Form ADV (full filing)
as of Mar 31, 2026
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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: M HOLDINGS SECURITIES, INC. CRD Number: 43285
Annual Amendment - All Sections Rev. 10/2021
3/31/2026 5:35:17 PM
WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal
prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the information in
Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.
A. Your full legal name (if you are a sole proprietor, your last, first, and middle names):
M HOLDINGS SECURITIES, INC.
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
M HOLDINGS SECURITIES, INC.
List on Section 1.B. of Schedule D any additional names under which you conduct your advisory business.
(2) If you are using this Form ADV to register more than one investment adviser under an umbrella registration, check this box
If you check this box, complete a Schedule R for each relying adviser.
C. If this filing is reporting a change in your legal name (Item 1.A.) or primary business name (Item 1.B.(1)), enter the new name and specify whether the name
change is of
your legal name or your primary business name:
D. (1) If you are registered with the SEC as an investment adviser, your SEC file number: 801-57304
(2) If you report to the SEC as an exempt reporting adviser, your SEC file number:
(3) If you have one or more Central Index Key numbers assigned by the SEC ("CIK Numbers"), all of your CIK numbers:
CIK Number
1569638
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 43285
If your firm does not have a CRD number, skip this Item 1.E. Do not provide the CRD number of one of your officers, employees, or affiliates.
(2) If you have additional CRD Numbers, your additional CRD numbers:
No Information Filed
F. Principal Office and Place of Business
(1) Address (do not use a P.O. Box):
Number and Street 1: Number and Street 2:
1125 N.W. COUCH STREET SUITE 900
City: State: Country: ZIP+4/Postal Code:
PORTLAND Oregon United States 97209
If this address is a private residence, check this box:
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are
applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are
applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to
the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal
year.
(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:
Normal business hours at this location:
8:00AM-5:00PM PST
(3) Telephone number at this location:
800-656-6960
(4) Facsimile number at this location, if any:
503-414-7474
(5) What is the total number of offices, other than your principal office and place of business, at which you conduct investment advisory business as of the end of
your most recently completed fiscal year?
105
G. Mailing address, if different from your principal office and place of business address:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Yes No
I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and
LinkedIn)?
If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a
website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all of
the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media
platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts on
publicly available social media platforms.
J. Chief Compliance Officer
(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information for
your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.
Name: Other titles, if any:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if Chief Compliance Officer has one:
(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the
Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer Identification
Number (if any):
Name:
IRS Employer Identification Number:
K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about
this Form ADV, you may provide that information here.
Name: Titles:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if contact person has one:
Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere
other than your principal office and place of business?
If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority?
Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory
authority. If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?
Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
If yes, what is the approximate amount of your assets:
$1 billion to less than $10 billion
$10 billion to less than $50 billion
$50 billion or more
For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the total
assets shown on the balance sheet for your most recent fiscal year end.
P. Provide your Legal Entity Identifier if you have one:
A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.
SECTION 1.B. Other Business Names
No Information Filed
SECTION 1.F. Other Offices
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
325 N. WILLIAMSON BLVD SUITE 120
City: State: Country: ZIP+4/Postal Code:
DAYTONA BEACH Florida United States 32114
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
386-255-0519 386-252-4084
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142528
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
6756 EXECUTIVE OAK LANE
City: State: Country: ZIP+4/Postal Code:
CHATTANOOGA Tennessee United States 37421
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
423-756-3828 423-265-0735
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
277395
How many employees perform investment advisory functions from this office location?
8
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1 NORTHFIELD PLAZA, SUITE 430
City: State: Country: ZIP+4/Postal Code:
NORTHFIELD Illinois United States 60093
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
847-441-4200
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142461
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
244 NORTH ROSE STREET
City: State: Country: ZIP+4/Postal Code:
KALAMAZOO Michigan United States 49007
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
269-552-3200 269-343-3533
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142482
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
100 SMITH RANCH RD. SUITE 340
City: State: Country: ZIP+4/Postal Code:
SAN RAFAEL California United States 94903
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
2549139911
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142455
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
67 EAST PARK PLACE SUITE 750
City: State: Country: ZIP+4/Postal Code:
MORRISTOWN New Jersey United States 07960
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
973-434-8700 973-434-8171
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142533
How many employees perform investment advisory functions from this office location?
17
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
109 PHEASANT RUN
City: State: Country: ZIP+4/Postal Code:
NEWTOWN Pennsylvania United States 18940
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
215-968-4741 215-504-6343
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
486472
How many employees perform investment advisory functions from this office location?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
2555 TOWNSGATE RD. SUITE 105
City: State: Country: ZIP+4/Postal Code:
WESTLAKE VILLAGE California United States 91361
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
805-604-2728
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
632516
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
ONE WOODWARD AVE
City: State: Country: ZIP+4/Postal Code:
DETROIT Michigan United States 48226
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
313-394-1700
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
547831
How many employees perform investment advisory functions from this office location?
6
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
200 CONNELL PARK SUITE 1000
City: State: Country: ZIP+4/Postal Code:
BERKELEY HEIGHTS New Jersey United States 07922
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
844-451-8326
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
564048
How many employees perform investment advisory functions from this office location?
1
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1100 KENILWORTH AVE 110
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28204
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
704-333-0508
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
374243
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
2699 HOWELL ST. SUITE 1100
City: State: Country: ZIP+4/Postal Code:
DALLAS Texas United States 75204
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
800-656-6960 503-414-7474
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
823581
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1802 HAMILTON STREET
City: State: Country: ZIP+4/Postal Code:
ALLENTOWN Pennsylvania United States 18104
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
6104371375 6104374575
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
461248
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
7979 EAST TUFTS SUITE 1550
City: State: Country: ZIP+4/Postal Code:
DENVER Colorado United States 80237
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
303-832-6100 303-832-7100
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142470
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
5550 W EXECUTIVE DRIVE 500
City: State: Country: ZIP+4/Postal Code:
TAMPA Florida United States 33609
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
813-273-9416 813-229-8874
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142453
How many employees perform investment advisory functions from this office location?
5
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1421 EMERSON AVE
City: State: Country: ZIP+4/Postal Code:
OXNARD California United States 93033
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
8056600347
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
686390
How many employees perform investment advisory functions from this office location?
1
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
600 CORPORATE POINTE SUITE 600
City: State: Country: ZIP+4/Postal Code:
CULVER CITY California United States 90230
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
4242537400
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
482947
How many employees perform investment advisory functions from this office location?
1
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
20 BUTTE DES MORTS
City: State: Country: ZIP+4/Postal Code:
APPLETON Wisconsin United States 54914
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
5166836100
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
747495
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1325 4TH AVENUE SUITE 2100
City: State: Country: ZIP+4/Postal Code:
SEATTLE Washington United States 98101
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
2063432323
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142497
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
8100 E. UNION AVE. 1605
City: State: Country: ZIP+4/Postal Code:
DENVER Colorado United States 80237
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
9132693219
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
698685
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
9700 WESTLAND DR. SUITE 103
City: State: Country: ZIP+4/Postal Code:
KNOXVILLE Tennessee United States 37922
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
8656909590
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
502084
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
740 WAUKEGA N. ROAD SUITE 310
City: State: Country: ZIP+4/Postal Code:
DEERFIELD Illinois United States 60015
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
8472722500
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
401117
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
55 HARRISTOWN ROAD SUITE 102
City: State: Country: ZIP+4/Postal Code:
GLEN ROCK New Jersey United States 07452
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
2012126909
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
533665
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
FOUR PPG PLACE SUITE 600
City: State: Country: ZIP+4/Postal Code:
PITTSBURG Pennsylvania United States 15222
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
4124971759
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142430
How many employees perform investment advisory functions from this office location?
1
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You must
complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are an
exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
361 S. BASSWOOD RD
City: State: Country: ZIP+4/Postal Code:
LAKE FOREST Illinois United States 60045
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
3123160010
If this office location is also required to be registered with FINRA or a state securities authority as a branch office location for a broker-dealer or investment adviser on
the Uniform Branch Office Registration Form (Form BR), please provide the CRD Branch Number here:
142455
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
SECTION 1.I. Website Addresses
List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not limited
to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available social media
platform.
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://MFIN.COM/M-SECURITIES
Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/m-financial-group/
Address of Website/Account on Publicly Available Social Media Platform: https://www.glassdoor.com/Overview/Working-at-M-Financial-Group-EI_IE17413.11,28.htm
SECTION 1.L. Location of Books and Records
Complete the following information for each location at which you keep your books and records, other than your principal office and place of business. You must
complete a separate Schedule D, Section 1.L. for each location.
