← Jpmorgan Asset Management (Asia Pacific) Limited
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: JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED CRD Number: 300114
Other-Than-Annual Amendment - All Sections Rev. 10/2021
3/31/2026 11:34:10 AM
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):
JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED
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: 801-114775
(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
1657968
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 300114
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:
19/F, CHATER HOUSE 8 CONNAUGHT ROAD CENTRAL
City: State: Country: ZIP+4/Postal Code:
HONG KONG Hong Kong
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:
9:00AM - 6:00PM
(3) Telephone number at this location:
852-2800-2800
(4) Facsimile number at this location, if any:
852-3018-5379
(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?
1
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:
5493006DKST2MXVG4R57
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:
12/F TOWER1&2, AND 17/F TOWER2 THE QUAYSIDE, 77 HOI BUN ROAD, KWUN TONG
City: State: Country: ZIP+4/Postal Code:
HONG KONG Hong Kong
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
852-2800-2800 852-3018-5379
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:
How many employees perform investment advisory functions from this office location?
0
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://www.youtube.com/@jpmorganassetmanagement
Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/jpmorganassetmanagement/
Address of Website/Account on Publicly Available Social Media Platform: https://twitter.com/JPMorganAM
Address of Website/Account on Publicly Available Social Media Platform: https://am.jpmorgan.com/us/en/asset-management/
Address of Website/Account on Publicly Available Social Media Platform: https://www.facebook.com/jpmrich.family
Address of Website/Account on Publicly Available Social Media Platform: http://instagram.com/jpmorganassetmanagement
Address of Website/Account on Publicly Available Social Media Platform: https://line.me/ti/p/%40jpmorganfunds
Address of Website/Account on Publicly Available Social Media Platform: http://www.youtube.com/user/jpmamhk
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/user/JPMorganTouch
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/jpmamjp
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/channel/UCqg8LNFkgTSwbJlfqDOtaPg
Address of Website/Account on Publicly Available Social Media Platform: https://web.gim.jpmorgan.com/whatsapp-opt-in?country=hk
Address of Website/Account on Publicly Available Social Media Platform: https://www.douyin.com
Address of Website/Account on Publicly Available Social Media Platform: https://mp.weixin.qq.com/mp/profile_ext?action=home&__biz=MzA4MDQ4MzcxMw==&scene=123#wechat_redirect
Address of Website/Account on Publicly Available Social Media Platform: https://xiaohongshu.com
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:
JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED
Number and Street 1: Number and Street 2:
12/F TOWER 1&2, AND 17/F TOWER 2 THE QUAYSIDE, 77 HOI BUN ROAD, KWUN TONG
City: State: Country: ZIP+4/Postal Code:
HONG KONG Hong Kong
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
852-2800-2800 852-3018-5379
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.
BOOKS AND RECORDS RELATED TO: INVESTMENT AND TRADE RELATED RECORDS, INCLUDING PROXY VOTING FINANCIAL RECORDS; COMPLIANCE RELATED RECORDS, INCLUDING PERSONAL
SECURITIES TRANSACTIONS; CORPORATE SECRETARIAL RECORDS
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D Section 1.M. for each foreign
financial regulatory authority with whom you are registered.
Name of Country/Foreign Financial Regulatory Authority:
Hong Kong - Securities and Futures Commission
Other:
Name of Country/Foreign Financial Regulatory Authority:
Ireland - Central Bank of Ireland
Other:
Name of Country/Foreign Financial Regulatory Authority:
South Korea - Financial Supervisory Commission / Financial Supervisory Service
Other:
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
Hong Kong
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.
419
B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
62
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
0
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser representatives?
0
(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?
0
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
0
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
0
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?
33
(2) Approximately what percentage of your clients are non-United States persons?
97%
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) $
(b) High net worth individuals $
(c) Banking or thrift institutions $
(d) Investment companies 1 $ 175,667,726
(e) Business development companies $
(f) Pooled investment vehicles (other than investment companies and business 149 $ 149,259,253,227
development companies)
(g) Pension and profit sharing plans (but not the plan participants or government 21 $ 3,737,864,530
pension plans)
(h) Charitable organizations 3 $ 251,045,513
(i) State or municipal government entities (including government pension plans) 4 $ 1,493,772,751
(j) Other investment advisers 2 $ 467,808,217
(k) Insurance companies 12 $ 6,226,026,842
(l) Sovereign wealth funds and foreign official institutions 4 $ 2,405,566,739
(m) Corporations or other businesses not listed above 14 $ 5,606,636,397
(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) $ 169,623,641,942 (d) 268
Non-Discretionary: (b) $0 (e) 0
Total: (c) $ 169,623,641,942 (f) 268
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?
$ 168,595,022,762
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
$
(b) portfolio manager for a wrap fee program?
$
(c) sponsor to and portfolio manager for the same wrap fee program?
$
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
If you check Item 5.G.(3), what is the SEC file number (811 or 814 number) of each of the registered investment companies and business development companies to which you act as an
adviser pursuant to an advisory contract? You must complete a separate Schedule D Section 5.G.(3) for each registered investment company and business development company to which
you act as an adviser.
SEC File Number
811 - 04058
Provide the regulatory assets under management of all parallel managed accounts related to a registered investment company (or series thereof) or business development company that you
advise.
