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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: STEPHENS CRD Number: 3496
Other-Than-Annual Amendment - All Sections Rev. 10/2021
6/25/2026 1:45:16 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):
STEPHENS INC.
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
STEPHENS
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: 801-15510
(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
94074
757657
1957244
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 3496
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:
111 CENTER ST
City: State: Country: ZIP+4/Postal Code:
LITTLE ROCK Arkansas United States 72201
If this address is a private residence, check this box:
List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If you are
applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to which you are
applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or if you are reporting to
the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your most recently completed fiscal
year.
(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:
Normal business hours at this location:
8:00AM TO 5:00PM
(3) Telephone number at this location:
501-377-2000
(4) Facsimile number at this location, if any:
501-377-2495
(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?
20
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:
213800LH6T9XDYZCA534
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: STEPHENS SPECTRUM 401K
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
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: STEPHENSCHOICE
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
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: STEPHENS CAPITAL MANAGEMENT
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
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: STEPHENS FIXED INCOME MANAGEMENT
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
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: STEPHENS ALLOCATION STRATIGIES PROGRAM
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
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: PROFESSIONAL WEALTH MANAGEMENT PROGRAM
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
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: STEPHENS CAPITAL MANAGEMENT FIXED INCOME STRATEGY
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
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: STEPHENS SPECTRUM PROGRAM
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
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: STEPHENS CAPITAL MANAGEMENT - PENSION MANAGEMENT TRUST PROGRAM
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
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: STEPHENS SMALL-MID CAP GROWTH PROGRAM
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
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: STEPHENS ADVISOR NON-DISCRETIONARY PROGRAM
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
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: STEPHENS CAPITAL MANGEMENT - HEALTH MANAGEMENT TRUST
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
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: STEPHENS MANAGED ASSETS PROGRAM
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
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: STEPHENS CAPITAL MANAGEMENT NON-DISCRETIONARY
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
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: STEPHENS RETIREMENT SOLUTIONS PROGRAM
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
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: STEPHENS RETIREMENT ACCESS
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
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: STEPHENS INC. EQUITY RESEARCH SERVICES PROGRAM
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
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: STEPHENS UNIFIED MANAGED ACCOUNT
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:
191 NORTH WACKER SUITE 925
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:
312-292-5750 312-292-5760
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:
104337
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
RESEARCH, MARKET MAKING/TRADING, INVESTMENT BANKING/UNDERWRITING
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:
161 TELEVISION HILL ROAD
City: State: Country: ZIP+4/Postal Code:
HOT SPRINGS Arkansas United States 71913
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
501-609-4100 501-609-4115
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:
169911
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:
7600 FERN AVENUE BUILDING 1300, SUITE 1100
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:
318-934-6100 318-934-6110
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:
555753
How many employees perform investment advisory functions from this office location?
4
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You
must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are
an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
3425 N FUTRALL DRIVE SUITE 201
City: State: Country: ZIP+4/Postal Code:
FAYETTEVILLE Arkansas United States 72703
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
479-718-7400 479-718-7490
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:
104334
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:
PUBLIC FINANCE
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:
2479 BROWNS LANE
City: State: Country: ZIP+4/Postal Code:
JONESOBORO Arkansas United States 72401
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
870-819-0300 870-819-0310
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:
376506
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You
must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are
an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
3344 PEACHTREE ROAD SUITE #2000
City: State: Country: ZIP+4/Postal Code:
ATLANTA Georgia United States 30326
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
404-461-5100 404-461-5140
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:
104332
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:
INVESTMENT BANKING/UNDERWRITING
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:
140 TOWNSHIP AVENUE SUITE 202
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:
601-605-5675 601-605-5680
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:
391999
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
PUBLIC FINANCE
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You
must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are
an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
100 CONGRESS AVENUE SUITE 750
City: State: Country: ZIP+4/Postal Code:
AUSTIN Texas United States 78701
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
512-542-3200 512-542-3275
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:
169914
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You
must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are
an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
3100 WEST END AVE ONE AMERICAN CENTER STE 630
City: State: Country: ZIP+4/Postal Code:
NASHVILLE Tennessee United States 37203
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
615-279-4300 615-279-4365
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:
169910
How many employees perform investment advisory functions from this office location?
5
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
INVESTMENT BANKING/ UNDERWRITING, PUBLIC FINANCE
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:
1320 MAIN STREET SUITE 550
City: State: Country: ZIP+4/Postal Code:
COLUMBIA South Carolina United States 29201
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
803-343-0100 803-343-0110
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:
261926
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:
225 COMMERCIAL AVENUE SUITE 500
City: State: Country: ZIP+4/Postal Code:
PORTLAND Maine United States 04101
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
207-808-5025 207-808-5023
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:
606693
How many employees perform investment advisory functions from this office location?
