Corporation Shareholder Dec 2009 B ≈ 31.64% – 100% via The Manufacturers Investment Corporation
Manufacturers Life Insurance Company Shareholder Dec 2003 B ≈ 17.8% – 100% via Manulife Holdings (Alberta) Limited
Manulife Holdings (Alberta) Limited Member Dec 2009 B ≈ 23.73% – 100% via John Hancock Financial Corporation
The Manufacturers Investment Corporation Shareholder Jan 2002 B ≈ 42.19% – 100% via John Hancock Life Insurance Company (U.S.A.)
John Hancock Life Insurance Company (U.S.A.) Member Dec 2009 B ≈ 56.25% – 100% via John Hancock Subsidiaries Llc

Undisclosed: 0% – 25% of the firm is not attributable from the filed Schedule A bands.

Estimated effective ownership (look-through of filed bands):

  • Manulife Financial Corporation: 75% – 100% of Manufacturers Life Insurance Company × 75% – 100% of Manulife Holdings (Alberta) Limited × 75% – 100% of John Hancock Financial Corporation × 75% – 100% of The Manufacturers Investment Corporation × 75% – 100% of John Hancock Life Insurance Company (U.S.A.) × 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 13.35% – 100% of the firm
  • John Hancock Financial Corporation: 75% – 100% of The Manufacturers Investment Corporation × 75% – 100% of John Hancock Life Insurance Company (U.S.A.) × 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 31.64% – 100% of the firm
  • Manufacturers Life Insurance Company: 75% – 100% of Manulife Holdings (Alberta) Limited × 75% – 100% of John Hancock Financial Corporation × 75% – 100% of The Manufacturers Investment Corporation × 75% – 100% of John Hancock Life Insurance Company (U.S.A.) × 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 17.8% – 100% of the firm
  • Manulife Holdings (Alberta) Limited: 75% – 100% of John Hancock Financial Corporation × 75% – 100% of The Manufacturers Investment Corporation × 75% – 100% of John Hancock Life Insurance Company (U.S.A.) × 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 23.73% – 100% of the firm
  • The Manufacturers Investment Corporation: 75% – 100% of John Hancock Life Insurance Company (U.S.A.) × 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 42.19% – 100% of the firm
  • John Hancock Life Insurance Company (U.S.A.): 75% – 100% of John Hancock Subsidiaries Llc × 75% – 100% direct ≈ 56.25% – 100% of the firm

Roster from the IAPD representatives feed; ownership and acquisition dates from Form ADV Schedule A/B. "Since" is the earliest filed registration or acquisition date.

Private funds (4, $1.9B gross assets)

FundTypeGross assetsMin. investmentOwners
Hancock Timberland And Farmland Fund Lp Other Private Fund $1.4B $5.0M 61
Hancock Timberland Xii Lp Other Private Fund $321M $5.0M 15
Manulife Permanent Cropland Plus Fund Lp Other Private Fund $137M $5.0M 5
Manulife Forest Climate Fund Lp Other Private Fund $24.9M $5.0M 13

From Form ADV Section 7.B private fund reporting.

Documents (1 archived)

FormPeriodSize
Form ADV (full filing) 03/31/2026 3.66 MB View · PDF · Source ↗

Archived copies of the firm's regulatory filings, versioned by content hash.

Disciplinary disclosures

Civil judicial as of Nov 12, 2024

Allegations: THE COMPLAINT INCLUDES A SINGLE COUNT AGAINST FARMLAND MANAGEMENT SERVICES, INC. FOR THE UNPERMITTED DISCHARGE OF DREDGED OR FILL MATERIAL INTO WATERS OF THE UNITED STATES UNDER SECTION 404 OF THE CWA. IT ALLEGES THAT, BEGINNING ON OR ABOUT NOVEMBER 15, 2012, FARMLAND MANAGEMENT SERVICES, INC. OPERATED EARTHMOVING EQUIPMENT ON THE PROPERTY, INCLUDING IN POTENTIALLY 100 OR MORE ACRES OF STREAMS AND WETLANDS THAT CONSTITUTE WATERS OF THE UNITED STATES. Status: Final Summary: FARMLAND MANAGEMENT SERVICES AND A CLIENT INVESTMENT VEHICLE, WITH THE APPROVAL OF THE CLIENT, REACHED SETTLEMENT WITH THE UNITED STATES IN THE FORM OF A CONSENT DECREE. AS PART OF THE PROCESS, THE COURT MUST REVIEW THE CONSENT DECREE AND MAY HOLD A HEARING IF IT REQUIRES QUESTIONS TO BE ANSWERED, AND THEN MAKE A FINDING THAT THE CONSENT DECREE IS CONSISTENT WITH THE PURPOSES AND PARAMETERS OF THE CLEAN WATER ACT. THE DISTRICT COURT SIGNED AND ENTERED THE CONSENT DECREE ON JUNE 10, 2019.

