← Benjamin F. Edwards & Company, Incorporated
Form ADV (full filing)
as of Mar 31, 2026
· 2.73 MB
· sha256 2a4f246e36ad…
Extracted text
Machine-extracted from the archived PDF. Layout artifacts are expected.
FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: BENJAMIN F. EDWARDS & COMPANY, INCORPORATED CRD Number: 146936
Annual Amendment - All Sections Rev. 10/2021
3/31/2026 1:13:57 PM
WARNING: Complete this form truthfully. False statements or omissions may result in denial of your application, revocation of your registration, or criminal
prosecution. You must keep this form updated by filing periodic amendments. See Form ADV General Instruction 4.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing business, and how we can contact you. If you are filing an umbrella registration, the
information in Item 1 should be provided for the filing adviser only. General Instruction 5 provides information to assist you with filing an umbrella registration.
A. Your full legal name (if you are a sole proprietor, your last, first, and middle names):
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
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: 801-71421
(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
1445065
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 146936
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:
ONE NORTH BRENTWOOD BOULEVARD SUITE 850
City: State: Country: ZIP+4/Postal Code:
ST. LOUIS Missouri United States 63105
If this address is a private residence, check this box:
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If
you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to
which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your
most recently completed fiscal year.
(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:
Normal business hours at this location:
8:00 - 5:00
(3) Telephone number at this location:
314-726-1600
(4) Facsimile number at this location, if any:
314-726-1601
(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?
100
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:
2549003FIOJT37PTTC29
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
List your other business names and the jurisdictions in which you use them. You must complete a separate Schedule D Section 1.B. for each business
name.
Name: BENJAMIN F. EDWARDS
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 Other:
ID MT RI
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:
400 SOUTH COUNTY ROAD SUITE 140
City: State: Country: ZIP+4/Postal Code:
WHEATON Illinois United States 60187
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
630-871-2673 630-692-8076
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?
22
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
475 REGENCY PARK DRIVE SUITE 125
City: State: Country: ZIP+4/Postal Code:
O'FALLON Illinois United States 62269
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
618-624-1500 618-624-1501
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?
10
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
67 PARK PLACE EAST SUITE 800
City: State: Country: ZIP+4/Postal Code:
MORRISTOWN New Jersey United States 07960
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
973-254-5880 973-254-5899
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?
13
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
2056 WESTINGS AVE. SUITE 360
City: State: Country: ZIP+4/Postal Code:
NAPERVILLE Illinois United States 60563
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
331-814-2595 331-814-2596
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:
640423
How many employees perform investment advisory functions from this office location?
10
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1605 MARTHA BERRY BOULEVARD NW
City: State: Country: ZIP+4/Postal Code:
ROME Georgia United States 30165
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
706-292-3600 706-292-3601
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?
15
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
6300 S SYRACUSE WAY SUITE 210
City: State: Country: ZIP+4/Postal Code:
GREENWOOD VILLAGE Colorado United States 80111
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
303-770-6621 303-770-0935
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:
547331
How many employees perform investment advisory functions from this office location?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
125 HALF MILE ROAD, SUITE 104
City: State: Country: ZIP+4/Postal Code:
RED BANK New Jersey United States 07701
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
732-383-2050 732-383-2100
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:
480002
How many employees perform investment advisory functions from this office location?
10
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
SHADES CREEK PLAZA 850 SHADES CREEK PARKWAY, SUITE 310
City: State: Country: ZIP+4/Postal Code:
BIRMINGHAM Alabama United States 35209
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
205-877-9900 205-877-9999
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:
534337
How many employees perform investment advisory functions from this office location?
9
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
400 ASHMAN STREET SUITE 200
City: State: Country: ZIP+4/Postal Code:
MIDLAND Michigan United States 48640
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
989-835-3000 989-835-7462
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:
546765
How many employees perform investment advisory functions from this office location?
7
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
36468 EMERALD COAST PARKWAY SUITE 5101
City: State: Country: ZIP+4/Postal Code:
DESTIN Florida United States 32541
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
8508372451 8508372471
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:
535347
How many employees perform investment advisory functions from this office location?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
5832 NORTH KNOXVILLE AVENUE SUITE B
City: State: Country: ZIP+4/Postal Code:
PEORIA Illinois United States 61614
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
309-693-5760 309-693-5731
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:
424949
How many employees perform investment advisory functions from this office location?
9
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
12600 DEERFIELD PARKWAY SUITE 180
City: State: Country: ZIP+4/Postal Code:
ALPHARETTA Georgia United States 30004
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
770-619-3004 770-619-3979
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:
447658
How many employees perform investment advisory functions from this office location?
8
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
751 E PORTER AVE SUITE 6
City: State: Country: ZIP+4/Postal Code:
CHESTERTON Indiana United States 46304
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
219-250-3240 219-250-3252
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:
695938
How many employees perform investment advisory functions from this office location?
8
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
2884 N.MONROE STREET
City: State: Country: ZIP+4/Postal Code:
DECATUR Illinois United States 62526
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
217-876-0649
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:
446070
How many employees perform investment advisory functions from this office location?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
111 S. CALVERT ST. SUITE 2020
City: State: Country: ZIP+4/Postal Code:
BALTIMORE Maryland United States 21202
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
410-347-5559 410-347-5659
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:
549672
How many employees perform investment advisory functions from this office location?
8
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
440 SCIENCE DRIVE SUITE 402
City: State: Country: ZIP+4/Postal Code:
MADISON Wisconsin United States 53711
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
608-233-1000 608-233-1085
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:
429592
How many employees perform investment advisory functions from this office location?
7
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
5250 W. 116TH PLACE SUITE 320
City: State: Country: ZIP+4/Postal Code:
LEAWOOD Kansas United States 66211
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
913-253-1400 913-253-1499
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:
513410
How many employees perform investment advisory functions from this office location?
6
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
99 MONROE AVENUE, NW SUITE 975
City: State: Country: ZIP+4/Postal Code:
GRAND RAPIDS Michigan United States 49503
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
616-974-3000 616-974-9027
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:
560209
How many employees perform investment advisory functions from this office location?
6
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1101 BROAD STREET SUITE 105
City: State: Country: ZIP+4/Postal Code:
CHATTANOOGA Tennessee United States 37402
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
423-668-5411 423-668-5412
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:
479036
How many employees perform investment advisory functions from this office location?
7
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
1112 WINDOVER ROAD
City: State: Country: ZIP+4/Postal Code:
JONESBORO Arkansas United States 72401
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
870-520-7000 870-520-7001
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:
644743
How many employees perform investment advisory functions from this office location?
13
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
ONE NORTH BRENBTWOOD BLVD SUITE 510
City: State: Country: ZIP+4/Postal Code:
CLAYTON Missouri United States 63105
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
314-854-9900 314-727-1388
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?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
6555 US HIGHWAY 98-WEST SUITE B
City: State: Country: ZIP+4/Postal Code:
HATTIESBURG Mississippi United States 39402
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
061-271-7110
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:
622838
How many employees perform investment advisory functions from this office location?
11
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
11621 CATALPA LANE
City: State: Country: ZIP+4/Postal Code:
WOODSTOCK Illinois United States 60098
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
815-337-4485 815-337-5865
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:
527028
How many employees perform investment advisory functions from this office location?
12
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
850 PARK SHORE DR, SUITE 204
City: State: Country: ZIP+4/Postal Code:
NAPLES Florida United States 34103
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
239-354-7432 239-354-7433
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:
711520
How many employees perform investment advisory functions from this office location?
7
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
50 S. 1ST STREET SUITE 100
City: State: Country: ZIP+4/Postal Code:
ST. CHARLES Illinois United States 60174
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
630-313-2460 630-313-2464
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:
674891
How many employees perform investment advisory functions from this office location?
7
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.facebook.com/people/Benjamin-F-Edwards-Co/100040273672567/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.BENJAMINFEDWARDS.COM
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.YOUTUBE.COM/USER/BENJAMINFEDWARDS
Address of Website/Account on Publicly Available Social Media Platform: https://vimeo.com/user143999078
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/BENJAMIN-F.-EDWARDS-&-CO.
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://TWITTER.COM/GROWWITHBFEC
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:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
345 FRAZIER AVENUE SUITE 205
City: State: Country: ZIP+4/Postal Code:
CHATTANOOGA Tennessee United States 37405
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
423-668-5411 423-668-5412
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
10260 SW GREENBURG ROAD SUITE 535
City: State: Country: ZIP+4/Postal Code:
PORTLAND Oregon United States 97223
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
971-319-6172 971-319-6405
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
210 N. HAMILTON ST.
City: State: Country: ZIP+4/Postal Code:
DALTON Georgia United States 30720
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
706-229-4798 706-229-4882
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
201 W.MAIN STREET
City: State: Country: ZIP+4/Postal Code:
EL DORADO Arkansas United States 71730
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
870-639-6909 870-639-6910
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
5832 NORTH KNOXVILLE AVENUE SUITE B
City: State: Country: ZIP+4/Postal Code:
PEORIA Illinois United States 61614
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
309-693-5760 309-693-5761
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
120 NORTH MAIN STREET
City: State: Country: ZIP+4/Postal Code:
BREWER Maine United States 04412
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
207-300-2460 207-300-2462
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
400 SOUTH COUNTY ROAD SUITE 140
City: State: Country: ZIP+4/Postal Code:
WHEATON Illinois United States 60187
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
630-871-2673 630-692-8076
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS &CO., INC.