Name of entity where books and records are kept:
MCINNES GROUP
Number and Street 1: Number and Street 2:
3500 W 75TH ST STE 200
City: State: Country: ZIP+4/Postal Code:
PRAIRIE VILLAGE Kansas United States 66208
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
913-831-0999 913-204-0514
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
EVERGREEN CONSULTING
Number and Street 1: Number and Street 2:
40 W. 5TH ST.
City: State: Country: ZIP+4/Postal Code:
COVINGTON Kentucky United States 41011
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
513-257-7810 513-784-9170
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
CORNERSTONE FINANCIAL CONSULTANTS
Number and Street 1: Number and Street 2:
1802 HAMILTON STREET
City: State: Country: ZIP+4/Postal Code:
ALLENTOWN Pennsylvania United States 18104
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
6104371375 6104374575
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS/NOTES.
Name of entity where books and records are kept:
HEIRMARK
Number and Street 1: Number and Street 2:
7005 S EDGERTON RD
City: State: Country: ZIP+4/Postal Code:
CLEVELAND Ohio United States 44141
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
330-665-2376 330-670-1081
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
GREENBERG, WEXLER & EIG
Number and Street 1: Number and Street 2:
7315 WISCONSIN AVENUE STE 250
City: State: Country: ZIP+4/Postal Code:
BETHESDA Maryland United States 20814
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
301-656-0660 301-656-8656
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
JONES LOWRY
Number and Street 1: Number and Street 2:
470 COLUMBIA DR STE E-100
City: State: Country: ZIP+4/Postal Code:
WEST PALM BEACH Florida United States 33409
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
561-712-9799 561-712-9899
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
DOCUPACE
Number and Street 1: Number and Street 2:
400 CORPORATE POINTE SUITE 300
City: State: Country: ZIP+4/Postal Code:
CULVER CITY California United States 90230
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
3104457722
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
ELECTRONIC VENDOR FOR PAPERWORK PROCESSING
Name of entity where books and records are kept:
LRI LLC BDA MARINER FINANCIAL GROUP
Number and Street 1: Number and Street 2:
223 EASTERN BLVD
City: State: Country: ZIP+4/Postal Code:
GLASTONBURY Connecticut United States 06003
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
860-657-1037
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES, RECOMMENDATIONS
Name of entity where books and records are kept:
CAPITAL STRATEGIES GROUP, INC
Number and Street 1: Number and Street 2:
740 WAUGKEGAN RD STE 310
City: State: Country: ZIP+4/Postal Code:
DEERFIELD Illinois United States 60015
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
847-272-2500 847-272-2205
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
MEZRAH FINANCIAL GROUP
Number and Street 1: Number and Street 2:
5350 WEST KENNEDY BLVD. SUITE 1
City: State: Country: ZIP+4/Postal Code:
TAMPA Florida United States 33609
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
813-282-3100 813-289-1577
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
WINGED KEEL GROUP, INC
Number and Street 1: Number and Street 2:
2000 RIVEREDGE PARKWAY STE 700
City: State: Country: ZIP+4/Postal Code:
ATLANTA Georgia United States 30328
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
770-956-1800 770-956-8516
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS,NOTES
Name of entity where books and records are kept:
HERITAGE STRATEGIES
Number and Street 1: Number and Street 2:
135 CROSSWAYS PARK DR STE 402
City: State: Country: ZIP+4/Postal Code:
WOODBURY New York United States 11797
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
631-423-0505 631-423-9656
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
DSG FAMILY LEGACY INSURANCE SOLUTIONS
Number and Street 1: Number and Street 2:
1340 VALLEY VISTA DRIVE
City: State: Country: ZIP+4/Postal Code:
DIAMOND BAR California United States 91765
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
626-854-8738 626-854-8737
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
DOERSCHLER & ASSOC. WEALTH MGMT LLC
Number and Street 1: Number and Street 2:
54870 N MAIN STREET
City: State: Country: ZIP+4/Postal Code:
MATTAWAN Michigan United States 49071
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
269-744-4180
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CLIENT NOTES, RECOMMENDATIONS
Name of entity where books and records are kept:
FAMILY CAPITAL ADVISORS
Number and Street 1: Number and Street 2:
200 MAYFAIR ROAD
City: State: Country: ZIP+4/Postal Code:
NASHVILLE Tennessee United States 37205
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
615-385-7885 866-408-9712
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
JKJ FINANCIAL SERVICES
Number and Street 1: Number and Street 2:
109 PHEASANT RUN
City: State: Country: ZIP+4/Postal Code:
NEWTOWN Pennsylvania United States 18940
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
215-968-4741 215-504-6343
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
EXECUTIVE COMPENSATION GROUP
Number and Street 1: Number and Street 2:
325 N. WILLIAMSON BLVD STE 120
City: State: Country: ZIP+4/Postal Code:
DAYTONA BEACH Florida United States 32114
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
386-255-0519 386-252-4084
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
GATEWAY FINANCIAL GROUP
Number and Street 1: Number and Street 2:
FOUR PPG PLACE SUITE 600
City: State: Country: ZIP+4/Postal Code:
PITTSBURGH Pennsylvania United States 15222
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
412-497-1750
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES, RECOMMENDATIONS
Name of entity where books and records are kept:
BARRY, EVANS, JOSEPHS & SNIPES
Number and Street 1: Number and Street 2:
1100 KENILWORTH AVE, STE 110 STE 110
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28204
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
704-333-0508
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
MERIDIAN FINANCIAL GROUP
Number and Street 1: Number and Street 2:
13710 BEN C PRATT SIX MILE CYPRESS PARKWAY STE 3
City: State: Country: ZIP+4/Postal Code:
FORT MYERS Florida United States 33912
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
239-690-9820
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
EMONEY ADVISOR, LLC
Number and Street 1: Number and Street 2:
FOUR RADNOR COPRORATE CENTER 100 MATSONFORD ROAD #300
City: State: Country: ZIP+4/Postal Code:
RADNOR Pennsylvania United States 19087
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8883628482
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
VENDOR PROVIDING DATA AGGREGATION AND CONSOLIDATED REPORTS RELATED TO CLIENT HOLDINGS.
Name of entity where books and records are kept:
UNITED FINANCIAL CONSULTANTS
Number and Street 1: Number and Street 2:
4770 BISCAYNE BLVD 980
City: State: Country: ZIP+4/Postal Code:
MIAMI Florida United States 33137
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
305-377-8999
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
EB INC
Number and Street 1: Number and Street 2:
2000 CHAPEL VIEW BLVD SUITE 240
City: State: Country: ZIP+4/Postal Code:
CRANSTON Rhode Island United States 02920
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
401-884-7800 401-884-0290
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
LRI LLC DBA LINDBERG AND RIPPLE
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
919-904-7137
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
MCM
Number and Street 1: Number and Street 2:
1325 4TH AVE STE 2100
City: State: Country: ZIP+4/Postal Code:
SEATTLE Washington United States 98101
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
206-3436-2323 206-343-4199
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
TPG CONSULTING
Number and Street 1: Number and Street 2:
191 SUN VALLEY ROAD SUITE 106
City: State: Country: ZIP+4/Postal Code:
KETCHUM Idaho United States 83340
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Telephone Number: Facsimile number, if any:
212-573-5550 646-786-3675
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
FAMILY WEALTH COUNSELING
Number and Street 1: Number and Street 2:
2377 CRENSHAW BLVD
City: State: Country: ZIP+4/Postal Code:
TORRENCE California United States 90501
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Telephone Number: Facsimile number, if any:
310-626-0010
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NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
MADISON & MAIN ADVISORS LLC
Number and Street 1: Number and Street 2:
266 MAIN STREET
City: State: Country: ZIP+4/Postal Code:
MADISON New Jersey United States 07940
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Telephone Number: Facsimile number, if any:
908-653-7295
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NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
CARLSON HAMMOND
Number and Street 1: Number and Street 2:
755 BAYWOOD DR 2ND FLOOR
City: State: Country: ZIP+4/Postal Code:
PETALUMA California United States 94954
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Telephone Number: Facsimile number, if any:
415-256-8960 415-256-8965
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
TCS INSURANCE AGENCY, INC.
Number and Street 1: Number and Street 2:
1701 AUSTIN AVE STE B
City: State: Country: ZIP+4/Postal Code:
WACO Texas United States 78703
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Telephone Number: Facsimile number, if any:
254-913-9911
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
JAMIESON FINANCIAL SERVICES, LLC
Number and Street 1: Number and Street 2:
1 NORTHFIELD PLAZA SUITE 430
City: State: Country: ZIP+4/Postal Code:
NORTHFIELD Illinois United States 60093
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Telephone Number: Facsimile number, if any:
847-441-4200 847-441-4350
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CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
VIA FORTE
Number and Street 1: Number and Street 2:
1700 WEST 82ND STREET 180
City: State: Country: ZIP+4/Postal Code:
BLOOMINGTON Minnesota United States 55431
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Telephone Number: Facsimile number, if any:
952-314-7300
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
LINDBERG & RIPPLE
Number and Street 1: Number and Street 2:
3825 PGA BLVD SUITE 303 STE 200
City: State: Country: ZIP+4/Postal Code:
PALM BEACH GARDENS Florida United States 33458
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Telephone Number: Facsimile number, if any:
561-323-2265
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ERBEN ASSOCIATES
Number and Street 1: Number and Street 2:
300 BEARDSLEY LANE D-2
City: State: Country: ZIP+4/Postal Code:
AUSTIN Texas United States 78746
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Telephone Number: Facsimile number, if any:
512-402-0250 512-402-0381
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
GLOBAL RELAY COMMUNICATIONS INC.