Regulatory · Item 11.D(4) as of Nov 12, 2024

Allegations: THE OREGON DIVISION OF FINANCIAL REGULATION HAS COMPLETED AN INVESTIGATION INTO JOHN HANCOCK'S HANDLING OF ADULT FOSTER HOME CLAIMS IN OREGON. THE DIVISION'S INVESTIGATION REVEALED THAT JOHN HANCOCK VIOLATED ORS 743.656 (1)(B)(D) ON SEVEN OCCASIONS WHEN IT INCORRECTLY DENIED COVERED SERVICES. THE CONSENT ORDER ADDRESSES THE SEVEN VIOLATIONS AND ALSO IMPOSES THE SUSPENDED CIVIL PENALTY FROM PRIOR ADMINISTRATIVE ACTION INS-16-0262 Status: Final Sanction Detail: THE OREGON DIVISION OF FINANCIAL REGULATION HAS COMPLETED AN INVESTIGATION INTO JOHN HANCOCK'S HANDLING OF ADULT FOSTER HOME CLAIMS IN OREGON. THE DIVISION'S INVESTIGATION REVEALED THAT JOHN HANCOCK VIOLATED ORS 743.656 (1)(B)(D) ON SEVEN OCCASIONS WHEN IT INCORRECTLY DENIED COVERED SERVICES. THE CONSENT ORDER ADDRESSES THE SEVEN VIOLATIONS AND ALSO IMPOSES THE SUSPENDED CIVIL PENALTY FROM PRIOR ADMINISTRATIVE ACTION INS-16-0262. $49000 PENALTY WAS PAID JANUARY 18, 2018. Summary: THE OREGON DIVISION OF FINANCIAL REGULATION HAS COMPLETED AN INVESTIGATION INTO JOHN HANCOCK'S HANDLING OF ADULT FOSTER HOME CLAIMS IN OREGON. THE DIVISION'S INVESTIGATION REVEALED THAT JOHN HANCOCK VIOLATED ORS 743.656 (1)(B)(D) ON SEVEN OCCASIONS WHEN IT INCORRECTLY DENIED COVERED SERVICES. THE CONSENT ORDER ADDRESSES THE SEVEN VIOLATIONS AND ALSO IMPOSES THE SUSPENDED CIVIL PENALTY FROM PRIOR ADMINISTRATIVE ACTION INS-16-0262. PENALTY OF $14000 AND CIVIL PENALTY OF $35000 FOR NON-COMPLIANCE.

Regulatory · Item 11.D(4) as of Nov 12, 2024

Allegations: PURSUANT TO A MARKET CONDUCT EXAMINATION, THE STATE OF CONNECTICUT INSURANCE DEPARTMENT ALLEGED THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) FAILED TO FOLLOW ESTABLISHED PRACTICES AND PROCEDURES TO ENSURE COMPLIANCE WITH STATUTORY REQUIREMENTS RELATED TO PRODUCER APPOINTMENTS. Status: Final Sanction Detail: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUTES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000. Summary: ON MAY 24, 2022, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) CONSENTED TO THE TERMS OF AN ORDER ISSUED BY THE STATE OF CONNECTICUT INSURANCE DEPARTMENT RELATED TO A MARKET CONDUCT EXAMINATION AGREEING TO UNDERTAKE A REVIEW OF ITS PRACTICES AND PROCEDURES TO ENHANCE COMPLIANCE WITH CONNECTICUT STATUTES RELATED TO PRODUCER APPOINTMENTS AND PAY A FINE IN THE AMOUNT OF $68,000.