Number and Street 1: Number and Street 2:
1403 W PRIEN LAKE RD
City: State: Country: ZIP+4/Postal Code:
LAKE CHARLES Louisiana United States 70601
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
337-429-1845
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS &CO., INC.
Number and Street 1: Number and Street 2:
4050 STATE HIGHWAY 42/57
City: State: Country: ZIP+4/Postal Code:
STURGEON BAY Wisconsin United States 54235
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
920-743-9843
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS &CO., INC.
Number and Street 1: Number and Street 2:
4020 DEL MAR DRIVE SW SUITE 160
City: State: Country: ZIP+4/Postal Code:
WYOMING Michigan United States 49418
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
616-342-7316
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
1 NORTH BRENTWOOD BOULEVARD SUTIE 510
City: State: Country: ZIP+4/Postal Code:
CLAYTON Missouri United States 63105
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
314-854-9900 314-727-1388
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
200 1ST AVENUE NW SUITE 201
City: State: Country: ZIP+4/Postal Code:
HICKORY North Carolina United States 28601
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
828-624-7868
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
7347 POWELL RD. SUITE C
City: State: Country: ZIP+4/Postal Code:
WILDWOOD Florida United States 34785
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
352-76-0153
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
727-914-9191
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2475 NORTHWINDS PARKWAY SUITE 175
City: State: Country: ZIP+4/Postal Code:
ALPHARETTA Georgia United States 30009
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
770-619-3004 770-619-3979
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
ALBRIDGE SOLUTIONS, INC.
Number and Street 1: Number and Street 2:
1800 AMERICAN BLVD. SUITE 300
City: State: Country: ZIP+4/Postal Code:
PENNINGTON New Jersey United States 08534
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
201-395-1456 201-413-9141
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.
RECORDS RETAINED INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(3), (7),(18)(1)(A).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
5370 KIETZKE LN. SUITE 104
City: State: Country: ZIP+4/Postal Code:
RENO Nevada United States 89511
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
775-300-7560 775-300-7551
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
3511 CANYON DE FLORES SUITE 202
City: State: Country: ZIP+4/Postal Code:
WATKINSVILLE Georgia United States 30677
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
706-705-0350 706-705-0341
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
4833 MUNSON STREET NW
City: State: Country: ZIP+4/Postal Code:
CANTON Ohio United States 44718
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
330-494-8640 330-494-8654
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
224 E. LARKIN ST.
City: State: Country: ZIP+4/Postal Code:
MIDLAND Michigan United States 48640
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
989-835-3000 989-835-7462
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
910 W TRIMBLE AVE SUITE 2
City: State: Country: ZIP+4/Postal Code:
BERRYVILLE Arkansas United States 72616
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
870-505-6793 870-505-6794
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
2240 MILITARY RD.
City: State: Country: ZIP+4/Postal Code:
COLUMBUS Mississippi United States 39705
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
662-368-1630 662-368-1630
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
16201 E INDIANA AVE. SUITE 1450
City: State: Country: ZIP+4/Postal Code:
SPOKANE VALLEY Washington United States 99216
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
509-598-2037
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENAJMIN F. EDWARDS
Number and Street 1: Number and Street 2:
401 COWAN ROAD SUITE D
City: State: Country: ZIP+4/Postal Code:
GULFPORT Mississippi United States 39507
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
228-284-3131 228-896-6661
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
1701 4TH STREET SUITE 101
City: State: Country: ZIP+4/Postal Code:
PERU Illinois United States 61354
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
815-220-0588 815-220-0579
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
TWO CARLSON PARKWAY NORTH SUITE 355
City: State: Country: ZIP+4/Postal Code:
PLYMOUTH Minnesota United States 55447
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
651-377-2078 651-377-2079
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1305 LAMAR AVE SUITE C
City: State: Country: ZIP+4/Postal Code:
PARIS Texas United States 75460
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
903-783-1307 903-783-1875
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
6300 SOUTH SYRACUSE WAY SUITE 210
City: State: Country: ZIP+4/Postal Code:
GREENWOOD VILLAGE Colorado United States 80111
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
303-770-6621 303-770-0935
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
751 E PORTER AVE. SUITE 6
City: State: Country: ZIP+4/Postal Code:
CHESTERTON Indiana United States 46304
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
219-250-3240 219-250-3252
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
50 S. 1ST STREET SUITE 100
City: State: Country: ZIP+4/Postal Code:
ST. CHARLES Illinois United States 60174
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
833-313-2460 833-313-2464
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
217 WEST MAIN STREET
City: State: Country: ZIP+4/Postal Code:
SALEM Illinois United States 62881
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
618-548-9099 618-548-9077
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
4101 PIONEER WOODS DRIVE SUITE 100
City: State: Country: ZIP+4/Postal Code:
LINCOLN Nebraska United States 68506
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
402-325-1170 402-325-1171
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
67 PARK PLACE EAST SUITE 800
City: State: Country: ZIP+4/Postal Code:
MORRISTOWN New Jersey United States 07960
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
973-254-5880 973-254-5899
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
8500 WEST BOWLES AVENUE SUITE 315
City: State: Country: ZIP+4/Postal Code:
LITTLETON Colorado United States 80123
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
720-283-3274 720-283-4002
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
90 SOUTH CASCADE AVENUE SUITE 1140
City: State: Country: ZIP+4/Postal Code:
COLORADO SPRINGS Colorado United States 80903
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
719-234-0373
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
272 VALLEY RD. SUITE 1
City: State: Country: ZIP+4/Postal Code:
MIDDLETON Rhode Island United States 02842
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
401-239-2033
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
850 SHADES CREEK PARKWAY SUITE 310
City: State: Country: ZIP+4/Postal Code:
BIRMINGHAM Alabama United States 35209
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
205-877-9900 205-877-9999
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2102 BIRDCREEK DRIVE SUITE A
City: State: Country: ZIP+4/Postal Code:
TEMPLE Texas United States 76502
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
254-236-6490 254-236-6491
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
70COMMERCIAL ST. SUITE 101
City: State: Country: ZIP+4/Postal Code:
CONCORD New Hampshire United States 03301
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
603-369-4960 603-369-4959
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
7607 FERN AVENUE SUITE 102
City: State: Country: ZIP+4/Postal Code:
SHREVEPORT Louisiana United States 71105
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
318-383-6805 318-383-6814
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
11503 NW MILITARY HWY SUITE 319
City: State: Country: ZIP+4/Postal Code:
SAN ANTONIO Texas United States 78231
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
726-900-8080 726-900-8081
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
715 WEST SHERMAN AVENUE SUITE B
City: State: Country: ZIP+4/Postal Code:
HARRISON Arkansas United States 72601
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
870-704-4060 870-704-4027
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
460 DILLARD ROAD
City: State: Country: ZIP+4/Postal Code:
HIGHLANDS North Carolina United States 28741
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
828-526-3535 828-526-3088
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
5250 W 116TH PLACE SUITE 320
City: State: Country: ZIP+4/Postal Code:
LEAWOOD Kansas United States 66211
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
913-253-1400 913-253-1499
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1590 W. CAUSEWAY APPROACH SUITE 1
City: State: Country: ZIP+4/Postal Code:
MANDEVILLE Louisiana United States 70471
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
985-674-7000 985-674-7099
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
3510 NORTH CAUSEWAY BLVD SUITE 520 SUITE 520
City: State: Country: ZIP+4/Postal Code:
METAIRIE Louisiana United States 70002
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
504-208-4779 504-208-4778
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1605 MARTHA BERRY BOULEVARD NW
City: State: Country: ZIP+4/Postal Code:
ROME Georgia United States 30165
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
706-292-3600 706-292-3601
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
600 COLLEGE AVE.
City: State: Country: ZIP+4/Postal Code:
CLEMSON South Carolina United States 29631
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
864-653-7702 864-653-7720
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2745 S. ALMA SCHOOL RD. SUITE 4
City: State: Country: ZIP+4/Postal Code:
CHANDLER Arizona United States 85286
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
480-566-6422 480-566-6423
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
3038 SPRING MILL DRIVE
City: State: Country: ZIP+4/Postal Code:
SPRINGFIELD Illinois United States 62704
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
217-441-8490
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
ONE COUNTRY CLUB VIEW SUITE 201
City: State: Country: ZIP+4/Postal Code:
EDWARDSVILLE Illinois United States 62025
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
618-659-6741 618-659-9752
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
3400 HEDLEY ROAD
City: State: Country: ZIP+4/Postal Code:
SPRINGFIELD Illinois United States 62711
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
217-726-5862 217-726-5883
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1805 BOYSON RD.,
City: State: Country: ZIP+4/Postal Code:
HIAWATHA Iowa United States 52233
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
319-249-6110 319-249-6111
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
401 ELBA HWUY
City: State: Country: ZIP+4/Postal Code:
TROY Alabama United States 36079
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
334-635-9115 334-635-9116
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2056 WESTINGS AVE. SUITE 360
City: State: Country: ZIP+4/Postal Code:
NAPERVILLE Illinois United States 60563
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
331-814-2595 331-814-2596
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
3511 CANYON DE FLORES SUITE A
City: State: Country: ZIP+4/Postal Code:
SIERRA VISTA Arizona United States 85650
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
520-226-9107 520-226-9108
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
930 S. HARBOR CITY BLVD SUITE 400
City: State: Country: ZIP+4/Postal Code:
MELBOURNE Florida United States 32901
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
321-729-6615 321-729-6619
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
4940 CASCADE ROAD SE SUITE 210
City: State: Country: ZIP+4/Postal Code:
GRAND RAPIDS Michigan United States 49546
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
616-974-3000 616-974-9027
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
145 VILLAGE SQUARE
City: State: Country: ZIP+4/Postal Code:
PAINTED POST New York United States 14870
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
607-962-2045 607-962-6035
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
4101 PIONEER WOODS DRIVE SUITE 100
City: State: Country: ZIP+4/Postal Code:
LINCOLN Nebraska United States 68506
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
402-325-1170 402-325-1171
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2000 98 PALMS BOULEVARD SUITE 200
City: State: Country: ZIP+4/Postal Code:
DESTIN Florida United States 32541
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
850-837-2451 850-837-2471
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
475 REGENCY PARK DRIVE SUITE 125
City: State: Country: ZIP+4/Postal Code:
O'FALLON Illinois United States 62269
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
618-624-1500 618-624-1501
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
10440 BROADWAY
City: State: Country: ZIP+4/Postal Code:
CROWN POINT Indiana United States 46307
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
219-226-3401 219-226-3402
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
11741 MISSOURI BOTTOM RD.
City: State: Country: ZIP+4/Postal Code:
HAZELWOOD Missouri United States 63042
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
314-731-1174
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.
OFFSITE STORAGE OF CERTAIN BOOKS AND RECORDS.
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1008 VANDALIA ST.
City: State: Country: ZIP+4/Postal Code:
COLLINSVILLE Illinois United States 62234
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
6183077048
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
317 SOUTHWEST DR. STE B
City: State: Country: ZIP+4/Postal Code:
JONESBORO Arkansas United States 72401
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
870-520-7000 870-520-7001
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
235 EAST MAIN STREET SUITE 3
City: State: Country: ZIP+4/Postal Code:
GALESBURG Illinois United States 61401
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
309-341-0682 309-341-0684
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
77 SOUTH PALM AVENUE
City: State: Country: ZIP+4/Postal Code:
SARASOTA Florida United States 34236
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
941-954-8651 941-954-8654
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS &CO., INC.
Number and Street 1: Number and Street 2:
7777 BONHOMME AVE SUITE 1616
City: State: Country: ZIP+4/Postal Code:
CLAYTON Missouri United States 63105
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
3142820700
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
102 NW 3RD STREET
City: State: Country: ZIP+4/Postal Code:
ABILENE Kansas United States 67410
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
785-263-3794 785-263-3794
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2802 COLLEGE AVE
City: State: Country: ZIP+4/Postal Code:
CONWAY Arkansas United States 72034
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
501-273-5776 501-273-5777
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
771 CORPORATE DRIVE SUITE 605
City: State: Country: ZIP+4/Postal Code:
LEXINGTON Kentucky United States 40503
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
859-286-7528 859-286-7529
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2585 HUNTCLIFF LANE
City: State: Country: ZIP+4/Postal Code:
PANAMA CITY Florida United States 32405
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
960-769-7053 850-769-7057
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
925 WESTCHESTER AVE SUITE LL01
City: State: Country: ZIP+4/Postal Code:
WHITE PLAINS New York United States 10604
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
914-467-5033 914-997-9755
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
330 N. DIVISION UNIT H
City: State: Country: ZIP+4/Postal Code:
SUGAR GROVE Illinois United States 60554
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
630-409-0410 630-409-0409
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1151 OFFICE WOODS DRIVE SUITE B
City: State: Country: ZIP+4/Postal Code:
PENSACOLA Florida United States 32504
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
850-477-3336 850-447-3339
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2309 VILLAGE GREEN PLACE SUITE A
City: State: Country: ZIP+4/Postal Code:
CHAMPAIGN Illinois United States 61822
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
217-318-0134 217-318-0135
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
ONE RESERVE ROAD
City: State: Country: ZIP+4/Postal Code:
DANBURY Connecticut United States 06810
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
203-790-8700 203-748-3900
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
GLOBAL RELAY
Number and Street 1: Number and Street 2:
233 S. WACKER DRIVE 84TH FLOOR
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60606
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
866-484-6630
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.
ARCHIVAL OF ELECTRONIC COMMUNICATIONS.
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2321 WHITNEY AVE SUITE 502
City: State: Country: ZIP+4/Postal Code:
HAMDEN Connecticut United States 06518
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
203-287-9266 203-287-9293
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
105 N WASHINGTON STREET SUITE 101
City: State: Country: ZIP+4/Postal Code:
GREEN BAY Wisconsin United States 54301
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
920-305-7970 920-305-7971
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
7322 CENTER STREET
City: State: Country: ZIP+4/Postal Code:
MENTOR Ohio United States 44060
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
440-205-0829 440-205-0968
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2500 HIGHWAY ROAD SUITE 107
City: State: Country: ZIP+4/Postal Code:
HERMITAGE Pennsylvania United States 16148
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
724-308-1045 724-308-1046
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
6555 US HIGHWAY 98-WEST SUITE 5B
City: State: Country: ZIP+4/Postal Code:
HATTIESBURG Mississippi United States 39402
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
601-271-7110 601-271-7176
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
921 EAST NORTH AVENUE
City: State: Country: ZIP+4/Postal Code:
FLORA Illinois United States 62839
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
618-508-8050 618-508-8049
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
4501 N. HWY 7 SUITE 4
City: State: Country: ZIP+4/Postal Code:
HOT SPRINGS VILLAGE Arkansas United States 71909
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
501-431-2379
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1411 EAST PRIMROSE SUITE A
City: State: Country: ZIP+4/Postal Code:
SPRINGFIELD Missouri United States 65804
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
417-712-3922 417-823-8912
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
2480 E. RIVER ROAD
City: State: Country: ZIP+4/Postal Code:
TUCSON Arizona United States 85718
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
520-274-2748 520-274-2749
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
8794 BOYNTON BEACH BLVD SUITE 220
City: State: Country: ZIP+4/Postal Code:
BOYNTON BEACH Florida United States 33472
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
561-733-9900 561-733-9991
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
2640 W. ANDREW JOHNSON HWY
City: State: Country: ZIP+4/Postal Code:
MORRISTOWN Tennessee United States 37814
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
423-353-9526 423-353-9527
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2884 N. MONROE STREET
City: State: Country: ZIP+4/Postal Code:
DECATUR Illinois United States 62526
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
217-876-0649 217-876-0931
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1276 WESTGATE PARKWAY
City: State: Country: ZIP+4/Postal Code:
DOTHAN Alabama United States 36303
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
3345005462
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
850 PARK SHORE DR. SUITE 204
City: State: Country: ZIP+4/Postal Code:
NAPLES Florida United States 34103
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
239-354-7432 239-354-7433
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F EDWARDS
Number and Street 1: Number and Street 2:
125 HALF MILE ROAD
City: State: Country: ZIP+4/Postal Code:
RED BANK New Jersey United States 07701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
732-383-2050 732-383-2100
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4),(5),(7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
440 SCIENCE DRIVE SUITE 401
City: State: Country: ZIP+4/Postal Code:
MADISON Wisconsin United States 53711
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
608-233-1000 608-233-1085
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
247 NEWPORT RD UNIT F
City: State: Country: ZIP+4/Postal Code:
NEW LONDON New Hampshire United States 03257
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
603-526-6914 603-526-6919
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
111 S. CALVERT ST. SUITE 1720
City: State: Country: ZIP+4/Postal Code:
BALTIMORE Maryland United States 21202
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
410-347-5559 410-347-5659
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
708B WINDOVER RD
City: State: Country: ZIP+4/Postal Code:
JONESBORO Arkansas United States 72401
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
870-520-7020 870-520-7021
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
5001 SPRING VALLEY ROAD SUITE 400 EAST OFFICE 26
City: State: Country: ZIP+4/Postal Code:
DALLAS Texas United States 75244
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
855-645-9996
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
11621 CATALPA LANE
City: State: Country: ZIP+4/Postal Code:
WOODSTOCK Illinois United States 60098
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
815-337-4485 815-337-5865
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS & COMPANY, INC.