Number and Street 1: Number and Street 2:
220 CAMBIE ST 2ND FL
City: State: Country: ZIP+4/Postal Code:
VANCOUVER, BC Canada V6B 2M9
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Telephone Number: Facsimile number, if any:
604-484-6630
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ELECTRONIC CORRESPONDENCE
Name of entity where books and records are kept:
WEALTH PRESERVATION PARTNERS
Number and Street 1: Number and Street 2:
90 HOPEMEADOW ST.
City: State: Country: ZIP+4/Postal Code:
SIMSBURY Connecticut United States 06089
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Telephone Number: Facsimile number, if any:
860-408-6188 860-408-6194
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
EVERGREEN CONSULTING
Number and Street 1: Number and Street 2:
6756 EXECUTIVE OAK LANE
City: State: Country: ZIP+4/Postal Code:
CHATTANOOGA Tennessee United States 37421
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Telephone Number: Facsimile number, if any:
423-756-3828 423-265-0735
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ENZA FINANCIAL
Number and Street 1: Number and Street 2:
6450 ROCKSIDE WOODS BLVD STE 150
City: State: Country: ZIP+4/Postal Code:
INDEPENDENCE Ohio United States 44131
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Telephone Number: Facsimile number, if any:
216-236-0700 216-264-8077
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
THE BENEFITS GROUP
Number and Street 1: Number and Street 2:
9700 WESTLAND DR. SUITE 103
City: State: Country: ZIP+4/Postal Code:
KNOXVILLE Tennessee United States 37922
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Telephone Number: Facsimile number, if any:
865-690-9590 856-690-9052
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
VIE INTERNATIONAL FINANCIAL
Number and Street 1: Number and Street 2:
118 PICCADILLY 7NW
City: State: Country: ZIP+4/Postal Code:
LONDON United Kingdom W1J7DF
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Telephone Number: Facsimile number, if any:
44 (0)20 3457
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CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ICAPITAL
Number and Street 1: Number and Street 2:
60 EAST 42ND STREET
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10165
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Telephone Number: Facsimile number, if any:
212-994-7333
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ALTERNATIVE INVESTMENT PLATFORM.
Name of entity where books and records are kept:
REGED INC.
Number and Street 1: Number and Street 2:
2100 GATEWAY CENTRE BLVD SUITE 200
City: State: Country: ZIP+4/Postal Code:
MORRISVILLE North Carolina United States 27560
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Telephone Number: Facsimile number, if any:
800-334-8322
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VENDOR PROVIDES SOFTWARE AND STORAGE FOR M SECURITIES BOOKS AND RECORDS.
Name of entity where books and records are kept:
CHERNOFF DIAMOND & CO
Number and Street 1: Number and Street 2:
725 RXR PLAZA - EAST TOWER
City: State: Country: ZIP+4/Postal Code:
UNIONDALE New York United States 11556
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Telephone Number: Facsimile number, if any:
516-683-6100 516-683-6163
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
BOLICOLI.COM
Number and Street 1: Number and Street 2:
281 MAIN ST FLOOR 2
City: State: Country: ZIP+4/Postal Code:
READING Massachusetts United States 01867
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Telephone Number: Facsimile number, if any:
781-942-5700 781-942-5710
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
NBW INSURANCE GROUP
Number and Street 1: Number and Street 2:
706 2ND AVE. SOUTH STE 300
City: State: Country: ZIP+4/Postal Code:
MINNEAPOLIS Minnesota United States 55402
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Telephone Number: Facsimile number, if any:
612-339-7385 612-337-5535
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CORRESPONDENCE, INVOICES, RECCOMENDATIONS, NOTES
Name of entity where books and records are kept:
LINDBERG & RIPPLE
Number and Street 1: Number and Street 2:
29 SOUTH MAIN ST. STE 215
City: State: Country: ZIP+4/Postal Code:
WEST HARTFORD Connecticut United States 06107
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Telephone Number: Facsimile number, if any:
860-761-9790 860-761-9791
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CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
FINANCIAL DESIGNS
Number and Street 1: Number and Street 2:
7979 E TUFTS STE 1550
City: State: Country: ZIP+4/Postal Code:
DENVER Colorado United States 80237
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Telephone Number: Facsimile number, if any:
303-832-6100 303-832-7100
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
QUEALLY GROUP
Number and Street 1: Number and Street 2:
28 THORNDALE CIRCLE SUITE 300
City: State: Country: ZIP+4/Postal Code:
DARIEN Connecticut United States 06820
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Telephone Number: Facsimile number, if any:
203-967-8844 203-967-8855
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RECOMMENDATIONS/NOTES.
Name of entity where books and records are kept:
CBA PREMIER INSURANCE SOLUTIONS
Number and Street 1: Number and Street 2:
2033 GATEWAY PLACE #500
City: State: Country: ZIP+4/Postal Code:
SAN JOSE California United States 95110
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Telephone Number: Facsimile number, if any:
408-780-2307 408-271-1802
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ROSE STREET ADVISORS, LLC
Number and Street 1: Number and Street 2:
244 NORTH ROSE ST.
City: State: Country: ZIP+4/Postal Code:
KALAMAZOO Michigan United States 49007
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Telephone Number: Facsimile number, if any:
269-552-3200 269-343-3533
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
FIS GLOBAL
Number and Street 1: Number and Street 2:
347 RIVERSIDE AVE
City: State: Country: ZIP+4/Postal Code:
JACKSONVILLE Florida United States 32204
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Telephone Number: Facsimile number, if any:
9044386000
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TRADE BLOTTER AND SURVEILLANCE REPORTS
Name of entity where books and records are kept:
RETIREMENT & INSURANCE RESOURCES
Number and Street 1: Number and Street 2:
1185 IMMOKALEE RD STE 120
City: State: Country: ZIP+4/Postal Code:
NAPLES Florida United States 34110
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Telephone Number: Facsimile number, if any:
239-434-7500 239-596-9911
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
KJAC PARTNERS
Number and Street 1: Number and Street 2:
300 CARNEGIE CENTER SUITE 240
City: State: Country: ZIP+4/Postal Code:
PRINCETON New Jersey United States 08540
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
609-924-7250 732-899-3000
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
TPG CONSULTING, LLC
Number and Street 1: Number and Street 2:
6520 AIRPORT CENTER DR. STE 203
City: State: Country: ZIP+4/Postal Code:
GREENSBORO North Carolina United States 27409
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
336-553-9240 336-553-9239
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
PLYBON & ASSOCIATES
Number and Street 1: Number and Street 2:
1150 REVOLUTION MILL DRIVE
City: State: Country: ZIP+4/Postal Code:
GREENSBORO North Carolina United States 27409
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Telephone Number: Facsimile number, if any:
336-292-9050 336-292-4618
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
GRENERT FINANCIAL GROUP
Number and Street 1: Number and Street 2:
6424 E GREENWAY PARKWAY
City: State: Country: ZIP+4/Postal Code:
SCOTTSDALE Arizona United States 85254
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Telephone Number: Facsimile number, if any:
7753224500
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RECOMMENDATIONS AND NOTES
Name of entity where books and records are kept:
AEM PARTNERS LLC
Number and Street 1: Number and Street 2:
1800 GLENARM PLACE SUITE 900
City: State: Country: ZIP+4/Postal Code:
DENVER Colorado United States 80202
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Telephone Number: Facsimile number, if any:
3038925701
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AEM PARTNERS, LLC
Name of entity where books and records are kept:
FIELDSTONE INSURANCE GROUP, LLC
Number and Street 1: Number and Street 2:
55 HARRISTOWN RD SUITE 102
City: State: Country: ZIP+4/Postal Code:
GLEN ROCK New Jersey United States 07452
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
201-212-6909 831-309-7353
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
WAXMAN LAWSON FINANCIAL
Number and Street 1: Number and Street 2:
2314 WOODLAWN BLVD
City: State: Country: ZIP+4/Postal Code:
AUSTIN Texas United States 78703
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
512-476-6392 512-474-5057
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
HERITAGE CAPITAL STRATEGIES
Number and Street 1: Number and Street 2:
2555 TOWNSGATE RD STE 105
City: State: Country: ZIP+4/Postal Code:
WESTLAKE VILLAGE California United States 91361
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Telephone Number: Facsimile number, if any:
805-604-2728 805-604-2717
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
BENSON BLACKBURN, LLC
Number and Street 1: Number and Street 2:
5150 TAMIAMI TRAIL NORTH
City: State: Country: ZIP+4/Postal Code:
NAPLES Florida United States 34108
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
239-348-1800
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NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
CHERNOFF DIAMOND & CO.LLC
Number and Street 1: Number and Street 2:
100 N. CORPORATE DRIVE 100
City: State: Country: ZIP+4/Postal Code:
BROOKFIELD Wisconsin United States 53045
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
608-490-8358
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
FINANCIAL DATABASE SERVICES
Number and Street 1: Number and Street 2:
9920 PACIFIC HEIGHTS BLVD #430
City: State: Country: ZIP+4/Postal Code:
SAN DIEGO California United States 92121
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
(858) 526-8110
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VENDOR PROVIDES SOFTWARE AND STORAGE FOR M SECURITIES BOOKS AND RECORDS.