Series ID Parallel Managed Account Regulatory assets under management
$0
SECTION 5.I.(2) Wrap Fee Programs
No Information Filed
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 33 % 30 %
(ii) Non Exchange-Traded Equity Securities 0% 0%
(iii) U.S. Government/Agency Bonds 20 % 19 %
(iv) U.S. State and Local Bonds 0% 0%
(v) Sovereign Bonds 1% 1%
(vi) Investment Grade Corporate Bonds 15 % 13 %
(vii) Non-Investment Grade Corporate Bonds 1% 1%
(viii) Derivatives 0% 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 0% 0%
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies) 23 % 24 %
(xi) Cash and Cash Equivalents 6% 11 %
(xii) Other 1% 1%
Generally describe any assets included in "Other"
MORTGAGE ASSET BACKED
(b) Asset Type 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"
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
(a) Interest Rate (b) Foreign Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 1,190,711,971 $0 0% 0.75 % 0% 2.7 % 0% 0%
10-149% $ 7,371,446,324 $0 25.47 % 29.79 % 0% 9.23 % 1.97 % 0%
150% or more $ 7,848,395,429 $0 94.5 % 129.78 % 0% 2.18 % 0% 0%
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
(a) Interest Rate (b) Foreign Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 3,287,746,941 $0 0% 0.27 % 0% 2.75 % 0% 0%
10-149% $ 3,892,273,925 $0 21.23 % 28.5 % 0% 12.3 % 3.67 % 0%
150% or more $ 9,695,272,927 $0 104.12 % 104.72 % 0% 29.52 % 0% 0%
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% $0 $0
10-149% $0 $0
150% or more $0 $0
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:
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
(b) Primary business name of custodian:
JPMORGAN CHASE BANK, NA
(c) The location(s) of the custodian's office(s) responsible for custody of the assets :
City: State: Country:
COLUMBUS Ohio 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)
-
(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)
7H6GLXDRUGQFU57RNE97
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 6,351,186,083
(a) Legal name of custodian:
STATE STREET CORPORATION
(b) Primary business name of custodian:
STATE STREET CORPORATION
(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)
-
(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)
549300ZFEEJ2IP5VME73
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 2,791,379,512
(a) Legal name of custodian:
CITIGROUP GLOBAL MARKETS INC.
(b) Primary business name of custodian:
CITIGROUP GLOBAL MARKETS INC.
(c) The location(s) of the custodian's office(s) responsible for custody of the assets :
City: State: Country:
NEW YORK New York 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)
-
(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)
MBNUM2BPBDO7JBLYG310
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 3,609,780,639
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.
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:
JPMORGAN FUNDS LIMITED
2. Primary Business Name of Related Person:
JPMORGAN FUNDS LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 80071
or
Other
4. Related Person's
(a) CRD Number (if any):
172045
(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.
Name of Country/English Name of Foreign Financial Regulatory Authority
United Kingdom - Financial Conduct Authority
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:
JPMORGAN FUNDS (ASIA) LIMITED
2. Primary Business Name of Related Person:
JPMORGAN FUNDS (ASIA) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
54930038LF43WPERUD
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?
FOREIGN INVESTMENT ADVISER WITH NO U.S. CLIENTS
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
Hong Kong - Securities and Futures Commission
Other - HONG KONG - MANDATORY PROVIDENT FUND AUTHORITY
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:
JPMORGAN INVESTMENT ADVISORS (KOREA) COMPANY LIMITED
2. Primary Business Name of Related Person:
JPMORGAN INVESTMENT ADVISORS (KOREA) COMPANY LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
5493002IVFFIGK5LL7
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?
PARTICIPATING AFFILIATE RELYING ON UNIAO DE BANCOS BRASILEIROS SA, NO-ACTION LETTER (JUL. 28, 1992) AND SUBSEQUENT LETTERS.
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
South Korea - Financial Supervisory Commission / Financial Supervisory Service
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:
JPMORGAN CHASE BANK, N.A.
2. Primary Business Name of Related Person:
JPMORGAN CHASE BANK, N.A.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
7H6GLXDRUGQFU57RNE
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
CIK Number
835271
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?
SECTION 202(A)(11) OF THE INVESTMENT ADVISERS ACT OF 1940
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
Australia - Australian Securities and Investments Commission
Belgium - Banking, Finance and Insurance Commission
Brazil - Securities and Exchange Commission
Canada - Ontario Securities Commission
China, People's Republic of - China Securities Regulatory Commission
Dubai - Dubai Financial Services Authority
Germany - German Federal Financial Supervisory Agency
Hong Kong - Securities and Futures Commission
Japan - Financial Services Agency
Jersey - Jersey Financial Services Commission
Other - HONG KONG - HONG KONG MONETARY AUTHORITY
Other - OTHER - ARGENTINA - BANCO CENTRAL DE LA REPUBLICA DE ARGENTINA INSPECCION GENERAL DE JUSTICA
Other - OTHER - AUSTRALIA - COMMONWEALTH DEPARTMENT OF THE TREASURY
Other - OTHER - BAHAMAS - CENTRAL BANK OF THE BAHAMAS
Other - OTHER - BAHRAIN - BAHRAIN MONETARY AUTHORITY
Other - OTHER - BEIJING - BEIJING ADMINISTRATION FOR INDUSTRY AND COMMERCE
Other - OTHER - BRAZIL - CENTRAL BANK OF BRAZIL
Other - OTHER - CANADA - OFFICE OF THE SUPERINTENDENT OF FINANCIAL INSTITUTIONS
Other - OTHER - CHILE - BANCO CENTRAL DE CHILE SUPERINTENDENCIA DE BANCOS E INSTITUCIONES FINANCIERAS
Other - OTHER - FRANCE - BANQUE DE FRANCE
Other - OTHER - INDIA - RESERVE BANK OF INDIA
Other - OTHER - INDONESIA - BANK OF INDONESIA
Other - OTHER - INDONESIA - MINISTRY OF FINANCE
Other - OTHER - ITALY - BANK OF ITALY
Other - OTHER - MALAYSIA - LABUAN OFFSHORE FINANCIAL SERVICES AUTHORITY
Other - OTHER - NETHERLANDS - NEDERLANDSE BANK NV CENTRAL BANK
Other - OTHER - NETHERLANDS - NEDERLANDSE VERENIGING VAN BANKEN (DUTCH ASSOCIATION OF BANKS)
Other - OTHER - NEW ZEALAND - RESERVE BANK OF NEW ZEALAND
Other - OTHER - PHILIPPINES - BANGKO SENTRAL NG PILIPINAS (CENTRAL BANK)
Other - OTHER - QATAR - QATAR FINANCIAL CENTRAL REGULATORY AUTHORITY
Other - OTHER - SAUDIA ARABIA - MINISTRY OF COMMERCE
Other - OTHER - SOUTH AFRICA - SOUTH AFRICA RESERVE BANK
Other - OTHER - SOUTH KOREA - MINISTRY OF FINANCE AND ECONOMY
Other - OTHER - SPAIN - BANK OF SPAIN
Other - OTHER - SWITZERLAND - FEDERAL BANKING COMMISSION
Other - OTHER - TAIWAN - CENTRAL BANK OF CHINA
Other - OTHER - THAILAND - THE BANK OF THAILAND
Other - OTHER - TURKEY - MINISTRY OF TRADE REGISTRY
Other - OTHER - VIETNAM - STATE BANK OF VIETNAM
Singapore - Monetary Authority of Singapore
South Korea - Financial Supervisory Commission / Financial Supervisory Service
Taiwan - Financial Supervisory Commission
Thailand - Securities and Exchange Commission
United Kingdom - Financial Conduct Authority
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:
JPMORGAN ASSET MANAGEMENT (TAIWAN) LIMITED
2. Primary Business Name of Related Person:
JPMORGAN ASSET MANAGEMENT (TAIWAN) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
5493007XKH607S1KJV
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?