Number and Street 1: Number and Street 2:
811 TILTON ROAD
City: State: Country: ZIP+4/Postal Code:
NORTHFIELD New Jersey United States 08225
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
609-484-2659 609-484-2650
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS &CO., INC.
Number and Street 1: Number and Street 2:
635 S. 100 EAST SUITE 120
City: State: Country: ZIP+4/Postal Code:
LOGAN Utah United States 84321
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
435-317-4047
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
2901 OVERLAND TRAIL SUITE 125
City: State: Country: ZIP+4/Postal Code:
SHERMAN Texas United States 75092
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
903-893-8338 903-893-8392
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
576 HIGHLAND COLONY PARKWAY SUITE 120
City: State: Country: ZIP+4/Postal Code:
RIDGELAND Mississippi United States 39157
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
601-213-0360 601-213-0361
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
130 INTEGRA BREEZE LN SUITE 4A
City: State: Country: ZIP+4/Postal Code:
DAYTONA BEACH Florida United States 32117
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
386-267-0129 386-267-0130
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
500 CORPORATE PARKWAY SUITE 125
City: State: Country: ZIP+4/Postal Code:
HOOVER Alabama United States 35242
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
659-219-2812
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
Name of entity where books and records are kept:
BENJAMIN F. EDWARDS
Number and Street 1: Number and Street 2:
1468 KIMBROUGH RD SUITE 101
City: State: Country: ZIP+4/Postal Code:
GERMANTOWN Tennessee United States 38138
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
901-236-0910 901-236-0909
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.
RECORDS RETAINED AT BRANCH OFFICES INCLUDE ITEMS REQUIRED BY IA RULE 204-2(A)(4), (5), (7), AND (11).
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
No Information Filed
Item 2 SEC Registration/Reporting
Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for
SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2
should be provided for the filing adviser only.
A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an
annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2
provides information to help you determine whether you may affirmatively respond to each of these items.
You (the adviser):
(1) are a large advisory firm that either:
(a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or
(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating
amendment and is registered with the SEC;
(2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100
million (in U.S. dollars) and you are either:
(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place
of business; or
(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;
Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities
authority.
(3) Reserved
(4) have your principal office and place of business outside the United States;
(5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;
(6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the
Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under
management;
(7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption
in rule 203A-2(a);
(8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is
registered with the SEC, and your principal office and place of business is the same as the registered adviser;
If you check this box, complete Section 2.A.(8) of Schedule D.
(9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;
If you check this box, complete Section 2.A.(9) of Schedule D.
(10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);
If you check this box, complete Section 2.A.(10) of Schedule D.
(11) are an Internet adviser relying on rule 203A-2(e);
If you check this box, complete Section 2.A.(11) of Schedule D.
(12) have received an SEC order exempting you from the prohibition against registration with the SEC;
If you check this box, complete Section 2.A.(12) of Schedule D.
(13) are no longer eligible to remain registered with the SEC.
State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they
file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy
of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would
like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to
additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit
to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck
the box(es) next to those state(s).
Jurisdictions
AL IL NE SC
AK IN NV SD
AZ IA NH TN
AR KS NJ TX
CA KY NM UT
CO LA NY VT
CT ME NC VI
DE MD ND VA
DC MA OH WA
FL MI OK WV
GA MN OR WI
GU MS PA WY
HI MO PR
ID MT RI
If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that
state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).
SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control
with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser,
provide the following information:
Name of Registered Investment Adviser
CRD Number of Registered Investment Adviser
SEC Number of Registered Investment Adviser
-
SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days
If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration
within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will b e
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
Missouri United States
If you are a partnership, provide the name of the state or country under whose laws your partnership was formed. If you are a sole proprietor, provide the
name of the state or country where you reside.
If you are changing your response to this Item, see Part 1A Instruction 4.
Item 4 Successions
Yes No
A. Are you, at the time of this filing, succeeding to the business of a registered investment adviser, including, for example, a change of your
structure or legal status (e.g., form of organization or state of incorporation)?
If "yes", complete Item 4.B. and Section 4 of Schedule D.
B. Date of Succession: (MM/DD/YYYY)
If you have already reported this succession on a previous Form ADV filing, do not report the succession again. Instead, check "No." See Part 1A Instruction 4.
SECTION 4 Successions
No Information Filed
Item 5 Information About Your Advisory Business - Employees, Clients, and Compensation
Responses to this Item help us understand your business, assist us in preparing for on-site examinations, and provide us with data we use when making
regulatory policy. Part 1A Instruction 5.a. provides additional guidance to newly formed advisers for completing this Item 5.
Employees
If you are organized as a sole proprietorship, include yourself as an employee in your responses to Item 5.A. and Items 5.B.(1), (2), (3), (4), and (5). If an
employee performs more than one function, you should count that employee in each of your responses to Items 5.B.(1), (2), (3), (4), and (5).
A. Approximately how many employees do you have? Include full- and part-time employees but do not include any clerical workers.
755
B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
450
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
545
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives?
450
(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?
3
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
376
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
1
In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on
your behalf.
Clients
In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship
with those investors.
C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services
during your most recently completed fiscal year?
23
(2) Approximately what percentage of your clients are non-United States persons?
0%
D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does
not include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of
1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment
Company Act of 1940, do not answer (1)(d) or (3)(d) below.
Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below)
attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check
Item 5.D.(2) rather than respond to Item 5.D.(1).
The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under
management reported in Item 5.F.(2)(c) below.
If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If
you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e),
and (f) as applicable.
(1) Number of (2) Fewer than (3) Amount of Regulatory Assets
Type of Client Client(s) 5 Clients under Management
(a) Individuals (other than high net worth individuals) 32288 $ 15,548,600,940
(b) High net worth individuals 244 $ 2,458,766,402
(c) Banking or thrift institutions 0 $0
(d) Investment companies 0 $0
(e) Business development companies 0 $0
(f) Pooled investment vehicles (other than investment companies and 0 $0
business development companies)
(g) Pension and profit sharing plans (but not the plan participants or 203 $ 149,684,406
government pension plans)
(h) Charitable organizations 96 $ 187,337,009
(i) State or municipal government entities (including government pension 0 $0
plans)
(j) Other investment advisers 0 $0
(k) Insurance companies 0 $0
(l) Sovereign wealth funds and foreign official institutions 0 $0
(m) Corporations or other businesses not listed above 226 $ 570,127,495
(n) Other: INVESTMENT CLUB 0 $ 690,058
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) $ 12,768,094,847 (d) 43,163
Non-Discretionary: (b) $ 6,147,111,463 (e) 12,260
Total: (c) $ 18,915,206,310 (f) 55,423
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?
$ 7,266,212
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
$ 6,251,915,944
(b) portfolio manager for a wrap fee program?
$0
(c) sponsor to and portfolio manager for the same wrap fee program?
$ 12,663,290,367
If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b).
If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D.
If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a
wrap fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2).
Yes No
J. (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of
investments?
(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your
regulatory assets under management?
K. Separately Managed Account Clients
Yes No
(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately
managed account clients)?
If yes, complete Section 5.K.(1) of Schedule D.
(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold
ten percent or more of this remaining amount of regulatory assets under management?
If yes, complete Section 5.K.(3) of Schedule D for each custodian.
L. Marketing Activities
Yes No
(1) Do any of your advertisements include:
(a) Performance results?
(b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))?
(c) Testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(e) Third-party ratings?
(2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in
connection with the use of testimonials, endorsements, or third-party ratings?
(3) Do any of your advertisements include hypothetical performance ?
(4) Do any of your advertisements include predecessor performance ?
SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies
No Information Filed
SECTION 5.I.(2) Wrap Fee Programs
If you are a portfolio manager for one or more wrap fee programs, list the name of each program and its sponsor. You must complete a separate Schedule D
Section 5.I.(2) for each wrap fee program for which you are a portfolio manager.