Name of entity where books and records are kept:
GDK & COMPANY
Number and Street 1: Number and Street 2:
5771 MAYFAIR RD.
City: State: Country: ZIP+4/Postal Code:
NORTH CANTON Ohio United States 44720
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
330-966-5577 330-966-5586
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CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
GREENBERG WEXLER & EIG LLC
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
913-269-3219
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NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
M BENEFIT SOLUTIONS
Number and Street 1: Number and Street 2:
1125 NW COUCH ST. STE 900
City: State: Country: ZIP+4/Postal Code:
PORTLAND Oregon United States 97209
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
503-238-1813 503-238-1815
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
BRIDGE FINANCIAL GROUP, LLC
Number and Street 1: Number and Street 2:
13986 W. BOWLES AVE. STE. 200
City: State: Country: ZIP+4/Postal Code:
LITTLETON Colorado United States 80127
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
303-358-7464
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
COHN FINANCIAL GROUP, LLC
Number and Street 1: Number and Street 2:
5090 NORTH 40TH ST. STE 180
City: State: Country: ZIP+4/Postal Code:
PHOENIX Arizona United States 85018
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
602-468-9667 602-468-9704
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
WINGED KEEL GROUP
Number and Street 1: Number and Street 2:
1701 PENNSYLVANIA AVE 200
City: State: Country: ZIP+4/Postal Code:
WASHINGTON District of Columbia United States 20006
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
202-618-5209 301-718-8131
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
CHAFFEE & ASSOCIATES
Number and Street 1: Number and Street 2:
11100 WAYZATA BLVD STE 220
City: State: Country: ZIP+4/Postal Code:
MINNETONKA Minnesota United States 55305
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
952-746-6990 952-746-6995
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RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
CHERNOFF DIAMOND & CO.LLC
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
952-322-9098
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NOTES & RECOMMENDATIONS
Name of entity where books and records are kept:
GREENBERG AND RAPP
Number and Street 1: Number and Street 2:
67 EAST PARK PLACE SUITE 750
City: State: Country: ZIP+4/Postal Code:
MORRISTOWN New Jersey United States 07960
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
973-434-8700 973-434-8171
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CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
HOUGHTON FINANCIAL PARTNERS
Number and Street 1: Number and Street 2:
210 N. CAMPBELL
City: State: Country: ZIP+4/Postal Code:
EL PASO Texas United States 79901
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
915-541-7055 915-577-0751
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS/NOTES.
Name of entity where books and records are kept:
THOMAS FINANCIAL GROUP
Number and Street 1: Number and Street 2:
5550 W. EXECUTIVE DR STE 500
City: State: Country: ZIP+4/Postal Code:
TAMPA Florida United States 33609
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
813-273-9416 813-229-8874
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
THE TEEKELL COMPANY
Number and Street 1: Number and Street 2:
8520 BUSINESS PARK DRIVE
City: State: Country: ZIP+4/Postal Code:
SHREVEPORT Louisiana United States 71105
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
318-222-2373 318-226-1440
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
MADISON & MAIN ADVIORS
Number and Street 1: Number and Street 2:
2185 LEMOINE AVE SUITE 1E
City: State: Country: ZIP+4/Postal Code:
FORT LEE New Jersey United States 07024
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
2123821912
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS AND NOTES
Name of entity where books and records are kept:
MADISON & MAIN ADVISORS
Number and Street 1: Number and Street 2:
339 W BALTIMORE AVE
City: State: Country: ZIP+4/Postal Code:
MEDIA Pennsylvania United States 19063
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
610-977-2015 610-544-1289
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
LYMAN GROUP
Number and Street 1: Number and Street 2:
600 UNIVERSITY STREET 2328
City: State: Country: ZIP+4/Postal Code:
SEATTLE Washington United States 98101
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
2066826266
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS AND NOTES
Name of entity where books and records are kept:
PILLAR INTERNATIONAL INS ADVISORS
Number and Street 1: Number and Street 2:
600 UNIVERSITY STREET STE 280
City: State: Country: ZIP+4/Postal Code:
SEATTE Washington United States 98101
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
2067360500
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS AND NOTES
Name of entity where books and records are kept:
THE R.O.W. GROUP.
Number and Street 1: Number and Street 2:
2020 21ST SUITE 200
City: State: Country: ZIP+4/Postal Code:
NASHVILLE Tennessee United States 37212
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
615-250-7600 615-250-7638
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
PERSPECTIVE FINANCIAL GROUP
Number and Street 1: Number and Street 2:
1041 OLD CASSATT ROAD
City: State: Country: ZIP+4/Postal Code:
BERWYN Pennsylvania United States 19312
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
6108540035
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES AND RECOMMENDATIONS
Name of entity where books and records are kept:
MBS FINANCIAL & INSURANCE
Number and Street 1: Number and Street 2:
340 S WESTGATE AVE
City: State: Country: ZIP+4/Postal Code:
LOS ANGELES California United States 90049
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
310-473-0060
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ESLICK FINANCIAL GROUP
Number and Street 1: Number and Street 2:
999 HOME PLAZA STE 201
City: State: Country: ZIP+4/Postal Code:
WATERLOO Iowa United States 50701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
319-232-5500 319-232-5409
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
WELLSPRING CONSULTING
Number and Street 1: Number and Street 2:
2635 N. FIRST ST. STE. 201
City: State: Country: ZIP+4/Postal Code:
SAN JOSE California United States 95134
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
408-435-1668 408-456-6768
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
LOVASCO CONSULTING GROUP
Number and Street 1: Number and Street 2:
ONE WOODWARD AVE STE 1500
City: State: Country: ZIP+4/Postal Code:
DETROIT Michigan United States 48226
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
313-394-1700
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
RESSOURCEMENT
Number and Street 1: Number and Street 2:
114 W THIRD STREET
City: State: Country: ZIP+4/Postal Code:
PERRYSBURG Ohio United States 43551
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
419-874-9300 419-874-9766
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ONETEAM FINANCIAL
Number and Street 1: Number and Street 2:
331 NEWMAN SPRINGS ROAD BLDG 1, SUITE 107
City: State: Country: ZIP+4/Postal Code:
RED BANK New Jersey United States 07701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
908-653-7295 908-272-0704
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
CORRESPONDENCE, INVOICES, RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ONETEAM FINANCIAL
Number and Street 1: Number and Street 2:
331 NEWMAN SPRINGS RD BLDG 1, STE 107
City: State: Country: ZIP+4/Postal Code:
RED BANK New Jersey United States 07701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
844-451-8326
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
R.MARSHALL JONES INC
Number and Street 1: Number and Street 2:
13631 DEERING BAY DRIVE
City: State: Country: ZIP+4/Postal Code:
CORAL GABLES Florida United States 33134
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
5617129799
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES AND RECOMMENDATIONS
Name of entity where books and records are kept:
TCS INSURANCE AGENCY
Number and Street 1: Number and Street 2:
100 SMITH RANCH STE 340
City: State: Country: ZIP+4/Postal Code:
SAN RAFAEL California United States 94903
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
4154614427
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
NOTES AND RECOMMENDATIONS
Name of entity where books and records are kept:
ENVESTNET
Number and Street 1: Number and Street 2:
1801 CALIFORNIA STREET 23RD FLOOR
City: State: Country: ZIP+4/Postal Code:
DENVER Colorado United States 80202
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
8669248913
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
SERVICE PROVIDER TO WRAP FEE PROGRAM AND DATA AGGREGATION FOR OTHER PROGRAMS.