PARTICIPATING AFFILIATE RELYING ON UNIAO DE BANCOS BRASILEIROS SA, NO-ACTION LETTER (JUL. 28, 1992) AND SUBSEQUENT LETTERS.
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
Taiwan - Financial Supervisory Commission
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:
J.P. MORGAN INVESTMENT MANAGEMENT INC.
2. Primary Business Name of Related Person:
J.P. MORGAN INVESTMENT MANAGEMENT INC.
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 21011
or
Other
4. Related Person's
(a) CRD Number (if any):
107038
(b) CIK Number(s) (if any):
CIK Number
741611
928121
1173475
1363391
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
India - Securities and Exchange Board of India
Japan - Financial Services Agency
South Korea - Financial Supervisory Commission / Financial Supervisory Service
United Kingdom - Financial Conduct Authority
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:
JPMORGAN ASSET MANAGEMENT (JAPAN) LIMITED
2. Primary Business Name of Related Person:
JPMORGAN ASSET MANAGEMENT (JAPAN) LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
549300TNMIIYQ6ZC45
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?
PARTICIPATING AFFILIATE RELYING ON UNIAO DE BANCOS BRASILEIROS SA, NO-ACTION LETTER (JUL. 28, 1992) AND SUBSEQUENT LETTERS
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.
Name of Country/English Name of Foreign Financial Regulatory Authority
Japan - Financial Services Agency
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
1. Name of the private fund:
CHINA A-SHARE EQUITY FUND LLC
2. Private fund identification number:
(include the "805-" prefix also)
805-4075225659
3. Name and SEC File number of adviser that provides information about this private fund in Section 7.B.(1) of Schedule D of its Form ADV filing
Name:
J.P. MORGAN INVESTMENT MANAGEMENT INC.
SEC File Number:
801 - 21011
Yes No
4. Are your clients solicited to invest in this private fund?
In answering this question, disregard feeder funds' investment in a master fund. For purposes of this question, in a master-feeder arrangement, one or more funds ("feeder funds")
invest all or substantially all of their assets in a single fund ("master fund"). A fund would also be a "feeder fund" investing in a "master fund" for purposes of this question if it issued
multiple classes (or series) of shares or interests, and each class (or series) invests substantially all of its assets in a single master fund.
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) $ (b)
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:
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?
SECTION 9.C. Independent Public Accountant
No Information Filed
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
No Information Filed
SECTION 10.B. Control Person Public Reporting Companies
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
provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting company):
(1) Full legal name of the public reporting company: JPMORGAN CHASE & CO
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company): 19617
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 Name, DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of Birth,
First Name, Middle Name) Acquired MM/YYYY Code Person IRS Tax No. or Employer ID No.
JPMORGAN ASSET MANAGEMENT (ASIA) INC. DE SHAREHOLDER 11/2001 E Y N
Chan, Edwin, Tsun Kay I DIRECTOR/MANAGING DIRECTOR 12/2010 NA Y N 6663205
Thomas, Chloe, Louise I DIRECTOR/MANAGING DIRECTOR 03/2018 NA Y N 7069607
WATKINS, DANIEL, JAMES I DIRECTOR/MANAGING DIRECTOR 03/2019 NA Y N 6178182
DeBurca, Stiofan, Seamus I DIRECTOR / MANAGING DIRECTOR 05/2021 NA Y N 7396580
Tan Ai Li, Jacqueline I CHIEF COMPLIANCE OFFICER / 07/2021 NA Y N 7421809
MANAGING DIRECTOR
SPELMAN, CHRISTOPHER, DAVID I DIRECTOR / MANAGING DIRECTOR 04/2024 NA Y N 6453168
YUN, SOHEE I ASSISTANT GENERAL COUNSEL / 07/2014 NA N N 8061378
PRIMARY LEGAL CONTACT
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.
FULL LEGAL NAME (Individuals: Last Name, DE/FE/I Entity in Which Interest is Status Date Status Ownership Control PR CRD No. If None: S.S. No. and Date of
First Name, Middle Name) Owned Acquired Code Person Birth, IRS Tax No. or Employer ID No.
MM/YYYY
JPMORGAN ASSET MANAGEMENT HOLDINGS DE JPMORGAN ASSET SHAREHOLDER 06/2001 E Y N
INC. MANAGEMENT (ASIA) INC.
JPMORGAN CHASE HOLDINGS LLC DE JPMORGAN ASSET SHAREHOLDER 04/2017 E Y N
MANAGEMENT HOLDINGS
INC.
JPMORGAN CHASE & CO. DE JPMORGAN CHASE HOLDINGS SHAREHOLDER 09/2016 E Y Y
LLC
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Section 1.I of Schedule D – The Adviser markets its investment advisory services through the marketing name, J.P. Morgan Asset Management, which has a global geotargeted handle on
LinkedIn that redirects users in each country to content applicable to their location. In the normal course of business, the Adviser does not market or promote its investment advisory
services to U.S. residents or investors. If a decision is made to market or promote investment advisory services to U.S. residents or investors, such marketing is delivered through the U.S.
web portal and U.S. social media handles. For jurisdictions outside the U.S., the Adviser has websites and social media handles that are used to market products and services in foreign
jurisdictions where the Adviser is also registered. Item 5 - The methodology for calculating assets for the Form ADV may be different from the methodology used in other external reporting,
due to differences in the applicable requirements for such reports. Section 5.K.(3) – In responding to this Section, the Adviser has, to the best of its knowledge, combined the affiliated
entities of each custodian that holds ten percent or more of the Adviser's aggregate separately managed account regulatory assets under management. Item 9 and Section 7.A of Schedule
D - The Adviser is a non-U.S. adviser with U.S. and non-U.S. clients. Therefore, the Adviser has responded to custody-related questions with respect to its U.S. clients only. Section 7.A of
Schedule D - The Adviser is a non-U.S. adviser with U.S. and non-U.S. clients. Therefore, the Adviser has responded to this Section with respect to its U.S. clients only. The Adviser has related
persons that are not included in Section 7.A of Schedule D because the Adviser (1) has no business dealings with the related person in connection with advisory services the Adviser provides
to the Adviser's clients; (2) does not conduct shared operations with the related person; (3) does not refer clients or business to the related person, and the related person does not refer
prospective clients or business to the Adviser; (4) does not share supervised persons or premises with the related person; and (5) has no reason to believe that the Adviser's relationship
with the related person otherwise creates a conflict of interest with the Adviser's clients. A supplementary list of these related persons is available on request.