Name of Wrap Fee Program
BENJAMIN F. EDWARDS ACTIVE PASSIVE PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS CLIENT PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS CUSTOM MUTUAL FUND PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS EQUITY PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS EXCHANGE TRADED FUND PORTOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS MUTUAL FUND MODEL STRATEGIES
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS MUTUAL FUND PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
BENJAMIN F. EDWARDS PRIVATE PORTFOLIOS
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
Name of Wrap Fee Program
UNIFIED MANAGED ACCOUNT
Name of Sponsor
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 71421
Sponsor's CRD Number (if any):
146936
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 43 % 42 %
(ii) Non Exchange-Traded Equity Securities 0% 1%
(iii) U.S. Government/Agency Bonds 1% 1%
(iv) U.S. State and Local Bonds 3% 3%
(v) Sovereign Bonds 0% 0%
(vi) Investment Grade Corporate Bonds 0% 0%
(vii) Non-Investment Grade Corporate Bonds 0% 0%
(viii) Derivatives 0% 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 50 % 49 %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business 0% 0%
Development Companies)
(xi) Cash and Cash Equivalents 3% 4%
(xii) Other 0% 0%
Generally describe any assets included in "Other"
(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 (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(a) Interest (b) Foreign
Rate Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 14,423,379 $0 0% 0% 0% 9.55 % 0% 0%
10-149% $ 84,761,779 $ 3,696,025 0% 0% 0% 67.9 % 0% 0%
150% or more $0 $0 0% 0% 0% 0% 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 (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(a) Interest (b) Foreign
Rate Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 33,934,486 $0 0% 0% 0% 3.87 % 0% 0%
10-149% $ 80,299,337 $ 3,696,000 0% 0% 0% 65.9 % 0% 0%
150% or more $0 $0 0% 0% 0% 0% 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% $ $
10-149% $ $
150% or more $ $
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
SECTION 5.K.(3) Custodians for Separately Managed Accounts
Complete a separate Schedule D Section 5.K.(3) for each custodian that holds ten percent or more of your aggregate separately managed account
regulatory assets under management.
(a) Legal name of custodian:
PERSHING LLC
(b) Primary business name of custodian:
PERSHING LLC
(c) The location(s) of the custodian's office(s) responsible for custody of the assets :
City: State: Country:
JERSEY CITY New Jersey United States
Yes No
(d) Is the custodian a related person of your firm?
(e) If the custodian is a broker-dealer, provide its SEC registration number (if any)
8 - 17574
(f) If the custodian is not a broker-dealer, or is a broker-dealer but does not have an SEC registration number, provide its legal entity identifier (if
any)
(g) What amount of your regulatory assets under management attributable to separately managed accounts is held at the custodian?
$ 18,904,727,986
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.
BROKERAGE, INSURANCE SERVICES, AND MERGERS AND ACQUISITIONS.
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:
BENJAMIN F. EDWARDS WEALTH MANAGEMENT, LLC
2. Primary Business Name of Related Person:
BENJAMIN F. EDWARDS WEALTH MANAGEMENT, LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 113797
or
Other
4. Related Person's
(a) CRD Number (if any):
297750
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the
presumption that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not
required to obtain a surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
2. Primary Business Name of Related Person:
BENJAMIN F. EDWARDS & COMPANY, INCORPORATED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 71421
or
Other
4. Related Person's
(a) CRD Number (if any):
146936
(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:
ONE NORTH BRENTWOOD BLVD SUITE 850
City: State: Country: ZIP+4/Postal Code:
ST. LOUIS Missouri United States 63105
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next
sentence and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt
reporting adviser, and another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section
7.B.(1) of Schedule D of its Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must,
instead, complete Section 7.B.(2) of Schedule D.
In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical
code, or similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or
designation in place of the fund's name.
SECTION 7.B.(1) Private Fund Reporting
No Information Filed
SECTION 7.B.(2) Private Fund Reporting
No Information Filed
Item 8 Participation or Interest in Client Transactions
In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which
conflicts of interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation
and interest that you expect to engage in during the next year.
Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.
Proprietary Interest in Client Transactions
A. Do you or any related person: Yes No
(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?
(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?
(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary
(ownership) interest (other than those mentioned in Items 8.A.(1) or (2))?
Sales Interest in Client Transactions
B. Do you or any related person: Yes No
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory
client securities are sold to or bought from the brokerage customer (agency cross transactions)?
(2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for
which you or any related person serves as underwriter or general or managing partner?
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than
the receipt of sales commissions as a broker or registered representative of a broker-dealer)?
Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the: Yes No
(1) securities to be bought or sold for a client's account?
(2) amount of securities to be bought or sold for a client's account?
(3) broker or dealer to be used for a purchase or sale of securities for a client's account?
(4) commission rates to be paid to a broker or dealer for a client's securities transactions?
D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?
E. Do you or any related person recommend brokers or dealers to clients?
F. If you answer "yes" to E. above, are any of the brokers or dealers related persons?
G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party
("soft dollar benefits") in connection with client securities transactions?
(2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under
section 28(e) of the Securities Exchange Act of 1934?
H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?
(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for
the firm (cash or non-cash compensation in addition to the employee's regular salary)?
I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related
person) for client referrals?
In your response to Item 8.I., do not include the regular salary you pay to an employee.
In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received
from (in answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client
referrals.
Item 9 Custody
In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the
Investment Company Act of 1940) assets and about your custodial practices.
A. (1) Do you have custody of any advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees
directly from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you
have overcome the presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.
(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which
you have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ 10,062,463,754 (b) 21,073
If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not
include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in
connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2).
Instead, include that information in your response to Item 9.B.(2).
B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).
(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which
your related persons have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ (b)
C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following
that apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements
are distributed to the investors in the pools.
(3) An independent public accountant conducts an annual surprise examination of client funds and securities.
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons
are qualified custodians for client funds and securities.
If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare
an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this
information with respect to the private funds you advise in Section 7.B.(1) of Schedule D).
D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian
(2) your related person(s) act as qualified custodian(s)
If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule
206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent
under rule 206(4)-2 of the Advisers Act.
E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last
fiscal year, provide the date (MM/YYYY) the examination commenced:
08/2025
F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act
as qualified custodians for your clients in connection with advisory services you provide to clients?
2
SECTION 9.C. Independent Public Accountant
You must complete the following information for each independent public accountant engaged to perform a surprise examination, perform an audit of a
pooled investment vehicle that you manage, or prepare an internal control report. You must complete a separate Schedule D Section 9.C. for each
independent public accountant.
(1) Name of the independent public accountant:
DELOITTE & TOUCHE, LLP
(2) The location of the independent public accountant's office responsible for the services provided:
Number and Street 1: Number and Street 2:
100 SOUTH 4TH STREET SUITE 300
City: State: Country: ZIP+4/Postal Code:
ST. LOUIS Missouri United States 63102
Yes No
(3) Is the independent public accountant registered with the Public Company Accounting Oversight Board?
If "yes," Public Company Accounting Oversight Board-Assigned Number:
34
(4) If "yes" to (3) above, is the independent public accountant subject to regular inspection by the Public Company Accounting Oversight Board in
accordance with its rules?
(5) The independent public accountant is engaged to:
A. audit a pooled investment vehicle
B. perform a surprise examination of clients' assets
C. prepare an internal control report
(6) Since your last annual updating amendment, did all of the reports prepared by the independent public accountant that audited the pooled investment
vehicle or that examined internal controls contain unqualified opinions?
Yes
No
Report Not Yet Received
If you check "Report Not Yet Received", you must promptly file an amendment to your Form ADV to update your response when the accountant's report is
available.
Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10
should be provided for the filing adviser only.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners
and executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported
on either Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
If yes, complete Section 10.A. of Schedule D.
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please complete Section 10.B. of Schedule D.
SECTION 10.A. Control Persons
No Information Filed
SECTION 10.B. Control Person Public Reporting Companies
No Information Filed
Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to
determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an
investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than
one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an
umbrella registration.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all
of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you.
If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.
If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years
following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your
disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of
calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary
orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.
Yes No
Do any of the events below involve you or any of your supervised persons?
For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
(2) been charged with any felony?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to
charges that are currently pending.
B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving:
investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to
charges that are currently pending.
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?
(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business
denied, suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory
affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule
violation" under a plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you
or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or
suspended?
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
11.D., or 11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by
a state or foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?
Item 12 Small Businesses
The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine
whether you meet the definition of "small business" or "small organization" under rule 0-7.
Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets
under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a
current state registration, or switching from SEC to state registration.
For purposes of this Item 12 only:
Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total
assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with
subsidiaries included, if that amount is larger).
Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by
contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent
or more of the profits, of another person is presumed to control the other person.
Yes No
A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?
If "yes," you do not need to answer Items 12.B. and 12.C.
B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV)
of $25 million or more on the last day of its most recent fiscal year?
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal
year?
C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in
response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year?
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the
last day of its most recent fiscal year?
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive
officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is
required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar
status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a
public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a
class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild,
grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-
law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to
purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has
contributed, 5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5%
or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or
member; and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and
Last Name, First Name, Middle Acquired Code Person Date of Birth, IRS Tax No. or
Name) MM/YYYY Employer ID No.