Name of entity where books and records are kept:
TIPPETT MOORHEAD FINANCIAL PTNRS
Number and Street 1: Number and Street 2:
3200 PARK CENTER DR. STE. 550
City: State: Country: ZIP+4/Postal Code:
COSTA MESA California United States 92626
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
949-209-9851 949-209-9811
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
EVERGREEN CONSULTING
Number and Street 1: Number and Street 2:
315 ROBERT ROSE DR SUITE B
City: State: Country: ZIP+4/Postal Code:
MURFREESBORO Tennessee United States 37129
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
615-893-4025 615-893-4069
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
SWARTZBAUGH-FARBER & ASSOCIATES
Number and Street 1: Number and Street 2:
FINANCIAL PLAZA 9140 WEST DODGE RD STE 418
City: State: Country: ZIP+4/Postal Code:
OMAHA Nebraska United States 68114
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
402-397-5800 402-397-5424
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
DBP WEALTH ADVISORY GROUP LLC
Number and Street 1: Number and Street 2:
1007 BROADWAY
City: State: Country: ZIP+4/Postal Code:
HIGHLAND Illinois United States 62249
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
618-654-4426 618-654-4442
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
PFLEGER FINANCIAL GROUP
Number and Street 1: Number and Street 2:
2600 S DOUGLAS ROAD STE 101
City: State: Country: ZIP+4/Postal Code:
CORAL GABLES Florida United States 33134
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
305-441-1410 305-441-1710
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
ROBINSON FINANCIAL GROUP
Number and Street 1: Number and Street 2:
8833 GROSS POINT RD STE 200
City: State: Country: ZIP+4/Postal Code:
SKOKIE Illinois United States 60077
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
847-679-0700 847-679-0857
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
MCDOWELL FINANCIAL GROUP
Number and Street 1: Number and Street 2:
609 E TAN TARA CIRCLE STE 101
City: State: Country: ZIP+4/Postal Code:
SIOUX FALLS South Dakota United States 57108
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
605-323-3330 605-323-3310
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
MORGAN ADVISORY GROUP
Number and Street 1: Number and Street 2:
2101 E. COAST HIGHWAY, STE 120
City: State: Country: ZIP+4/Postal Code:
CORONA DEL MAR California United States 92625
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
949-760-4051
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
CATALYST SOLUTIONS GROUP, INC
Number and Street 1: Number and Street 2:
210 EAST CIMARRON STREET
City: State: Country: ZIP+4/Postal Code:
COLORADO SPRINGS Colorado United States 80903
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
719-635-1132 719-635-1464
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
RECOMMENDATIONS, NOTES
Name of entity where books and records are kept:
RED OAK
Number and Street 1: Number and Street 2:
12708 RIATA CIRCLE SUITE B100 SUITE B100
City: State: Country: ZIP+4/Postal Code:
AUSTIN Texas United States 78727
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
5127963299
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
COMPLIANCE SYSTEM RECORDKEEPER
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
No Information Filed
Item 2 SEC Registration/Reporting
Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC
registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be provided
for the filing adviser only.
A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual updating
amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides information to help
you determine whether you may affirmatively respond to each of these items.
You (the adviser):
(1) are a large advisory firm that either:
(a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or
(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment and
is registered with the SEC;
(2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in U.S.
dollars) and you are either:
(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of
business; or
(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;
Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.
(3) Reserved
(4) have your principal office and place of business outside the United States;
(5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;
(6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment
Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;
(7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule
203A-2(a);
(8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered with
the SEC, and your principal office and place of business is the same as the registered adviser;
If you check this box, complete Section 2.A.(8) of Schedule D.
(9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;
If you check this box, complete Section 2.A.(9) of Schedule D.
(10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);
If you check this box, complete Section 2.A.(10) of Schedule D.
(11) are an Internet adviser relying on rule 203A-2(e);
If you check this box, complete Section 2.A.(11) of Schedule D.
(12) have received an SEC order exempting you from the prohibition against registration with the SEC;
If you check this box, complete Section 2.A.(12) of Schedule D.
(13) are no longer eligible to remain registered with the SEC.
State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with
the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and any
amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of this and
all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the box(es)
next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to your
registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s).
Jurisdictions
AL IL NE SC
AK IN NV SD
AZ IA NH TN
AR KS NJ TX
CA KY NM UT
CO LA NY VT
CT ME NC VI
DE MD ND VA
DC MA OH WA
FL MI OK WV
GA MN OR WI
GU MS PA WY
HI MO PR
ID MT RI
If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's
notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).
SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an
investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following
information:
Name of Registered Investment Adviser
CRD Number of Registered Investment Adviser
SEC Number of Registered Investment Adviser
-
SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days
If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within
120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have
made the required representations. You must make both of these representations:
I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register
with the SEC within 120 days after the date my registration with the SEC becomes effective.
I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section 203A(a)
of the Advisers Act from registering with the SEC.
SECTION 2.A.(10) Multi-State Adviser
If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about
your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.
If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:
I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment adviser
with the state securities authorities in those states.
I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states to
register as an investment adviser with the state securities authorities of those states.
If you are submitting your annual updating amendment, you must make this representation:
Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the laws
of at least 15 states to register as an investment adviser with the state securities authorities in those states.
SECTION 2.A.(11) Internet Adviser
If you are relying on rule 203A-2(e), the Internet adviser exemption from the prohibition on registration, you are required to make a representation about your
eligibility for SEC registration. By checking the appropriate box, you will be deemed to have made the required representation.
If you are applying for registration as an investment adviser with the SEC or changing your existing Item 2 response regarding your eligibility for SEC registration, you
must make this representation:
I will provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
If you are filing an annual updating amendment to your existing registration and are continuing to rely on the Internet adviser exemption for SEC registration, you
must make this representation:
I have provided and will continue to provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
SECTION 2.A.(12) SEC Exemptive Order
If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:
Application Number:
803-
Date of order:
Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation
Sole Proprietorship
Limited Liability Partnership (LLP)
Partnership
Limited Liability Company (LLC)
Limited Partnership (LP)
Other (specify):
If you are changing your response to this Item, see Part 1A Instruction 4.
B. In what month does your fiscal year end each year?
DECEMBER
C. Under the laws of what state or country are you organized?
State Country
Oregon United States
If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the name of the
state or country where you reside.
If you are changing your response to this Item, see Part 1A Instruction 4.
Item 4 Successions
Yes No
A. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your structure or
legal status (e.g., form of organization or state of incorporation)?
If "yes", complete Item 4.B. and Section 4 of Schedule D.
B. Date of Succession: (MM/DD/YYYY)
If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.
SECTION 4 Successions
No Information Filed
Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation
Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making regulatory
policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5.
Employees
If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an employee performs
more than one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).
A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.
1442
B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
171
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
709
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?
222
(4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives
for an investment adviser other than you?
156
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
445
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
1
In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your behalf.
Clients
In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those
investors.
C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during
your most recently completed fiscal year?
0
(2) Approximately what percentage of your clients are non-United States persons?
0%
D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not
include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940.
Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940, do
not answer (1)(d) or (3)(d) below.
Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to each
of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than respond
to Item 5.D.(1).
The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under management
reported in Item 5.F.(2)(c) below.
If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you
advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as
applicable.
(1) Number of (2) Fewer than 5 (3) Amount of Regulatory Assets under
Type of Client Client(s) Clients Management
(a) Individuals (other than high net worth individuals) 4290 $ 1,880,172,154
(b) High net worth individuals 78 $ 1,150,538,483
(c) Banking or thrift institutions $
(d) Investment companies $
(e) Business development companies $
(f) Pooled investment vehicles (other than investment companies and $
business development companies)
(g) Pension and profit sharing plans (but not the plan participants or 15 $ 11,863,919
government pension plans)
(h) Charitable organizations $
(i) State or municipal government entities (including government pension $
plans)
(j) Other investment advisers $
(k) Insurance companies $
(l) Sovereign wealth funds and foreign official institutions $
(m) Corporations or other businesses not listed above 130 $ 163,756,098
(n) Other: $
Compensation Arrangements
E. You are compensated for your investment advisory services by (check all that apply):
(1) A percentage of assets under your management
(2) Hourly charges
(3) Subscription fees (for a newsletter or periodical)
(4) Fixed fees (other than subscription fees)
(5) Commissions
(6) Performance-based fees
(7) Other (specify):
Item 5 Information About Your Advisory Business - Regulatory Assets Under Management
Regulatory Assets Under Management
Yes No
F. (1) Do you provide continuous and regular supervisory or management services to securities portfolios?
(2) If yes, what is the amount of your regulatory assets under management and total number of accounts?
U.S. Dollar Amount Total Number of Accounts
Discretionary: (a) $ 1,971,698,764 (d) 6,118
Non-Discretionary: (b) $ 1,234,631,890 (e) 1,997
Total: (c) $ 3,206,330,654 (f) 8,115
Part 1A Instruction 5.b. explains how to calculate your regulatory assets under management. You must follow these instructions carefully when completing this
Item.
(3) What is the approximate amount of your total regulatory assets under management (reported in Item 5.F.(2)(c) above) attributable to clients who are
non-United States persons?