Schedule R
No Information Filed
DRP Pages
CRIMINAL 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.A. or 11.B. of Form ADV.
OR
Criminal
Check item(s) being responded to:
11.A(1) 11.A(2) 11.B(1) 11.B(2)
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.
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate cases arising out of the same event,
must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may result in more than one affirmative answer to the items listed above.
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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.
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. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not the organization was an
investment-related business and your or the advisory affiliate's position, title, or relationship.
JPMORGAN CHASE & CO. ("JPMC")
2. Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case number).
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ("DISTRICT COURT"), 3:15-CR-79 (SRU)
3. Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY):
05/20/2015 Exact Explanation
If not exact, provide explanation:
B. Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor, (3) plea for each charge, and (4)
product type if charge is investment-related).
JPMC WAS CHARGED WITH A ONE COUNT FELONY CRIME CHARGE IN VIOLATION OF THE SHERMAN ANTITRUST ACT, 15 U.S.C. SECTION 1 RELATING TO THE FOREIGN CURRENCY
EXCHANGE SPOT MARKET ("FX SPOT MARKET"). JPMC PLED GUILTY PURSUANT TO A PLEA AGREEMENT WITH THE DOJ.
C. Did any of the Charge(s) within the Event involve a ?
felony Yes No
D. Current status of the Event? Pending On Appeal Final
E. Event Status Date (complete unless status is Pending) (MM/DD/YYYY):
01/10/2017 Exact Explanation
If not exact, provide explanation:
4. Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if sentence - suspension, probation,
etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
JPMC ENTERED A GUILTY PLEA ON MAY 20, 2015 PURSUANT TO A PLEA AGREEMENT WITH THE DOJ. JPMC AGREED TO PAY A CRIMINAL FINE OF $550 MILLION AND A MANDATORY
ASSESSMENT OF $400. JPMC AGREED TO BE SUBJECT TO PROBATION FOR 3 YEARS. ON JANUARY 10, 2017 JUDGMENT WAS ENTERED CONSISTENT WITH THE TERMS OF THE PLEA
AGREEMENT. THE FINE WAS PAID ON JANUARY 17, 2017.
5. Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was the subject of the charge(s)
occurred. (Your response must fit within the space provided.)
ON MAY 20, 2015, THE DOJ FILED A CRIMINAL INFORMATION IN THE DISTRICT COURT CHARGING JPMC WITH A ONE COUNT CRIME CHARGE IN VIOLATION OF THE SHERMAN ANTITRUST
ACT, 15 U.S.C. § 1 (THE "INFORMATION"). THE INFORMATION CHARGES THAT, FROM JULY 2010 UNTIL AT LEAST JANUARY 2013, JPMC, THROUGH ONE OF ITS EURO/U.S. DOLLAR
("EUR/USD") TRADERS, ENTERED INTO AND ENGAGED IN A CONSPIRACY TO FIX, STABILIZE, MAINTAIN, INCREASE OR DECREASE THE PRICE OF, AND RIG BIDS AND OFFERS FOR, THE
EUR/USD CURRENCY PAIR EXCHANGED IN THE FX SPOT MARKET BY AGREEING TO ELIMINATE COMPETITION IN THE PURCHASE AND SALE OF THE EUR/USD CURRENCY PAIR IN THE U.S.
AND ELSEWHERE.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.A. or 11.B. of Form ADV.
OR
Criminal
Check item(s) being responded to:
11.A(1) 11.A(2) 11.B(1) 11.B(2)
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.
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate cases arising out of the same event,
must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may result in more than one affirmative answer to the items listed above.
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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.
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. If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not the organization was an
investment-related business and your or the advisory affiliate's position, title, or relationship.
2. Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case number).
UNITED STATES DISTRICT COURT, DISTRICT OF CONNECTICUT
3. Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY):
09/29/2020 Exact Explanation
If not exact, provide explanation:
B. Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor, (3) plea for each charge, and (4)
product type if charge is investment-related).
2 COUNTS OF WIRE FRAUD, IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1343
C. Did any of the Charge(s) within the Event involve a ?
felony Yes No
D. Current status of the Event? Pending On Appeal Final
E. Event Status Date (complete unless status is Pending) (MM/DD/YYYY):
09/29/2020 Exact Explanation
If not exact, provide explanation:
4. Disposition Disclosure Detail:
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if sentence - suspension, probation,
etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid.
DEFERRED PROSECUTION AGREEMENT ~$920MM PENALTY WAS PAID ON OCT. 9TH AND THE FIRM IS REQUIRED TO COMPLY WITH THE OBLIGATIONS SET FORTH IN THE DEFERRED
PROSECUTION AGREEMENT FOR A PERIOD OF 3 YEARS
5. Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was the subject of the charge(s)
occurred. (Your response must fit within the space provided.)
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., 11.F. or 11.G. of Form ADV.
OR
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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 NEW HAMPSHIRE BUREAU OF SECURITIES REGULATION
2. Principal Sanction:
Restitution
Other Sanctions:
IN ADDITION TO THE AGREEMENT TO REPURCHASE CERTAIN AUCTION RATE SECURITIES ("ARS") SOLD TO ELIGIBLE INVESTORS PRIOR TO FEBRUARY 13, 2008, THE SETTLEMENT CALLS
FOR THE REIMBURSEMENT OF ELIGIBLE INVESTORS WHO SOLD ARS BELOW PAR, REFUNDING OF CERTAIN LOAN EXPENSES INCURRED BY ELIGIBLE INVESTORS, SPECIAL ARBITRATION
PROCEEDINGS CONCERNING CONSEQUENTIAL DAMAGES WITH RESPECT TO ARS, REFUNDING CERTAIN REFINANCING FEES INCURRED BY MUNICIPAL ISSUERS OF ARS AND A CIVIL
PENALTY.