EDWARDS, BENJAMIN FRANKLIN IV I CHAIRMAN/CHIEF EXECUTIVE 08/2008 NA Y N 1061490
OFFICER, PRESIDENT
BENJAMIN EDWARDS, INC. DE OWNER 10/2008 E Y N
MARTIN, THOMAS HAYDEN JR I DIRECTOR/CHIEF FINANCIAL 09/2009 NA Y N 1459719
OFFICER
KELLER, CHRISTOPHER M I DIRECTOR/DIRECTOR OF 04/2010 NA Y N 4346617
BUSINESS SERVICES
RUBENSTEIN, DOUGLAS DAVID I DIRECTOR/SENIOR ADVISOR 01/2026 NA Y N 1138380
TO THE CHAIRMAN
WISDOM, BILLY JOE I DIRECTOR/DIRECTOR OF 01/2015 NA Y N 1810908
REGULATORY & OVERSIGHT
SERVICES
WHITING, CHRISTOPHER MARK I DIRECTOR OF FINANCIAL 09/2018 NA Y N 2242513
STRATEGIES GROUP
STEVENS, KATELYN CLARE I CHIEF COMPLIANCE OFFICER, 01/2021 NA Y N 5752247
BROKERAGE
MUCKLER, MATTHEW PAUL I CHIEF COMPLIANCE OFFICER, 01/2021 NA Y N 4762147
ADVISORY
BRANDSTADT, TODD HEINRICH I DIRECTOR/DIRECTOR OF 01/2025 NA Y N 2631699
BRANCHES
EDWARDS, BENJAMIN FRANKLIN I DIRECTOR/ASSISTANT 09/2024 NA Y N 6670972
DIRECTOR OF BRANCHES
TAYLOR, GWENDOLYN MADISON I DIRECTOR/CHIEF LEGAL 01/2026 NA Y N 4812432
COUNSEL
EGGLESTON, BROOKE DANIELLE I DIRECTOR/CHIEF HUMAN 01/2024 NA Y N 7528898
RESOURCE OFFICER
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct
the sale of, 25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence;
or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon
dissolution, or have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have
contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of
the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or
members, the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
No Information Filed
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
*** NOTE 1 of 2 *** On Schedule D section 5.K.(1)(b), the form only permits the percentages of each Asset Type to be expressed as whole numbers. Four
different categories of Asset Types comprised less than 0.5% of BFE's regulatory assets under management, so BFE percentage holdings indicate 0%. These
categories included: (vi) Investment Grade Corporate Bonds – 0.469%; (vii) Non Investment Grade Corporate Bonds – 0.084%; (viii) Derivatives – 0.044%;
and (xii) Other - 0.0003% *** NOTE 2 of 2 *** For purposes of section 9.A.(2)(a)&(b), BFE has custody of client assets for situations in which a client has
provided written standing instructions to BFE for the periodic movement of client assets outside BFE.
Schedule R
No Information Filed
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 4264944
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: PINNELL, MARCY, B.
(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 CALIFORNIA DEPARTMENT OF INSURANCE
2. Principal Sanction:
Other
Other Sanctions:
REVOCATION AND ISSUANCE OF RESTRICTED LICENSE
3. Date Initiated (MM/DD/YYYY):
12/08/2015 Exact Explanation
If not exact, provide explanation:
THE ORDER OF SUMMARY REVOCATION AND ISSUANCE OF RESTRICTED LICENSE IS NOT DATED; HOWEVER, THE DECLARATION OF SERVICE IS DATED
12/8/15. I WAS NOT AWARE OF THIS MATTER UNTIL I RECEIVED THIS ORDER ON 12/11/15 VIA CERTIFIED MAIL.
4. Docket/Case Number:
LCB 1681-A
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
EDWARD JONES
6. Principal Product Type:
Annuity(ies) - Fixed
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
BASED SOLELY ON THE ACTIONS TAKEN BY FINRA IN JUNE 2014, THE STATE OF CALIFORNIA DEPARTMENT OF INSURANCE HAS ISSUED THE ORDER OF
SUMMARY REVOCATION AND ISSUANCE OF RESTRICTED LICENSE.
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):
12/08/2015 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:
ISSUANCE OF RESTRICTED LICENSE
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:
ISSUANCE OF RESTRICTED LICENSE
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).
NO FURTHER ACTION NEEDED.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 2376424
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: SWART, ANTHONY, KEVIN
(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)
MICHIGAN
2. Principal Sanction:
Other
Other Sanctions:
NOTICE OF INTENT TO DENY, CONDITION, OR LIMIT AGENT REGISTRATION APPLICATION
3. Date Initiated (MM/DD/YYYY):
06/14/2018 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
336358
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
BENJAMIN F. EDWARDS
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):
THE DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS FOR THE STATE OF MICHIGAN HAS ISSUED A NOTICE OF INTENT TO DENY, CONDITION, OR
LIMIT THE SECURITIES AGENT'S REGISTRATION APPLICATION IN THE STATE OF MICHIGAN UNDER SECTION 412(1) OF THE SECURITIES ACT, MCL
451.2412(1), FOR THE REASONS SET FORTH IN THE NOTICE.
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):
09/25/2018 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: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
STIPULATION AND ORDER FOR WITHDRAWAL
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:
STIPULATION AND ORDER FOR WITHDRAWAL
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).
STIPULATION AND ORDER FOR WITHDRAWAL REQUIRED WITHDRAWAL OF THE REGISTRATION REQUEST IN MICHIGAN.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
3-19054
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IA RELEASE 40-5151 / MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT
PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST BENJAMIN F. EDWARDS & CO., INC. ("RESPONDENT"). ON
THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY
DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE
FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL
FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE
ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR
OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES
THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH
MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
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 RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $3,151,205.81 AND PREJUDGMENT INTEREST
OF $294,058.93, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY,
IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $3,151,205.81 AND PREJUDGMENT
INTEREST OF $294,058.93, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. RESPONDENT SELF-REPORTED
TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION
DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-
REPORTED BY RESPONDENT.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 2212337
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: HAJRA, DEBASISH
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2. Principal Sanction:
Suspension
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
08/20/2021 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2019064919301
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
WELLS FARGO CLEARING SERVICES, LLC
6. Principal Product Type:
Unit Investment Trust(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING THE FINDINGS, HAJRA CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT HE EFFECTED NINE
UNAUTHORIZED TRADES IN A DECEASED CUSTOMER'S ACCOUNT. THE FINDINGS STATED THAT THIS MATTER ORIGINATED FROM THE UNIFORM
TERMINATION NOTICE FOR SECURITIES INDUSTRY REGISTRATION (FORM U5) FILING BY HAIRA'S MEMBER FIRM THAT STATED HE HAD BEEN TERMINATED
FOR MAKING TRADES IN A CUSTOMER'S ACCOUNT, BASED UPON PRIOR VERBAL AUTHORIZATION, WHILE UNAWARE THAT THE CLIENT HAD DIED. THE
FINDINGS ALSO STATED THAT THE CUSTOMER AUTHORIZED HAIRA TO MAKE SEVERAL TRADES IN HER ACCOUNT, BUT HE HAD NOT EFFECTUATED ANY
OF THE TRADES AT THE TIME OF HER DEATH. AFTER THE CUSTOMER'S DEATH, HAIRA BEGAN EXECUTING THE TRANSACTIONS. THE TOTAL VALUE OF THE
TRANSACTIONS WAS $526,966.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
08/20/2021 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: $ 5,000.00
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:
30 DAY SUSPENSION OF ALL ACTIVITIES. START DATE 09/20/2021. END DATE 10/19/2021. $5000 PENALTY WAS PAID 09/08/2021.
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).
THIS MATTER IS NOW CLOSED.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Cease and Desist
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
11/13/2020 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
3-20153
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
N/A
6. Principal Product Type:
Other
Other Product Types:
EXCHANGE TRADED PRODUCTS ("COMPLEX ETPS").
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE SECURITIES AND EXCHANGE COMMISSION (SEC) DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLIC ADMINISTRATIVE AND
CEASE-AND-DESIST PROCEEDINGS BE, AND HEREBY ARE, INSTITUTED PURSUANT TO SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF 1934
(EXCHANGE ACT), AND SECTIONS 203(E) AND 203(K) OF THE INVESTMENT ADVISERS ACT OF 1940 (ADVISERS ACT) AGAINST BENJAMIN F. EDWARDS &
COMPANY, INC. (BENJAMIN EDWARDS). THE SEC FINDS THAT THIS MATTER CONCERNS BENJAMIN EDWARDS'S FAILURE REASONABLY TO SUPERVISE
CERTAIN OF ITS REGISTERED REPRESENTATIVES (BROKERAGE REPRESENTATIVES) AND INVESTMENT ADVISORY REPRESENTATIVES (ADVISORY
REPRESENTATIVES) WHO MADE UNSUITABLE RECOMMENDATIONS TO ITS RETAIL BROKERAGE CUSTOMERS AND ADVISORY CLIENTS THAT THEY BUY AND
HOLD FOR EXTENDED PERIODS TWO COMPLEX EXCHANGE TRADED PRODUCTS THAT WERE INTENDED FOR SHORT-TERM HOLDING (COMPLEX ETPS).