$ 5,158,006
Item 5 Information About Your Advisory Business - Advisory Activities
Advisory Activities
G. What type(s) of advisory services do you provide? Check all that apply.
(1) Financial planning services
(2) Portfolio management for individuals and/or small businesses
(3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54 of
the Investment Company Act of 1940)
(4) Portfolio management for pooled investment vehicles (other than investment companies)
(5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other
pooled investment vehicles)
(6) Pension consulting services
(7) Selection of other advisers (including private fund managers)
(8) Publication of periodicals or newsletters
(9) Security ratings or pricing services
(10) Market timing services
(11) Educational seminars/workshops
(12) Other(specify):
Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the
Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment
companies to which you provide advice in Section 5.G.(3) of Schedule D.
H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?
0
1 - 10
11 - 25
26 - 50
51 - 100
101 - 250
251 - 500
More than 500
If more than 500, how many?
(round to the nearest 500)
In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those
investors.
Yes No
I. (1) Do you participate in a wrap fee program?
(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:
(a) sponsor to a wrap fee program
$ 25,455,391
(b) portfolio manager for a wrap fee program?
$0
(c) sponsor to and portfolio manager for the same wrap fee program?
$ 1,513,437,025
If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b).
If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D.
If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap fee
program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2).
Yes No
J. (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of
investments?
(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory
assets under management?
K. Separately Managed Account Clients
Yes No
(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed account
clients)?
If yes, complete Section 5.K.(1) of Schedule D.
(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten
percent or more of this remaining amount of regulatory assets under management?
If yes, complete Section 5.K.(3) of Schedule D for each custodian.
L. Marketing Activities
Yes No
(1) Do any of your advertisements include:
(a) Performance results?
(b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))?
(c) Testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(e) Third-party ratings?
(2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in connection
with the use of testimonials, endorsements, or third-party ratings?
(3) Do any of your advertisements include hypothetical performance ?
(4) Do any of your advertisements include predecessor performance ?
SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies
No Information Filed
SECTION 5.I.(2) Wrap Fee Programs
If you are a portfolio manager for one or more wrap fee programs, list the name of each program and its sponsor. You must complete a separate Schedule D Section
5.I.(2) for each wrap fee program for which you are a portfolio manager.
Name of Wrap Fee Program
WEALTH PURSUIT CLASSIC
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
Name of Wrap Fee Program
WEALTH PURSUIT CUSTOM
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
Name of Wrap Fee Program
WEALTH PURSUIT CUSTOM SMA
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
Name of Wrap Fee Program
WEALTH PURSUIT CUSTOM UMA
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
Name of Wrap Fee Program
WEALTH PURSUIT ENVOY
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
Name of Wrap Fee Program
WEALTH PURSUIT STRATIGIST
Name of Sponsor
M HOLDINGS SECURITIES, INC.
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 57304
Sponsor's CRD Number (if any):
43285
SECTION 5.K.(1) Separately Managed Accounts
After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this
remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management,
complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b).
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise.
End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date six
months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent.
Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those
categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit, bankers'
acceptances and similar bank instruments.
Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and
the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and
consistent with information you report internally and to current and prospective clients. However, you should not double count assets, and your responses must be
consistent with any instructions or other guidance relating to this Section.
(a) Asset Type Mid-year End of year
(i) Exchange-Traded Equity Securities % %
(ii) Non Exchange-Traded Equity Securities % %
(iii) U.S. Government/Agency Bonds % %
(iv) U.S. State and Local Bonds % %
(v) Sovereign Bonds % %
(vi) Investment Grade Corporate Bonds % %
(vii) Non-Investment Grade Corporate Bonds % %
(viii) Derivatives % %
(ix) Securities Issued by Registered Investment Companies or Business Development Companies % %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development % %
Companies)
(xi) Cash and Cash Equivalents % %
(xii) Other % %
Generally describe any assets included in "Other"
(b) Asset Type End of year
(i) Exchange-Traded Equity Securities 49 %
(ii) Non Exchange-Traded Equity Securities 0%
(iii) U.S. Government/Agency Bonds 2%
(iv) U.S. State and Local Bonds 2%
(v) Sovereign Bonds 0%
(vi) Investment Grade Corporate Bonds 0%
(vii) Non-Investment Grade Corporate Bonds 0%
(viii) Derivatives 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 39 %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies) 0%
(xi) Cash and Cash Equivalents 10 %
(xii) Other 1%
Generally describe any assets included in "Other"
WE HAVE ASSETS LESS THAN 1% IN (II), (VI) (VII), (VIII)
SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives
No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)
If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your
regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete Question
(b).
(a) In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed
account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate your
regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before the end of year date.
In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional
exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any
borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.
In column 2, provide the dollar amount of borrowings for the accounts included in column 1.
In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in
column 1 with respect to each category of derivatives specified in 3(a) through (f).
You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than
$10,000,000.
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
(i) Mid-Year
Gross Notional (1) Regulatory Assets Under (2)
Exposure Management Borrowings (3) Derivative Exposures
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ $ % % % % % %
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(ii) End of Year
Gross Notional (1) Regulatory Assets Under (2)
Exposure Management Borrowings (3) Derivative Exposures
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ $ % % % % % %
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory
assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide
information with respect to the portion of the account that you subadvise.
In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional
exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of any
borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.
In column 2, provide the dollar amount of borrowings for the accounts included in column 1.
You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than
$10,000,000.
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings
Less than 10% $ 109,203,238 $ 525,266
10-149% $ $
150% or more $ $
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
SECTION 5.K.(3) Custodians for Separately Managed Accounts
Complete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account regulatory assets
under management.
(a) Legal name of custodian:
CHARLES SCHWAB & CO., INC.
(b) Primary business name of custodian:
CHARLES SCHWAB & CO., INC.
(c) The location(s) of the custodian's office(s) responsible for custody of the assets :
City: State: Country:
SAN FRANCISCO California United States
Yes No
(d) Is the custodian a related person of your firm?
(e) If the custodian is a broker-dealer, provide its SEC registration number (if any)
8 - 16514
(f) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 1,198,358,982
(a) Legal name of custodian:
NATIONAL FINANCIAL SERVICES LLC
(b) Primary business name of custodian:
NATIONAL FINANCIAL SERVICES LLC
(c) The location(s) of the custodian's office(s) responsible for custody of the assets :
City: State: Country:
BOSTON Massachusetts United States
Yes No
(d) Is the custodian a related person of your firm?
(e) If the custodian is a broker-dealer, provide its SEC registration number (if any)
8 - 26740
(f) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if any)
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 1,691,708,140
Item 6 Other Business Activities
In this Item, we request information about your firm's other business activities.
A. You are actively engaged in business as a (check all that apply):
(1) broker-dealer (registered or unregistered)
(2) registered representative of a broker-dealer
(3) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(4) futures commission merchant
(5) real estate broker, dealer, or agent
(6) insurance broker or agent
(7) bank (including a separately identifiable department or division of a bank)
(8) trust company
(9) registered municipal advisor
(10) registered security-based swap dealer
(11) major security-based swap participant
(12) accountant or accounting firm
(13) lawyer or law firm
(14) other financial product salesperson (specify):
If you engage in other business using a name that is different from the names reported in Items 1.A. or 1.B.(1), complete Section 6.A. of Schedule D.
Yes No
B. (1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice)?
(2) If yes, is this other business your primary business?
If "yes," describe this other business on Section 6.B.(2) of Schedule D, and if you engage in this business under a different name, provide that name.
Yes No
(3) Do you sell products or provide services other than investment advice to your advisory clients?
If "yes," describe this other business on Section 6.B.(3) of Schedule D, and if you engage in this business under a different name, provide that name.
SECTION 6.A. Names of Your Other Businesses
No Information Filed
SECTION 6.B.(2) Description of Primary Business
Describe your primary business (not your investment advisory business):
If you engage in that business under a different name, provide that name:
SECTION 6.B.(3) Description of Other Products and Services
Describe other products or services you sell to your client. You may omit products and services that you listed in Section 6.B.(2) above.
THROUGH THE BROKER DEALER RELATIONSHIP WITH M HOLDINGS SECURITIES, INC., VARIABLE LIFE, VARIABLE ANNUITIES, MUTUAL FUNDS,GENERAL SECURITIES,
ALTERNATIVE INVESTMENTS ARE SOLD.
If you engage in that business under a different name, provide that name:
Item 7 Financial Industry Affiliations
In this Item, we request information about your financial industry affiliations and activities. This information identifies areas in which conflicts of interest may occur
between you and your clients.
A. This part of Item 7 requires you to provide information about you and your related persons, including foreign affiliates. Your related persons are all of your advisory
affiliates and any person that is under common control with you.