3. Date Initiated (MM/DD/YYYY):
01/03/2017 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
12009000013
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Other
Other Product Types:
AUCTION RATE SECURITIES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE INVESTIGATION CONCERNED ALLEGED MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE SECURITIES.
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):
01/03/2017 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: $ 97,706.22
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
IN ADDITION TO THE AGREEMENT TO REPURCHASE CERTAIN AUCTION RATE SECURITIES ("ARS") SOLD TO ELIGIBLE INVESTORS PRIOR TO FEBRUARY 13, 2008, THE SETTLEMENT
CALLS FOR THE REIMBURSEMENT OF ELIGIBLE INVESTORS WHO SOLD ARS BELOW PAR, REFUNDING OF CERTAIN LOAN EXPENSES INCURRED BY ELIGIBLE INVESTORS, SPECIAL
ARBITRATION PROCEEDINGS CONCERNING CONSEQUENTIAL DAMAGES WITH RESPECT TO ARS, REFUNDING CERTAIN REFINANCING FEES INCURRED BY MUNICIPAL ISSUERS OF
ARS AND A CIVIL PENALTY.
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:
WITHOUT ADMITTING OR DENYING THE FINDINGS, JPMORGAN CHASE & CO CONSENTED TO A FINE OF $97706.22 WHICH WAS PAID ON 01/04/2017. THE FINE REPRESENTS THE
NEW HAMPSHIRE PORTION OF A TOTAL FINE OF $25 MILLION NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION ON BEHALF OF THE
NASAA TASK FORCE. THE REMAINING AMOUNT WILL BE PAID SEPARATELY TO OTHER STATES. ALSO PAID WAS $15,000 TO NASAA AS REIMBURSEMENT FOR INVESTIGATIVE COSTS
INCURRED BY NASAA.
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).
THE ACTION RELATED TO ALLEGATIONS WITH RESPECT TO MISREPRESENTATIONS AND OMISSIONS IN CONNECTION WITH THE MARKETING, SALE AND DISTRIBUTION OF AUCTION RATE
SECURITIES. AS DESCRIBED HEREIN, THE PRINCIPAL TERMS OF THE SETTLEMENT WERE NEGOTIATED WITH THE NYAG AND THE STATE OF FLORIDA OFFICE OF FINANCIAL REGULATION
ON BEHALF OF THE NASAA TASK FORCE THAT CONTEMPLATES SEPARATE SIMILAR AGREEMENTS WITH OTHER STATES.
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., 11.F. or 11.G. of Form ADV.
OR
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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)
SEC
2. Principal Sanction:
Cease and Desist
Other Sanctions:
DISGORGEMENT, PRE-JUDGMENT INTEREST, AND UNDERTAKINGS
3. Date Initiated (MM/DD/YYYY):
11/17/2016 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
ADMINISTRATIVE PROCEEDING FILE NO. 3-17684
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE SECURITIES AND EXCHANGE COMMISSION ("SEC") UNDER WHICH JPMC
CONSENTED TO THE ENTRY OF AN ORDER (THE "ORDER") THAT FINDS THAT JPMC VIOLATED SECTIONS 13(B)(2)(A), 13(B)(2)(B) AND 30A OF THE SECURITIES EXCHANGE ACT OF 1934
("EXCHANGE ACT"). THE ORDER FINDS THAT JPMC VIOLATED THE ANTI-BRIBERY PROVISIONS OF THE FEDERAL SECURITIES LAWS BY CORRUPTLY PROVIDING VALUABLE INTERNSHIPS
AND EMPLOYMENT TO RELATIVES AND FRIENDS OF FOREIGN GOVERNMENT OFFICIALS ("REFERRAL HIRES") IN ORDER TO ASSIST JPMC IN RETAINING AND OBTAINING BUSINESS. IN
ADDITION, THE ORDER FINDS THAT JPMC VIOLATED THE BOOKS AND RECORDS PROVISIONS AND THE INTERNAL ACCOUNTING CONTROLS PROVISIONS OF THE FOREIGN CORRUPT
PRACTICES ACT ("FCPA") IN CONJUNCTION WITH CERTAIN REFERRAL HIRES.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
11/17/2016 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:
UNDERTAKINGS
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:
THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF THE ABOVE-ENUMERATED STATUTORY
PROVISIONS. ADDITIONALLY, THE ORDER REQUIRES JPMC TO PAY A TOTAL OF $105,507,668 IN DISGORGEMENT AND PREJUDGMENT INTEREST OF $25,083,737, WHICH WAS PAID
ON NOVEMBER 27, 2016. IN ADDITION, JPMC WAS ORDERED TO COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING REPORTING TO THE SEC STAFF PERIODICALLY, AT NO LESS
THAN NINE-MONTH INTERVALS DURING A THREE-YEAR TERM, THE STATUS OF JPMC'S REMEDIATION AND IMPLEMENTATION OF COMPLIANCE MEASURES RELATING TO FCPA AND
APPLICABLE ANTI-CORRUPTION LAWS, AND CERTIFYING THAT JPMC HAS MADE A GOOD FAITH EFFORT TO COMPLY WITH THE UNDERTAKINGS. THE SEC DID NOT IMPOSE A CIVIL
PENALTY BASED UPON THE IMPOSITION OF A $72,000,000 CRIMINAL FINE AS PART OF JPMORGAN SECURITIES (ASIA PACIFIC) LIMITED'S ("JPMORGAN APAC") SETTLEMENT WITH
THE UNITED STATES DEPARTMENT OF JUSTICE.
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).
SOLELY FOR THE PURPOSE OF SETTLING THESE PROCEEDINGS, JPMC ADMITTED THE SEC'S JURISDICTION AND THE SUBJECT MATTER OF THESE PROCEEDINGS AND CONSENTED TO THE
ORDER. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12. IN COORDINATION WITH THE SEC SETTLEMENT, JPMC
AND CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH OTHER AGENCIES TO RESOLVE CONCURRENT INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE
SETTLEMENTS ARE AS FOLLOWS: JPMORGAN APAC ENTERED INTO A NON-PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE THAT ACKNOWLEDGES RESPONSIBILITY FOR
CRIMINAL CONDUCT RELATING TO CERTAIN FINDINGS IN THE ORDER AND THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ENTERED AN ADMINISTRATIVE CEASE-AND-
DESIST ORDER AGAINST JPMC.