THESE BROKERAGE REPRESENTATIVES MADE THESE RECOMMENDATIONS TO BUY AND HOLD THE COMPLEX ETPS WITHOUT HAVING A REASONABLE
BASIS TO DO SO. SIMILARLY, THE BROKERAGE AND ADVISORY REPRESENTATIVES FAILED TO MAKE A REASONABLE DETERMINATION THAT THESE
INVESTMENTS WERE SUITABLE FOR CERTAIN OF THE CUSTOMERS AND CLIENTS TO WHOM THEY RECOMMENDED THE COMPLEX ETPS, BASED ON THOSE
RETAIL CUSTOMERS' AND CLIENTS' INVESTMENT OBJECTIVES, RISK TOLERANCE, AND FINANCIAL CONDITION. A NUMBER OF THESE BROKERAGE AND
ADVISORY REPRESENTATIVES ALSO MISLED THEIR CUSTOMERS AND CLIENTS ABOUT THE COMPLEX ETPS' BENEFITS AND RISKS. BENJAMIN EDWARDS
FAILED REASONABLY TO IMPLEMENT ITS SUPERVISORY POLICIES AND PROCEDURES TO PREVENT AND DETECT THESE VIOLATIONS AND FAILED TO
IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT ITS ADVISORY REPRESENTATIVES FROM MAKING UNSUITABLE
RECOMMENDATIONS TO ITS CLIENTS. FROM JANUARY 2016 THROUGH MARCH 2020, CERTAIN BROKERAGE AND ADVISORY REPRESENTATIVES
RECOMMENDED THAT MANY OF THEIR RETAIL BROKERAGE CUSTOMERS AND ADVISORY CLIENTS BUY AND HOLD ONE OR MORE OF THE COMPLEX ETPS
FOR MANY MONTHS AT A TIME, AS A HEDGE AGAINST THE ANTICIPATED MARKED DECLINE. THE COMPLEX ETPS WERE: (1) THE IPATH S&P 500 VIX
SHORT-TERM FUTURES ETN, AND (2) THE PROSHARES VIX SHORT-TERM FUTURES ETF. THE OFFERING DOCUMENTS GENERALLY DISCLOSED THAT THE
PRODUCTS CARRIED A HIGHER RISK OF SIGNIFICANT LOSSES IF HELD FOR EXTENDED PERIODS. THE BROKERAGE AND ADVISORY REPRESENTATIVES
MISUNDERSTOOD THE COMPLEX ETPS, OR IGNORED THESE DISCLOSURES, AND MADE UNSUITABLE RECOMMENDATIONS TO CUSTOMERS AND CLIENTS
THAT THEY BUY AND HOLD THE COMPLEX ETPS. BENJAMIN EDWARDS FAILED REASONABLY TO IMPLEMENT ITS SUPERVISORY POLICIES AND
PROCEDURES THAT WERE INTENDED TO PROVIDE ASSURANCE THAT ITS BROKERAGE REPRESENTATIVES HAD A REASONABLE BASIS TO RECOMMEND
COMPLEX PRODUCTS SUCH AS THE COMPLEX ETPS TO THEIR CUSTOMERS; FAILED TO IMPLEMENT ITS SUPERVISORY POLICIES AND PROCEDURES THAT
WERE INTENDED TO PROVIDE ASSURANCE THAT ITS BROKERAGE REPRESENTATIVES AND ADVISORY REPRESENTATIVES MADE REASONABLE
DETERMINATIONS THAT THE INVESTMENTS IN COMPLEX ETPS WERE SUITABLE FOR EACH INDIVIDUAL BROKERAGE CUSTOMER OR ADVISORY CLIENT; IN
ADDITION, AND FAILED TO IMPLEMENT ADVISORY POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT UNSUITABLE RECOMMENDATIONS
THAT THEIR RETAIL ADVISORY CLIENTS BUY AND HOLD THE COMPLEX ETPS FOR EXTENDED PERIODS. AS A RESULT, BENJAMIN EDWARDS'S RETAIL
BROKERAGE CUSTOMERS AND ADVISORY CLIENTS BOUGHT AND HELD THE COMPLEX ETPS FOR EXTENDED PERIODS IN APPROX. 201 ACCOUNTS AND
LOST ON AVERAGE MORE THAN 41 PERCENT OF THE AMOUNTS THEY INVESTED. BENJAMIN EDWARDS FAILED REASONABLY TO SUPERVISE ITS
BROKERAGE AND ADVISORY REPRESENTATIVES WITH RESPECT TO THEIR UNSUITABLE RECOMMENDATIONS TO CUSTOMERS AND CLIENTS, WITHIN THE
MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT AND SECTION 203(E)(6) OF THE ADVISERS ACT, AND WITH A VIEW TO PREVENTING AND
DETECTING THEIR VIOLATIONS OF SECTIONS 17(A)(2) AND 17(A)(3) OF THE SECURITIES ACT. BENJAMIN EDWARDS VIOLATED SECTION 206(4) AND
RULE 206(4)-7 THEREUNDER.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
11/13/2020 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: $ 650,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
PREJUDGMENT INTEREST ON DISGORGEMENT
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:
IT IS HEREBY ORDERED THAT BENJAMIN EDWARDS CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE
VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; IS CENSURED FOR FAILING REASONABLY TO
SUPERVISE WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT AND SECTION 203(E) OF THE ADVISERS ACT AND FOR ITS
WILLFUL VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER; AND SHALL PAY DISGORGEMENT OF
$31,417.62, PREJUDGMENT INTEREST OF $3,716.74, AND A CIVIL MONETARY PENALTY OF $650,000.
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).
BENJAMIN EDWARDS HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. BENJAMIN EDWARDS
WILLFULLY VIOLATED SECTION 206(4) AND RULE 206(4)-7 THEREUNDER. ACCORDINGLY, IT IS HEREBY ORDERED THAT BENJAMIN EDWARDS CEASE
AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE
206(4)-7 THEREUNDER; IS CENSURED FOR FAILING REASONABLY TO SUPERVISE WITHIN THE MEANING OF SECTION 15(B)(4)(E) OF THE EXCHANGE ACT
AND SECTION 203(E) OF THE ADVISERS ACT AND FOR ITS WILLFUL VIOLATIONS OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7
THEREUNDER; AND SHALL PAY DISGORGEMENT OF $31,417.62, PREJUDGMENT INTEREST OF $3,716.74, AND A CIVIL MONETARY PENALTY OF $650,000.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
3-19054
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Money Market Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IA RELEASE 40-5151 / MARCH 11, 2019: THE SECURITIES AND EXCHANGE COMMISSION DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT
PUBLIC ADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE INSTITUTED AGAINST BENJAMIN F. EDWARDS & CO., INC. ("RESPONDENT"). ON
THE BASIS OF THIS ORDER AND RESPONDENT'S OFFER, THE COMMISSION FINDS THAT THESE PROCEEDINGS ARISE OUT OF BREACHES OF FIDUCIARY
DUTY AND INADEQUATE DISCLOSURES BY THE RESPONDENT IN CONNECTION WITH ITS MUTUAL FUND SHARE CLASS SELECTION PRACTICES AND THE
FEES IT RECEIVED. AT TIMES DURING THE RELEVANT PERIOD, RESPONDENT PURCHASED, RECOMMENDED, OR HELD FOR ADVISORY CLIENTS MUTUAL
FUND SHARE CLASSES THAT CHARGED 12B-1 FEES INSTEAD OF LOWER-COST SHARE CLASSES OF THE SAME FUNDS FOR WHICH THE CLIENTS WERE
ELIGIBLE. RESPONDENT RECEIVED 12B-1 FEES IN CONNECTION WITH THESE INVESTMENTS. RESPONDENT FAILED TO DISCLOSE IN ITS FORM ADV OR
OTHERWISE THE CONFLICTS OF INTEREST RELATED TO (A) ITS RECEIPT OF 12B-1 FEES, AND/OR (B) ITS SELECTION OF MUTUAL FUND SHARE CLASSES
THAT PAY SUCH FEES. DURING THE RELEVANT PERIOD, RESPONDENT RECEIVED 12B-1 FEES FOR ADVISING CLIENTS TO INVEST IN OR HOLD SUCH
MUTUAL FUND SHARE CLASSES. AS A RESULT OF THE CONDUCT, RESPONDENT WILLFULLY VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
8. Current Status? Pending On Appeal Final
9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Order
11. Resolution Date (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
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 RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $3,151,205.81 AND PREJUDGMENT INTEREST
OF $294,058.93, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
RESPONDENT HAS SUBMITTED AN OFFER OF SETTLEMENT WHICH THE COMMISSION HAS DETERMINED TO ACCEPT. IN VIEW OF THE FOREGOING, THE
COMMISSION DEEMS IT APPROPRIATE IN THE PUBLIC INTEREST TO IMPOSE THE SANCTIONS AGREED TO IN THE RESPONDENT'S OFFER. ACCORDINGLY,
IT IS ORDERED THAT RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF
SECTIONS 206(2) AND 207 OF THE ADVISERS ACT. RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $3,151,205.81 AND PREJUDGMENT
INTEREST OF $294,058.93, AND SHALL COMPLY WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT. RESPONDENT SELF-REPORTED
TO THE COMMISSION THE VIOLATIONS DISCUSSED IN THIS ORDER PURSUANT TO THE DIVISION OF ENFORCEMENT'S SHARE CLASS SELECTION
DISCLOSURE INITIATIVE ("SCSD INITIATIVE"). ACCORDINGLY, THIS ORDER AND RESPONDENT'S OFFER ARE BASED ON THE INFORMATION SELF-
REPORTED BY RESPONDENT.