Regulatory · Item 11.D(2) as of Nov 12, 2024

Allegations: ON APRIL 22, 2014, THE ALBERTA SUPERINTENDENT OF INSURANCE ISSUED A FINE OF $5000.00 AFTER REACHING A DETERMINATION THAT MANULIFE CONTRAVENED SECTIONS 452(5) (INSURANCE AGENT'S CERTIFICATE) AND 499(1) (DEALING WITH UNAUTHORIZED INSURANCE AGENTS) OF THE ALBERTA INSURANCE ACT BY ALLOWING AN ADVISOR, CONTRACTED THROUGH IG INSURANCE SERVICES INC., TO ACT AS AN INSURANCE AGENT AND PAYING COMMISSIONS FOR A PERIOD BETWEEN FEBRUARY 16, 2009 AND SEPTEMBER 12, 2011 WHEN HE WAS NOT AUTHORIZED TO CONDUCT INSURANCE BUSINESS UNDER THE ACT (LICENSE LAPSED). Status: Final Sanction Detail: PENALTY OF $$5000.00 (CAD) AFTER REACHING A DETERMINATION THAT MLI CONTRAVENED SECTIONS 452(5) (INSURANCE AGENT'S CERTIFICATE) AND 499(1) (DEALING WITH UNAUTHORIZED INSURANCE AGENTS) OF THE ALBERTA INSURANCE ACT Summary: A RESPONSE WAS SENT TO THE SUPERINTENDENT OF INSURANCE ON JUNE 23, 2014 EXPLAINING THE VALIDATION PROCEDURES PUT IN PLACE TO AVOID FUTURE VIOLATIONS INCLUDING: (1) WORKING WITH OUR MANAGING GENERAL AGENCIES (MGA) AND NATIONAL ACCOUNT CHANNELS ("DISTRIBUTORS"), WHO ARE LICENSED ENTITIES HOLDING DISTRIBUTION AGREEMENTS WITH MLI TO CONFIRM THEIR ADHERENCE TO THE AGENT SCREENING AND ONGOING MONITORING DUTIES WHICH THEY ARE CONTRACTUALLY OBLIGATED TO CARRY OUT ON OUR BEHALF, (2) CONTINUING TO COMPLETE LICENSE REVIEWS FOLLOWING THE RENEWAL PERIOD IN ALBERTA USING THE SPREADSHEETS ON THE ALBERTA INSURANCE COUNCIL WEBSITE AND (3) CONTINUING TO INCLUDE THE REQUIREMENT FOR AGENTS TO CERTIFY THEY ARE LICENSED AND IN GOOD STANDING ON ALL INSURANCE APPLICATION FORMS.

Regulatory · Item 11.D(2) as of Nov 12, 2024

Allegations: A MARKET CONDUCT EXAM FOUND THAT JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) VIOLATED REQUIREMENTS RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES FROM JANUARY 1, 2021, THROUGH DECEMBER 31, 2022. Status: Final Sanction Detail: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE PROVIDED THE COMPANY WITH A CONSENT AGREEMENT, WHERE THE COMPANY AGREED TO ADDRESS THE FINDINGS BY IMPLEMENTING CORRECTIVE ACTION PLANS WITHIN 30 DAYS AND PAY AN ADMINISTRATIVE PENALTY OF $53,000. THE COMPANY PAID THE PENALTY ON MAY 10TH, 2024. Summary: THE STATE OF DELAWARE DEPARTMENT OF INSURANCE ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) AND ISSUED A FINE FOR $53,000 FOR VIOLATING PRACTICES RELATING TO INDIVIDUAL LIFE INSURANCE BUSINESS PRACTICES. THE EXAM RESULTED IN 78 EXCEPTIONS WITHIN THE CATEGORIES OF: PRODUCER TERMINATIONS, DELIVERY OF ILLUSTRATIONS, PRODUCER APPOINTMENTS, PRODUCER LICENSING AND PRODUCER KNOWLEDGE OR REPLACEMENTS.

Regulatory · Item 11.D(2) as of Nov 12, 2024

Allegations: A MARKET CONDUCT REPORT DATED JANUARY 12, 206 STATED THAT A MARKET CONDUCT EXAMINATION REVEALED CONCERNS WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) PROCEDURES AND PRACTICES IN UNDERWRITING AND CLAIMS. Status: Final Sanction Detail: NONE OF THE SANCTIONS IN 12.A. APPLY. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) WAS DIRECTED TO TAKE IMMEDIATE CORRECTIVE ACTION TO DEMONSTRATE ITS ABILITY AND INTENTION TO CONDUCT BUSINESS IN NORTH CAROLINA ACCORDING TO INSURANCE LAWS AND REGULATIONS. Summary: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) WAS DIRECTED TO TAKE IMMEDIATE CORRECTIVE ACTION TO DEMONSTRATE ITS ABILITY AND INTENTION TO CONDUCT BUSINESS IN NORTH CAROLINA ACCORDING TO INSURANCE LAWS AND REGULATIONS.