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., 11.F. or 11.G. of Form ADV.
OR
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
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: JPMORGAN ASSET MANAGEMENT
(TAIWAN) LIMITED
(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)
TAIWAN FINANCIAL SUPERVISORY COMMISSION
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
RECTIFICATION
3. Date Initiated (MM/DD/YYYY):
02/05/2018 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
N/A
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Other
Other Product Types:
FINANCE AND COMPLIANCE CONTROLS
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON FEBRUARY 5, 2018, THE TAIWAN FINANCIAL SUPERVISORY COMMISSION ("FSC") ISSUED A PUBLIC NOTICE OF ITS IMPOSITION OF A SANCTION OF RECTIFICATION AND AN
ADMINISTRATIVE PENALTY ("SANCTION") AGAINST JPMORGAN ASSET MANAGEMENT (TAIWAN) LIMITED ("JPMAM TAIWAN") BECAUSE JPMAM TAIWAN, HAD NOT EFFECTIVELY ESTABLISHED
A MECHANISM TO REVIEW TRAINING AND MARKETING EVENTS AND TO APPROVE AND REPORT EXPENSES. THE SANCTION IMPOSED AN ADMINISTRATIVE PENALTY UNDER ARTICLE 2(2) OF
THE REGULATIONS GOVERNING SECURITIES INVESTMENT TRUST ENTERPRISES, ARTICLE 13 OF REGULATIONS GOVERNING THE RESPONSIBLE PERSONNEL AND BUSINESS PERSONNEL OF
SECURITIES INVESTMENT TRUST ENTERPRISES, ARTICLE 6(2) OF THE STANDARDS GOVERNING THE ESTABLISHMENT OF INTERNAL CONTROL SYSTEMS BY SERVICE ENTERPRISES IN
SECURITIES AND FUTURES MARKETS, AS WELL AS ARTICLES 102 AND 111(7) OF THE SECURITIES INVESTMENT TRUST AND CONSULTING ACT. THE FSC DETERMINED THAT JPMAM TAIWAN
HAD NOT IMPLEMENTED EFFECTIVE INTERNAL CONTROL SYSTEMS AND ADEQUATELY SUPERVISED ITS EMPLOYEES.
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:
Decision
11. Resolution Date (MM/DD/YYYY):
02/05/2018 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: $ 40,900.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
JPMAM TAIWAN SHALL (1) IMPLEMENT REMEDIAL MEASURES APPROVED BY ITS BOARD OF DIRECTORS, AND REGULARLY REPORT ON THE PROGRESS TO THE BOARD SUPERVISOR;
(2) ENGAGE AN ACCOUNTING FIRM TO REVIEW THE COMPANY'S IMPLEMENTATION OF ITS INTERNAL CONTROL ENHANCEMENTS; AND (3) UNTIL THE CONTROLS REVIEW IS
COMPLETE AND THE FSC IS SATISFIED THAT THE NOTED DEFICIENCIES HAVE BEEN REMEDIATED, THE FSC WILL NOT ACCEPT FROM JPMAM TAIWAN APPLICATIONS OR REPORTS OF
ONSHORE FUND OFFERINGS OR PLACEMENTS (INCLUDING FOLLOW-ON OFFERINGS / PLACEMENTS) AND OFFSHORE FUNDS SALES CASES.
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:
IN THE SANCTION, JPMAM TAIWAN WAS REQUIRED TO PAY AN ADMINISTRATIVE PENALTY NT$1.2 MILLION (~USD 40,900), WHICH IT PAID ON FEBRUARY 13, 2018.
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).
THE ALLEGED CONDUCT DOES NOT RELATE IN ANY WAY TO THE REGISTRANT'S INVESTMENT ADVISER BUSINESS. THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE
SANCTION ARE DESCRIBED ABOVE IN ITEMS 7 AND 12.
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., 11.F. or 11.G. of Form ADV.
OR
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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)
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM
2. Principal Sanction:
Cease and Desist
Other Sanctions:
CIVIL MONEY PENALTY AND UNDERTAKINGS
3. Date Initiated (MM/DD/YYYY):
11/17/2016 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
16-22-B-HC AND 16-22-CMP-HC
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON NOVEMBER 17, 2016, JPMORGAN CHASE & CO. ("JPMC") ENTERED INTO A SETTLEMENT WITH THE BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM ("FRB") RESULTING IN
THE FRB ISSUING AN ORDER ("ORDER"). THE ORDER FINDS THAT FROM AT LEAST 2008 THROUGH 2013, JPMC'S ASIA-PACIFIC REGION INVESTMENT BANKING GROUP OPERATED A
REFERRAL HIRING PROGRAM WHEREBY CANDIDATES WHO WERE REFERRED, DIRECTLY OR INDIRECTLY, BY FOREIGN GOVERNMENT OFFICIALS AND EXISTING OR PROSPECTIVE
COMMERCIAL CLIENTS, AND WHO IN MOST INSTANCES WERE LESS QUALIFIED THAN NON-REFERRED CANDIDATES WHO WERE HIRED THROUGH THE JPMC'S STANDARD HIRING
PROGRAMS, WERE OFFERED INTERNSHIPS, TRAINING, AND OTHER EMPLOYMENT OPPORTUNITIES IN ORDER TO OBTAIN IMPROPER BUSINESS ADVANTAGES FOR JPMC.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
11/17/2016 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: $ 61,932,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
UNDERTAKINGS
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:
THE ORDER DIRECTS JPMC TO CEASE-AND-DESIST AND TO PAY A CIVIL MONEY PENALTY OF $61,932,500, WHICH WAS PAID ON NOVEMBER 17, 2016. IN ADDITION, THE ORDER
REQUIRES JPMC TO TAKE THE FOLLOWING STEPS: A) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR IMPLEMENTATION, TO IMPROVE SENIOR MANAGEMENT'S
OVERSIGHT OF JPMC'S FIRM-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO COMPLIANCE WITH APPLICABLE U.S. LAWS AND REGULATIONS AND APPLICABLE
INTERNAL POLICIES AND PROCEDURES IN CONNECTION WITH THE FIRM'S HIRING OF CANDIDATES WHO WERE REFERRED, DIRECTLY OR INDIRECTLY, BY FOREIGN GOVERNMENT
OFFICIALS AND EXISTING OR PROSPECTIVE COMMERCIAL CLIENTS ("REFERRAL HIRING PRACTICES"); B) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE FOR
IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF JPMC'S FIRM-WIDE COMPLIANCE RISK MANAGEMENT PROGRAM WITH REGARD TO THE OVERSIGHT AND IMPLEMENTATION
OF ANTI-BRIBERY PROCESSES AND PROCEDURES IN CONNECTION WITH THE FIRM'S REFERRAL HIRING PRACTICES; AND C) SUBMIT AN ACCEPTABLE WRITTEN PLAN, AND TIMELINE
FOR IMPLEMENTATION, TO ENHANCE THE EFFECTIVENESS OF THE FIRM'S COMPLIANCE WITH INTERNAL POLICIES AND PROCEDURES AS WELL AS APPLICABLE U.S. LAWS AND
REGULATIONS IN ITS REFERRAL HIRING PRACTICES.