You have a related person that is a (check all that apply):
(1) broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered)
(2) other investment adviser (including financial planners)
(3) registered municipal advisor
(4) registered security-based swap dealer
(5) major security-based swap participant
(6) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(7) futures commission merchant
(8) banking or thrift institution
(9) trust company
(10) accountant or accounting firm
(11) lawyer or law firm
(12) insurance company or agency
(13) pension consultant
(14) real estate broker or dealer
(15) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(16) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Note that Item 7.A. should not be used to disclose that some of your employees perform investment advisory functions or are registered representatives of a broker-
dealer. The number of your firm's employees who perform investment advisory functions should be disclosed under Item 5.B.(1). The number of your firm's employees
who are registered representatives of a broker-dealer should be disclosed under Item 5.B.(2).
Note that if you are filing an umbrella registration, you should not check Item 7.A.(2) with respect to your relying advisers, and you do not have to complete Section 7.A.
in Schedule D for your relying advisers. You should complete a Schedule R for each relying adviser.
For each related person, including foreign affiliates that may not be registered or required to be registered in the United States, complete Section 7.A. of Schedule D.
You do not need to complete Section 7.A. of Schedule D for any related person if: (1) you have no business dealings with the related person in connection with advisory
services you provide to your clients; (2) you do not conduct shared operations with the related person; (3) you do not refer clients or business to the related person, and
the related person does not refer prospective clients or business to you; (4) you do not share supervised persons or premises with the related person; and (5) you have
no reason to believe that your relationship with the related person otherwise creates a conflict of interest with your clients.
You must complete Section 7.A. of Schedule D for each related person acting as qualified custodian in connection with advisory services you provide to your clients (other
than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1)), regardless of whether you have determined the related person to be operationally independent
under rule 206(4)-2 of the Advisers Act.
SECTION 7.A. Financial Industry Affiliations
Complete a separate Schedule D Section 7.A. for each related person listed in Item 7.A.
1. Legal Name of Related Person:
MANAGEMENT COMPENSATION GROUP NORTHWEST, LLC DBA M BENEFIT SOLUTIONS
2. Primary Business Name of Related Person:
INSURANCE AGENCY
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
M FINANCIAL SECURITIES MARKETING, INC.
2. Primary Business Name of Related Person:
M FINANCIAL SECURITIES MARKETING, INC.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
8 - 67206
or
Other
4. Related Person's
(a) CRD Number (if any):
139304
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
M LIFE INSURANCE COMPANY
2. Primary Business Name of Related Person:
M FINANCIAL RE
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
M INSURANCE SOLUTIONS, INC.
2. Primary Business Name of Related Person:
M INSURANCE SOLUTIONS, INC.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
M FINANCIAL ASSET MANAGEMENT, INC.
2. Primary Business Name of Related Person:
M FINANCIAL ASSET MANAGEMENT, INC.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 66320
or
Other
4. Related Person's
(a) CRD Number (if any):
136694
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
M FINANCIAL INVESTMENT ADVISERS INC
2. Primary Business Name of Related Person:
M FINANCIAL INVESTMENT ADVISERS INC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 50553
or
Other
4. Related Person's
(a) CRD Number (if any):
106648
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption that
you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a surprise
examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence and
in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and another
SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its Form ADV (e.g.,
if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of Schedule D.
In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or
similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place of
the fund's name.
SECTION 7.B.(1) Private Fund Reporting
No Information Filed
SECTION 7.B.(2) Private Fund Reporting
No Information Filed
Item 8 Participation or Interest in Client Transactions
In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of
interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that you
expect to engage in during the next year.
Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.
Proprietary Interest in Client Transactions
A. Do you or any related person: Yes No
(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?
(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?
(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary (ownership)
interest (other than those mentioned in Items 8.A.(1) or (2))?
Sales Interest in Client Transactions
B. Do you or any related person: Yes No
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client
securities are sold to or bought from the brokerage customer (agency cross transactions)?
(2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you or
any related person serves as underwriter or general or managing partner?
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the receipt
of sales commissions as a broker or registered representative of a broker-dealer)?
Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the: Yes No
(1) securities to be bought or sold for a client's account?
(2) amount of securities to be bought or sold for a client's account?
(3) broker or dealer to be used for a purchase or sale of securities for a client's account?
(4) commission rates to be paid to a broker or dealer for a client's securities transactions?
D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?
E. Do you or any related person recommend brokers or dealers to clients?
F. If you answer "yes" to E. above, are any of the brokers or dealers related persons?
G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft dollar
benefits") in connection with client securities transactions?
(2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section
28(e) of the Securities Exchange Act of 1934?
H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?
(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm
(cash or non-cash compensation in addition to the employee's regular salary)?
I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related person)
for client referrals?
In your response to Item 8.I., do not include the regular salary you pay to an employee.
In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in
answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals.
Item 9 Custody
In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment
Company Act of 1940) assets and about your custodial practices.
A. (1) Do you have custody of any advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly from
your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the
presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.
(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have
custody:
U.S. Dollar Amount Total Number of Clients
(a) $ 945,024,204 (b) 945
If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not include
the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with
advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that
information in your response to Item 9.B.(2).
B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).
(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your related
persons have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ (b)
C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that
apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are
distributed to the investors in the pools.
(3) An independent public accountant conducts an annual surprise examination of client funds and securities.
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are qualified
custodians for client funds and securities.
If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an internal
control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information with respect
to the private funds you advise in Section 7.B.(1) of Schedule D).
D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian
(2) your related person(s) act as qualified custodian(s)
If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1))
must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of
the Advisers Act.
E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal year,
provide the date (MM/YYYY) the examination commenced:
08/2025
F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as
qualified custodians for your clients in connection with advisory services you provide to clients?
2
SECTION 9.C. Independent Public Accountant
You must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a pooled
investment vehicle that you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each independent public
accountant.
(1) Name of the independent public accountant:
ASHLAND PARTNERS & COMPANY LLP
(2) The location of the independent public accountant's office responsible for the services provided:
Number and Street 1: Number and Street 2:
3512 EXCEL DRIVE SUITE 103
City: State: Country: ZIP+4/Postal Code:
MEDFORD Oregon United States 97504
Yes No
(3) Is the independent public accountant registered with the Public Company Accounting Oversight Board?
If "yes," Public Company Accounting Oversight Board-Assigned Number:
3783
(4) If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
(5) The independent public accountant is engaged to:
A. audit a pooled investment vehicle
B. perform a surprise examination of clients' assets
C. prepare an internal control report
(6) Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment vehicle or
that examined internal controls contain unqualified opinions?
Yes
No
Report Not Yet Received
If you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is available.
Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be
provided for the filing adviser only.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and
executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either
Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
If yes, complete Section 10.A. of Schedule D.
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities Exchange
Act of 1934, please complete Section 10.B. of Schedule D.
SECTION 10.A. Control Persons
You must complete a separate Schedule D Section 10.A. for each control person not named in Item 1.A. or Schedules A, B, or C that directly or indirectly controls your
management or policies.
Individual Name (if applicable) (Last, First, Middle)
Bundschuh, Russell, George
CRD Number (if any)
7504882
Effective Date Termination Date
02/07/2022
Business Address:
Number and Street 1 Number and Street 2
1125 NW COUCH STREET #900, PORTLAND, OR 97209
City State Country ZIP+4/Postal Code
PORTLAND Oregon United States 97209
If this address is a private residence, check this box:
Briefly describe the nature of the control:
MR. BUNDSCHUH IS THE CEO OF M FINANCIAL HOLDINGS INC. (PARENT COMPANY OF M HOLDINGS SECURITIES, INC.) HAS DIRECT AUTHORITY OVER THE OFFICERS OF
M HOLDINGS SECURITIES, INC.
SECTION 10.B. Control Person Public Reporting Companies
No Information Filed
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. In
accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration.
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 or if you are an exempt reporting adviser, 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.
Yes No
Do any of the events below involve you or any of your supervised persons?
For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
(2) been charged with any felony?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, 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, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that are
currently pending.
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?
(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by
order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?
(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)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the
advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or
11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or
foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?
Item 12 Small Businesses
The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you
meet the definition of "small business" or "small organization" under rule 0-7.
Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under
management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state
registration, or switching from SEC to state registration.
For purposes of this Item 12 only:
Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you
may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that
amount is larger).
Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or
otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the
profits, of another person is presumed to control the other person.
Yes No
A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?
If "yes," you do not need to answer Items 12.B. and 12.C.
B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25
million or more on the last day of its most recent fiscal year?
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year?
C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to
Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year?
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day
of its most recent fiscal year?
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers. Use
Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if
you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public
reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of your
voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that
he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have
contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed, 5%
or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more of
your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member;
and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have
control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of
Name, First Name, Middle Name) Acquired MM/YYYY Code Person Birth, IRS Tax No. or Employer ID No.