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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2. Principal Sanction:
Other
Other Sanctions:
N/A
3. Date Initiated (MM/DD/YYYY):
01/30/2026 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2022073836301
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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
REASONABLY SUPERVISE ITS EMPLOYEES' BUSINESS-RELATED TEXT MESSAGES. THE FINDINGS STATED THAT THE FIRM'S SUPERVISORY SYSTEM,
INCLUDING ITS WRITTEN PROCEDURES, WAS NOT REASONABLY DESIGNED BECAUSE THE FIRM HAD NO PROCESS OR PROCEDURES, WRITTEN OR
OTHERWISE, FOR MONITORING FOR COMPLIANCE WITH ITS TEXT MESSAGING POLICIES. THE POLICIES GENERALLY PROHIBITED THE BUSINESS USE OF
TEXT MESSAGING EXCEPT THOSE SENT OR RECEIVED THROUGH A FIRM-APPROVED SOFTWARE THAT WOULD CAPTURE AND PRESERVE THE TEXT
MESSAGES. NOTWITHSTANDING THIS PROHIBITION, REGISTERED REPRESENTATIVES OF THE FIRM, INCLUDING AT LEAST ONE SENIOR EXECUTIVE,
USED TEXT MESSAGING FOR BUSINESS-RELATED COMMUNICATIONS THROUGH UNAPPROVED MEANS. IN ADDITION, DISCOVERY SANCTIONS WERE
IMPOSED AGAINST THE FIRM IN OCTOBER 2019, BUT THE FIRM FAILED TO TAKE REASONABLE STEPS TO COMPLY WITH ITS OBLIGATIONS TO
REASONABLY SUPERVISE, PRESERVE, AND REVIEW BUSINESS-RELATED COMMUNICATIONS DESPITE THIS RED FLAG. SUBSEQUENTLY, THE FIRM
RETAINED A CONSULTANT TO REVIEW THE FIRM'S SUPERVISION OF TEXT MESSAGING. BASED ON RECOMMENDATIONS FROM THE CONSULTANT, THE
FIRM ULTIMATELY HAD, AMONG OTHER THINGS, STRENGTHENED ITS WSPS CONCERNING TEXT MESSAGING, REQUIRED REGULAR CERTIFICATIONS
CONCERNING ITS TEXT MESSAGING POLICIES, INCREASED COMMUNICATIONS AND TRAINING CONCERNING ITS TEXT MESSAGING POLICIES, AND
STRENGTHENED ITS ELECTRONIC COMMUNICATION MONITORING SYSTEMS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO OBTAIN OR
PRESERVE ALL BUSINESS-RELATED TEXT MESSAGES AT THE TIME THEY WERE EXCHANGED. AT LEAST FIVE REGISTERED REPRESENTATIVES, INCLUDING
ONE SENIOR EXECUTIVE, SENT AND RECEIVED AT LEAST 3,560 TEXT MESSAGES TO COMMUNICATE ABOUT FIRM BUSINESS THROUGH UNAPPROVED
TEXT MESSAGING APPLICATIONS ON THEIR PERSONAL DEVICES. THESE TEXT MESSAGES INVOLVED, AMONG OTHER THINGS, RECEIVING INVESTMENT
DIRECTIVES AND SENSITIVE PERSONAL INFORMATION FROM CUSTOMERS AND GIVING INVESTMENT ADVICE TO CUSTOMERS. THE FIRM WAS ABLE TO
RECOVER CERTAIN OF THESE TEXT MESSAGES DURING FINRA'S INVESTIGATION. THE FINDINGS ALSO INCLUDED THAT THE FIRM FAILED TO COMPLY
WITH ITS DISCOVERY OBLIGATIONS IN A FINRA ARBITRATION. IN SEPTEMBER 2017, ANOTHER FINRA MEMBER FIRM FILED AN ARBITRATION AGAINST
THE FIRM AND CERTAIN OF ITS REGISTERED REPRESENTATIVES RELATED TO ITS RECRUITING OF FOUR OF ITS REGISTERED REPRESENTATIVES. THE
FIRM RECEIVED DISCOVERY REQUESTS IN DECEMBER 2017 FOR ELECTRONIC COMMUNICATIONS RELEVANT TO THE DISPUTE DATING BACK TO BEFORE
SEPTEMBER 2016. THE ARBITRATION PANEL ISSUED ORDERS IN OCTOBER 2018 COMPELLING THE FIRM TO PRODUCE THE REQUESTED
COMMUNICATIONS BY NOVEMBER 2018, WHICH INCLUDED BUSINESS-RELATED TEXT MESSAGES. THE FIRM FAILED TO TIMELY AND FULLY COMPLY
WITH THE ARBITRATION PANEL'S ORDERS, AND THE ARBITRATION PANEL ISSUED AN ORDER IN MAY 2019 IMPOSING SANCTIONS. IN JULY 2019, THE
ARBITRATION PANEL PAUSED THE PROCEEDING AND ORDERED DEPOSITIONS OF REGISTERED REPRESENTATIVES OF THE FIRM RELATED TO, AMONG
OTHER THINGS, POTENTIALLY DISCOVERABLE TEXT MESSAGES. THE DEPOSITIONS REVEALED THE EXISTENCE OF RESPONSIVE TEXT MESSAGES THAT
HAD NOT BEEN PRODUCED IN DISCOVERY. SUBSEQUENTLY, THE FIRM WAS BELATEDLY ABLE TO OBTAIN AND PRODUCE SOME, BUT NOT ALL, OF THE
RESPONSIVE TEXT MESSAGES. IN OCTOBER 2019, THE ARBITRATION PANEL ISSUED A SECOND ORDER IMPOSING ADDITIONAL SANCTIONS BECAUSE
THE FIRM DID NOT CURE THE DISCOVERY DEFICIENCY.
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:
Acceptance, Waiver & Consent(AWC)
11. Resolution Date (MM/DD/YYYY):
01/30/2026 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: $ 750,000.00
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:
THE FIRM WAS CENSURED AND FINED $750,000. FINE PAID IN FULL ON FEBRUARY 10, 2026.
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).
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
Part 2
Exemption from brochure delivery requirements for SEC-registered advisers
SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a
brochure to all of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules?
If no, complete the ADV Part 2 filing below.
Amend, retire or file new brochures:
Brochure ID Brochure Name Brochure Type(s)
418167 FIRM BROCHURE Individuals, High net worth individuals, Pension
plans/profit sharing plans, Pension consulting,
Foundations/charities, Government/municipal, Other
institutional, Financial Planning Services, Other
418168 WRAP PROGRAM Wrap program
428878 WRAP PROGRAM Wrap program
428879 FIRM BROCHURE Individuals, High net worth individuals, Pension
plans/profit sharing plans, Pension consulting,
Foundations/charities, Government/municipal, Other
institutional, Financial Planning Services, Other
Part 3
CRS Type(s) Affiliate Info Retire
Dual
Execution Pages
DOMESTIC INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the Secretary of State or other legally designated officer, of the
state in which you maintain your principal office and place of business and any other state in which you are submitting a notice filing, as your agents to
receive service, and agree that such persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand
for arbitration, or other process or papers, and you further agree that such service may be made by registered or certified mail, in any federal or state
action, administrative proceeding or arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding, or
arbitration (a) arises out of any activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b)
is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939,
the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of the state
in which you maintain your principal office and place of business or of any state in which you are submitting a notice filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the investment adviser. The investment adviser and I both certify, under
penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
CRAIG HARRISON 03/31/2026
Printed Name: Title:
CRAIG HARRISON SR. REGISTRATION MANAGER
Adviser CRD Number:
146936
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to
the SEC and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or
other legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such
persons may accept service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or
papers, and you further agree that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or
arbitration brought against you in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any
activity in connection with your investment advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly,
upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a
notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws
from or is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this
irrevocable power of attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in
Washington D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission,
correct, current, and complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940.
This undertaking shall be binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of
attorney or any of your general partners and managing agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both
certify, under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits
and any other information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having
custody or possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
146936