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).
THE ALLEGATIONS, DISPOSITIONS, FINDINGS AND SANCTIONS OF THE ORDER ARE DESCRIBED ABOVE IN ITEMS 7 AND 12. IN COORDINATION WITH THE FRB SETTLEMENT, JPMC AND
CERTAIN OF ITS AFFILIATES ALSO ENTERED INTO SETTLEMENTS WITH OTHER AGENCIES TO RESOLVE CONCURRENT INVESTIGATIONS ARISING OUT OF THE SAME CONDUCT. THOSE
SETTLEMENTS ARE AS FOLLOWS: JPMORGAN APAC ENTERED INTO A NON-PROSECUTION AGREEMENT WITH THE DEPARTMENT OF JUSTICE AND CONSENTED TO THE ISSUANCE OF A
CRIMINAL FINE FOR VIOLATIONS OF FEDERAL ANTI-BRIBERY LAWS AND THE U.S. SECURITIES AND EXCHANGE COMMISSION ENTERED AN ADMINISTRATIVE CEASE-AND-DESIST ORDER
AGAINST JPMC FINDING VIOLATIONS OF FEDERAL ANTI-BRIBERY AND SECURITIES LAWS.
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., 11.F. or 11.G. of Form ADV.
OR
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 EXCHANGE BOARD OF INDIA
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
01/15/2019 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
N/A
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") ALLEGED THAT JPMORGAN ASSET MANAGEMENT (ASIA PACIFIC) LIMITED (JPMAM(AP)), THEN KNOWN AS JF ASSET
MANAGEMENT LIMITED, VIOLATED REGULATION 19(2) OF THE SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2012
RESCINDED AND REPLACED WITH SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2018.
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:
Other
11. Resolution Date (MM/DD/YYYY):
03/05/2019 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: $ 7,500.00
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:
ON FEBRUARY 11, 2019, JPMAM(AP) ACCEPTED THE PROPOSED SETTLEMENT AND PAID THE SETTLEMENT AMOUNT OF 515,625 RUPEES (APPROXIMATELY $7,500).
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 MARCH 5, 2019 THE SECURITIES AND EXCHANGE BOARD OF INDIA ("SEBI") PASSED A SETTLEMENT ORDER REGARDING THE LATE APPLICATION TO ACQUIRE SHARES IN MULTI
COMMODITY EXCHANGE OF INDIA LIMITED ("MCX"), A RECOGNIZED STOCK EXCHANGE IN INDIA. PURSUANT TO REGULATION 19(2) OF THE SECURITIES CONTRACTS (REGULATION)
(STOCK EXCHANGES AND CLEARING CORPORATIONS) REGULATIONS, 2012 RESCINDED AND REPLACED WITH SECURITIES CONTRACTS (REGULATION) (STOCK EXCHANGES AND
CLEARING CORPORATIONS) REGULATIONS, 2018, JPMAM(AP) WAS REQUIRED TO APPLY FOR SEBI'S APPROVAL WITHIN FIFTEEN DAYS OF ITS AGGREGATED SHAREHOLDING
REPRESENTING GREATER THAN 2% OF MCX. JPMAM(AP), ON BEHALF OF CERTAIN CLIENT ACCOUNTS, ACQUIRED SHARES REPRESENTING IN AGGREGATE GREATER THAN 2% OF MCX ON
JANUARY 27, 2017 AND, UPON REALIZING THE INADVERTENT OMISSION IN SEEKING APPROVAL FROM SEBI, JPMAM(AP) SUBMITTED THE APPLICATION FOR APPROVAL ON FEBRUARY 28,
2018. SEBI GRANTED APPROVAL ON APRIL 23, 2018. ON JANUARY 15, 2019 SEBI ISSUED A NOTICE OF SUMMARY SETTLEMENT REGARDING THE ABOVE MATTER. ON FEBRUARY 11, 2019,
JPMAM(AP) ACCEPTED THE PROPOSED SETTLEMENT AND PAID THE SETTLEMENT AMOUNT OF 515,625 RUPEES (APPROXIMATELY $7,500).
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., 11.F. or 11.G. of Form ADV.
OR
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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)
COMMODITY FUTURES TRADING COMMISSION
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
UNDERTAKINGS
3. Date Initiated (MM/DD/YYYY):
09/29/2020 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
CFTC DOCKET NO. 20-69
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Futures - Commodity
Other Product Types:
PRECIOUS METALS, FUTURES CONTRACTS, AND U.S. TREASURY FUTURES
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CFTC ENTERED AN ORDER RESOLVING AN ACTION AGAINST JPMORGAN CHASE & CO., AN AFFILIATED BANK (THE "BANK") AND AN AFFILIATED BROKER-DEALER (THE "BROKER-
DEALER") (COLLECTIVELY, "JPM"). ACCORDING TO THE ORDER, FROM AT LEAST 2008 THROUGH 2016, NUMEROUS TRADERS ON THE PRECIOUS METALS AND U.S. TREASURIES TRADING
DESKS AT THE BANK AND THE BROKER-DEALER ENGAGED IN A MANIPULATIVE AND DECEPTIVE SCHEME BY ENGAGING IN THE PRACTICE OF "SPOOFING" (BIDDING OR OFFERING WITH
THE INTENT TO CANCEL THE BID OR OFFER BEFORE EXECUTION) WHILE PLACING ORDERS FOR FUTURES CONTRACTS ON A REGISTERED ENTITY, RESULTING IN SIGNIFICANT BENEFIT TO
THEMSELVES AND HARM TO OTHER MARKET PARTICIPANTS. BY VIRTUE OF THIS CONDUCT, JPM ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN VIOLATION OF SECTION
9(A)(2) OF THE ACT, 7 U.S.C. § 13(A)(2) (2018); FOR CONDUCT OCCURRING ON OR AFTER JULY 16, 2011, ENGAGED IN SPOOFING IN VIOLATION OF SECTION 4C(A)(5)(C) OF THE ACT, 7
U.S.C. § 6C(A)(5)(C) (2018); AND FOR CONDUCT OCCURRING ON OR AFTER AUGUST 15, 2011, ENGAGED IN MANIPULATION AND ATTEMPTED MANIPULATION IN VIOLATION OF SECTION
6(C)(1) AND 6(C)(3) OF THE ACT, 7 U.S.C. § 9(1), (3) (2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019). FURTHER, IN CONJUNCTION
WITH THE ABOVEREFERENCED MISCONDUCT, THE BROKERDEALER FAILED TO DILIGENTLY SUPERVISE IN VIOLATION OF COMMISSION REGULATION 166.3, 17 C.F.R. § 166.3 (2019).