M FINANCIAL HOLDINGS INCORPORATED DE EQUITY OWNER 03/1997 E Y N
ROGERS, MARIA RENEE I PRINCIPAL FINANCIAL 09/2007 NA N N 2442526
OFFICER
SCHOONMAKER, MICHAEL SKI I CHIEF EXECUTIVE OFFICER 01/2023 NA Y N 2408456
LUDWIG, STEVEN CHARLES I CHIEF COMPLIANCE 10/2023 NA N N 2440911
OFFICER
HANEY-JACKSON, LAURA ELIZABETH I VICE PRESIDENT - 01/2024 NA N N 4771801
PRINCIPAL OPERATIONS
OFFICER
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first complete
Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale
of, 25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent,
spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she has
the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 25%
or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the
Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members, the
class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have
control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
No Information Filed
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Schedule R
No Information Filed
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 43285
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: M HOLDINGS SECURITIES, INC.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
07/09/2018 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2017052293001
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Other
Other Product Types:
PRIVATE SECURITIES TRANSACTIONS
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
07/09/2018 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 135,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
MONETARY FINE
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
ON JULY 9, 2018, WITHOUT ADMITTING OR DENYING THE FINDINGS, OUR BROKER DEALER CONSENTED TO SANCTIONS EQUAL TO $135,000 AND TO THE ENTRY
OF FINDINGS FROM DECEMBER 2013 TO JUNE 2017, THAT SPECIFIED IT DID NOT ESTABLISH, MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING
WRITTEN SUPERVISORY PROCEDURES REASONABLY DESIGNED TO SUPERVISE REGISTERED REPRESENTATIVES' USE OF CONSOLIDATED REPORTS. THE FINDINGS
STATED THAT DURING THIS PERIOD, ASSOCIATED PERSONS OF M SECURITIES CREATED AND DISSEMINATED CONSOLIDATED REPORTS TO CUSTOMERS, YET IT
HAD NO PROCEDURES DIRECTLY ADDRESSING THE SUPERVISION OF CONSOLIDATED REPORTS. IN RESPONSE, WE CREATED PROCEDURES ADDRESSING THE USE
AND DISSEMINATION OF CONSOLIDATED REPORTS BY OUR REPRESENTATIVES.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Cease and Desist
Other Sanctions:
REMEDIAL SANCTIONS AND CENSURE
3. Date Initiated (MM/DD/YYYY):
06/11/2018 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
3-19096
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 11, 2019, THE SECURITIES AND EXCHANGE COMMISSION (SEC) PUBLISHED IA RELEASE NO. 5193, AN ORDER INSTITUTING ADMINISTRATIVE AND
CEASE AND DESIST PROCEEDINGS, PURSUANT TO SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT), AGAINST M
HOLDINGS SECURITIES, INC. (RESPONDENT). RESPONDENT SELF-REPORTED THE VIOLATIONS TO THE SEC. THE PROCEEDINGS ARISE OUT OF BREACHES OF
FIDUCIARY DUTY AND INADEQUATE DISCLOSURES BY RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE 12B-
1 FEES IT AND/OR ITS ASSOCIATED PERSONS RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED FOR, RECOMMENDED TO, OR HELD
FOR ADVISORY CLIENTS MUTUAL FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH
THE CLIENTS WERE ELIGIBLE. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR OTHERWISE CONFLICTS OF INTEREST RELATED TO THE COLLECTION OF
SUCH FEES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207
OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT PLUS INTEREST OF $1,022,048.49 AND SHALL COMPLY WITH THE
UNDERTAKINGS DESCRIBED IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
WITHIN 30 DAYS OF THE ORDER'S ISSUANCE, M SECURITIES IS REQUIRED TO: DEPOSIT THE MONEY IN AN ESCROW ACCOUNT, UPDATE ITS DISCLOSURES,
UPDATE ITS POLICIES AND PROCEDURES, CONVERT ELIGIBLE FUNDS TO A LOWER-COST SHARE CLASS AND PROVIDE AFFECTED CLIENTS WITH NOTIFICATION.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 44040
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: CHAFFEE, RICHARD, JOHNSON
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF MINNESOTA DEPARTMENT OF COMMERCE
2. Principal Sanction:
Censure
Other Sanctions:
CEASE AND DISIST, AND CIVIL AND ADMINISTRATIVE PENALTY/FINE
3. Date Initiated (MM/DD/YYYY):
01/02/2020 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2328
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
M HOLDINGS SECURITIES, INC.
6. Principal Product Type:
Insurance
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ALLEGATIONS THAT RESPONDENT MADE AN UNSUITABLE LIFE INSURANCE SALE TO MINNESOTA CONSUMER AND PROVIDED INACCURATE INFORMATION ABOUT
THE POLICY'S FUNDING TO THE ISSUING INSURANCE CARRIER.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
01/02/2020 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 4,225.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
RESTITUION OF $10,000, CIVIL PENALTY OF $4,000, MONETARY PENALTY OF $225. ALL PAID 1/13/2020.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
IN ORDER TO AVOID THE TIME AND EXPENSE OF LITIGATION, REPRESENTATIVE CONSENTED WITH THE INSURANCE COMMISSIONER TO INFORMAL DISPOSITION
FOLLOWING A CLIENT'S ALLEGATION REGARDING THE SALE OF A LIFE INSURANCE PRODUCT.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE, CEASE AND DESIST
3. Date Initiated (MM/DD/YYYY):
11/25/2025 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
3-22562
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION ("SEC") FOUND THAT M HOLDINGS SECURITIES, INC. ("M HOLDINGS") FAILED TO (1) ADOPT WRITTEN POLICIES
AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION, IN VIOLATION OF RULE 30(A) OF REGULATION SP (17 C.F.R. §
248.30(A)); AND (2) DEVELOP AND IMPLEMENT A WRITTEN IDENTITY THEFT PREVENTION PROGRAM THAT IS DESIGNED TO DETECT, PREVENT, AND MITIGATE
IDENTITY THEFT IN CONNECTION WITH THE OPENING OF A COVERED ACCOUNT OR ANY EXISTING COVERED ACCOUNT, IN VIOLATION OF RULE 201 OF
REGULATION SID (17 C.F.R. § 248.201).
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
11/25/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 325,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
RESPONDENT M HOLDINGS CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS. RESPONDENT PAID CIVIL MONEY PENALTY OF $325,000
ON DECEMBER 4, 2025.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit
within the space provided).
ON NOVEMBER 25, 2025, THE SEC ENTERED INTO A SETTLED ADMINISTRATIVE PROCEEDING WITH M HOLDINGS FINDING THAT M HOLDINGS FAILED TO (1)
ADOPT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PROTECT CUSTOMER RECORDS AND INFORMATION; AND (2) DEVELOP AND IMPLEMENT
A WRITTEN IDENTITY THEFT PREVENTION PROGRAM THAT IS DESIGNED TO DETECT, PREVENT, AND MITIGATE IDENTITY THEFT IN CONNECTION WITH THE
OPENING OF A COVERED ACCOUNT OR ANY EXISTING COVERED ACCOUNT. WITHOUT ADMITTING OR DENYING THE FINDINGS, M HOLDINGS ENTERED INTO A
SETTLEMENT WITH THE SEC, PURSUANT TO WHICH M HOLDINGS WAS (A) ORDERED TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS
AND ANY FUTURE VIOLATIONS OF RULE 30(A) OF REGULATION SP (17 C.F.R. § 248.30(A)) AND OF RULE 201 OF REGULATION SID (17 C.F.R. § 248.201), (B)
CENSURED, AND (C) ORDERED TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $325,000. THE CIVIL MONETARY PENALTY HAS BEEN PAID IN
ACCORDANCE WITH THE TERMS OF THE SETTLEMENT ORDER.
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
Part 2
Exemption from brochure delivery requirements for SEC-registered advisers
SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a brochure to all
of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules?
If no, complete the ADV Part 2 filing below.
Amend, retire or file new brochures:
Brochure ID Brochure Name Brochure Type(s)
367420 WEALTHPURSUIT WRAP FEE PROGRAMS Wrap program
BROCHURE
367421 M HOLDINGS SECURITIES, INC. FORM Individuals, Pension plans/profit sharing plans,
2A ADV FIRM BROCHURE Foundations/charities, Other institutional, Selection of
Other Advisers/Solicitors
Part 3
CRS Type(s) Affiliate Info Retire
Dual
Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC
and all amendments.
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the state in
which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to receive service, and
agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process
or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration
brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or arbitration (a) arises out of any activity in connection
with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the
Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of
1940, or any rule or regulation under any of these acts, or (ii) the laws of the state in which you maintain your principal office and place of business or of any state in
which you are submitting a notice filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under penalty of
perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information
submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or
possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
REGINA SIMS 03/31/2026
Printed Name: Title:
REGINA SIMS MANAGER, COMPLIANCE
Adviser CRD Number:
43285
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC
and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other
legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept
service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree
that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any place
subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment advisory
business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the
Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or
regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or is
admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power of
attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington D.C.,
at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and complete
copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be binding upon
you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general partners and
managing agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other information
submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or
possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
43285