Regulatory · Item 11.D(2) as of Nov 12, 2024

Allegations: A MARKET CONDUCT EXAMINATION FOUND JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) VIOLATED REQUIREMENTS RELATING TO THE REGULATIONS OF LONG-TERM CARE INSURANCE. Status: Final Sanction Detail: THE PENNSYLVANIA INSURANCE DEPARTMENT ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) AND ISSUED A FINE OF $50,000 FOR VIOLATING REQUIREMENTS RELATING TO THE REGULATIONS OF LONG-TERM CARE INSURANCE. THE FINE WAS PAID ON AUGUST 30, 2016 Summary: THE PENNSYLVANIA INSURANCE DEPARTMENT ENTERED INTO A CONSENT ORDER WITH JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) AND ISSUED A FINE OF $50,000 FOR VIOLATING REQUIREMENTS RELATING TO THE REGULATIONS OF LONG-TERM CARE INSURANCE. THE FINE WAS PAID ON AUGUST 30, 2016

Regulatory · Item 11.D(2) as of Nov 12, 2024

Allegations: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) FAILED TO ELECTRONICALLY FILE ITS REPLACEMENT AND LAPSE REPORT, ITS CLAIMS DENIAL REPORT, ITS RECESSION REPORT, AND ITS SUITABILITY REPORT ON OR BEFORE JUNE 30, OF EACH YEAR, AS REQUIRED UNDER UTAH ADMINISTRATIVE CODE RULE R590-148-25. Status: Final Sanction Detail: THE FINE WAS PAID BY THE DUE DATE OF NOVEMBER 18, 2016 Summary: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) FAILED TO ELECTRONICALLY FILE ITS REPLACEMENT AND LAPSE REPORT, ITS CLAIMS DENIAL REPORT, ITS RECESSION REPORT, AND ITS SUITABILITY REPORT ON OR BEFORE JUNE 30, OF EACH YEAR, AS REQUIRED UNDER UTAH ADMINISTRATIVE CODE RULE R590-148-25. THE UTAH INSURANCE DEPARTMENT ORDERED JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) TO PAY A $750 MONETARY PENALTY.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 12, 2024

Allegations: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. Status: Final Sanction Detail: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) SHALL PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON JANUARY 8, 2020 Summary: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) WAS ORDERED TO PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON JANUARY 8, 2020.

Regulatory · Item 11.D(2), 11.D(4) as of Nov 12, 2024

Allegations: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING THE DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. Status: Final Sanction Detail: JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A) SHALL PAY AN ADMINISTRATIVE PENALTY IN THE AMOUNT OF $800,000 TO THE VERMONT DEPARTMENT OF FINANCIAL REGULATION WITHIN 30 DAYS OF THE FULL EXECUTION AND DELIVERY OF THE STIPULATION AND CONSENT ORDER. THE $800,000 FINE WAS PAID ON JANUARY 8, 2020. Summary: STARTING IN JANUARY 2013, JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.) MISINTERPRETED THE STATE OF VERMONT'S STATUTE REGARDING HOW DEATH CLAIM INTEREST WAS TO BE CALCULATED, AND OVERLOOKED A PREVIOUS CONSENT ORDER WITH THE VERMONT DEPARTMENT OF FINANCIAL REGULATION COVERING THE DEATH CLAIM INTEREST. UPON LEARNING OF THE ERRORS, THE COMPANY PROMPTLY PAID THE INTEREST THAT WAS DUE TO THESE BENEFICIARIES. THE $800,000 FINE WAS PAID ON JANUARY 8, 2020.

Disclosure text reproduced verbatim from the firm's own Form ADV filings.

How they charge

  • Percentage of assets under management
  • Performance-based fees
  • Other fees
  • UP FRONT FEES

Services

  • Portfolio management for pooled investment vehicles
  • Portfolio management for businesses/institutional clients
  • Other services

Custody

Reported custodians

Amounts as reported in ADV Item 5.K.(3) (custodians holding 10%+ of SMA assets).

Firm reports having custody of client funds or securities (Item 9.A).

Source

All data on this page comes from this firm's Form ADV filings, reproduced without modification. Latest filing: Mar 31, 2026.

View current Form ADV (SEC/IAPD) ↗