THE BANK AND THE BROKER-DEALER DO NOT CONTROL, NOR ARE THEY CONTROLLED BY, THE ADVISER.
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:
Settled
11. Resolution Date (MM/DD/YYYY):
09/29/2020 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: $ 436,431,811.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
UNDERTAKINGS
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:
THE ORDER DIRECTS JPM TO CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C) (3), AND 9(A)(2) OF THE ACT, 7 U.S.C. §§ 6C(A)(5)(C), 9(1), (3), 13(A)(2)
(2018), AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, 17 C.F.R. §§ 180.1(A)(1), (3), 180.2 (2019). ADDITIONALLY, THE ORDER REQUIRES THE BANK AND JPMC & CO. TO PAY
RESTITUTION IN THE AMOUNT OF $205,992,102, AND THE BROKER-DEALER AND JPMC & CO. TO PAY ADDITIONAL RESTITUTION IN THE AMOUNT OF $105,744,906. THE ORDER
FURTHER REQUIRES JPM TO PAY A CIVIL MONETARY PENALTY IN THE AMOUNT OF $436,431,811. THE ORDER ALSO REQUIRES THE BANK AND JPMC & CO. TO PAY DISGORGEMENT
IN THE AMOUNT OF $120,332,430 AND THE BROKER-DEALER AND JPMC & CO. TO PAY DISGORGEMENT IN THE AMOUNT OF $51,702,360.
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).
RESPONDENTS JPM HAVE SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. ACCORDINGLY, IT IS HEREBY ORDERED THAT JPM SHALL
CEASE AND DESIST FROM VIOLATING SECTIONS 4C(A)(5)(C), 6(C)(1), 6(C)(3), AND 9(A)(2) OF THE ACT AND REGULATIONS 180.1(A)(1) AND (3) AND 180.2, AND THE BROKER-DEALER
SHALL CEASE AND DESIST FROM VIOLATING REGULATION 166.3. THE BROKER-DEALER SHALL PAY RESTITUTION OF ONE HUNDRED FIVE MILLION SEVEN HUNDRED FORTY-FOUR
THOUSAND NINE HUNDRED SIX DOLLARS ($105,744,906), JOINTLY AND SEVERALLY WITH JPMC & CO; A CIVIL MONETARY PENALTY OF FOUR HUNDRED THIRTY-SIX MILLION FOUR
HUNDRED THIRTY-ONE THOUSAND EIGHT HUNDRED ELEVEN DOLLARS ($436,431,811), JOINTLY AND SEVERALLY WITH THE BANK AND JPMC & CO; DISGORGEMENT IN THE AMOUNT OF
FIFTY ONE MILLION SEVEN HUNDRED TWO THOUSAND THREE HUNDRED SIXTY DOLLARS ($51,702,360), JOINTLY AND SEVERALLY WITH JPMC & CO; ADDITIONALLY, THE BANK AND JPMC
& CO SHALL PAY TWO HUNDRED FIVE MILLION NINE HUNDRED NINETY-TWO THOUSAND ONE HUNDRED TWO DOLLARS ($205,992,102) IN RESITUTION AND ONE HUNDRED TWENTY
MILLION THREE HUNDRED THIRTY-TWO THOUSAND FOUR HUNDRED THIRTY DOLLARS ($120,332,430) IN DISGORGEMENT, JOINTLY AND SEVERALLY; JPM SHALL COMPLY WITH THE
UNDERTAKINGS SET FORTH IN THE ORDER.
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., 11.F. or 11.G. of Form ADV.
OR
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 Number:
This advisory affiliate is a Firm an Individual
Registered:
Yes No
Name: JPMORGAN CHASE & CO.
(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)
FEDERAL FINANCIAL SUPERVISORY AUTHORITY (BAFIN)
2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
07/22/2021 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
WA 17-WP 3120-2020/0011
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
No Product
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NEGLIGENT BREACH OF SUPERVISORY AND ORGANIZATIONAL DUTIES IN CONNECTION WITH INFRINGEMENTS OF SECTION 21 OF THE GERMAN SECURITIES TRADING 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):
08/09/2021 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: $ 1,830,000.00
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:
AN ADMINISTRATIVE FINE OF 1,830,000 EUROS
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).
AN ADMINISTRATIVE FINE OF 1,830,000 EUROS IS IMPOSED PURSUANT TO SECTION 30 (1) NO. 1, (4)SENTENCE 1 OF THE GERMAN ACT ON BREACHES OF ADMINISTRATIVE
REGULATIONS, ON THE GROUNDS OF ANEGLIGENT BREACH OF SUPERVISORY AND ORGANIZATIONAL DUTIES IN CONNECTION WITH IN FRINGEMENTS OF SECTION 21 OF THE GERMAN
SECURITIES TRADING ACT RELATING TO THE FILING OF VOTING RIGHTS NOTIFICATIONS.
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:
Part 3
CRS Type(s) Affiliate Info Retire
There are no CRS filings to display.
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
Printed Name: Title:
Adviser CRD Number:
300114
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
CHRISTOPHER SPELMAN 03/31/2026
Printed Name: Title:
CHRISTOPHER SPELMAN DIRECTOR / MANAGING DIRECTOR
Adviser CRD Number:
300114