2
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
RESEARCH
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:
4521 SHARON ROAD SUITE 200
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28211
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
704-442-5000 704-442-5055
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:
169908
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:
INVESTMENT BANKING/UNDERWRITING, MARKET MAKING/TRADING
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:
703 CHESTNUT STREET
City: State: Country: ZIP+4/Postal Code:
CONWAY Arkansas United States 72032
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
501-328-4000 501-328-4090
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:
104336
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:
660 FIFTH AVENUE FLOOR 26
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10103
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
212-891-1700 212-891-1750
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:
169912
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:
RESEARCH, MARKET MAKING/TRADING, INVESTMENT BANKING/UNDERWRITING
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:
CRESCENT CENTER 6075 POPLAR AVE SUITE 200
City: State: Country: ZIP+4/Postal Code:
MEMPHIS Tennessee United States 38119
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
901-681-1300 901-681-1375
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:
169915
How many employees perform investment advisory functions from this office location?
23
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:
101 S STRATFORD ROAD SUITE 200
City: State: Country: ZIP+4/Postal Code:
WINSTON SALEM North Carolina United States 27104
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
336-251-0400 336-251-0410
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:
447545
How many employees perform investment advisory functions from this office location?
23
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:
9 GREENWAY PLAZA SUITE 1900
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77046
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
713-993-4200 713-993-4250
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:
191612
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:
AFFILIATE INVESTMENT ADVISOR - STEPHENS INVESTMENT MANAGEMENT GROUP (SIMG)
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:
300 CRESCENT COURT SUITE 600
City: State: Country: ZIP+4/Postal Code:
DALLAS Texas United States 75201
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
214-258-2700 214-258-2750
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:
104333
How many employees perform investment advisory functions from this office location?
5
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
PUBLIC FINANCE, RESEARCH, INVESTMENT BANKING/UNDERWRITING
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:
9 GREENWAY PLAZA SUITE 1910
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77046
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
713-993-4216 713-993-4220
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:
191612
How many employees perform investment advisory functions from this office location?
3
Are other business activities conducted at this office location? (check all that apply)
(1) Broker-dealer (registered or unregistered)
(2) Bank (including a separately identifiable department or division of a bank)
(3) Insurance broker or agent
(4) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(5) Registered municipal advisor
(6) Accountant or accounting firm
(7) Lawyer or law firm
Describe any other investment-related business activities conducted from this office location:
Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business. You
must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or if you are
an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).
Number and Street 1: Number and Street 2:
3100 MARKET STREET SUITE 301
City: State: Country: ZIP+4/Postal Code:
ROGERS Arkansas United States 72758
If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
479-286-0200 479-286-0210
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:
441594
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:
RESEARCH
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: HTTP://STEPHENS.LIBSYN.COM/
Address of Website/Account on Publicly Available Social Media Platform: https://apps.apple.com/us/app/stephens-events/id1480282538
Address of Website/Account on Publicly Available Social Media Platform: https://www.jacksontstephenscup.com/
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/channel/UCrOe4NqKjQO7NYPRAT37Mvw
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/TICAPITALISM/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/ABOUT.STEPHENS/
Address of Website/Account on Publicly Available Social Media Platform: HTTP://THISISCAPITALISM.LIBSYN.COM/
Address of Website/Account on Publicly Available Social Media Platform: HTTP://STEPHENS.COM/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://TWITTER.COM/STEPHENS_INC
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.YOUTUBE.COM/@JACKSONT.STEPHENSCUP8689
Address of Website/Account on Publicly Available Social Media Platform: https://www.instagram.com/thestephenscup
Address of Website/Account on Publicly Available Social Media Platform: https://www.facebook.com/TheStephensCup/
Address of Website/Account on Publicly Available Social Media Platform: https://x.com/thestephenscup
Address of Website/Account on Publicly Available Social Media Platform: https://open.spotify.com/show/2ocMipFyc1ok2GbgcxWp0r?si=82C9aJF3SSGZPq_Pc78fgw
Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/showcase/this-is-capitalism/
Address of Website/Account on Publicly Available Social Media Platform: https://itunes.apple.com/us/podcast/this-is-capitalism-ceo-stories/id1270233928?mt=2
Address of Website/Account on Publicly Available Social Media Platform: https://instagram.com/thisiscapitalism
Address of Website/Account on Publicly Available Social Media Platform: https://vimeo.com/user15195929
Address of Website/Account on Publicly Available Social Media Platform: https://www.linkedin.com/company/stephens-inc-
Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.THISISCAPITALISM.ORG/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://TWITTER.COM/TICAPITALISM
Address of Website/Account on Publicly Available Social Media Platform: https://www.youtube.com/channel/UCsls9POCpO9038tGWG8GzRA
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:
STEPHENS INC.
Number and Street 1: Number and Street 2:
3425 N FUTRALL DRIVE SUITE 201
City: State: Country: ZIP+4/Postal Code:
FAYETTEVILLE Arkansas United States 72703
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
479-718-7400 479-718-7490
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
4521 SHARON ROAD SUITE 200
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28211
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
704-442-5000 704-442-5055
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
100 CONGRESS AVE SUITE 750
City: State: Country: ZIP+4/Postal Code:
AUSTIN Texas United States 78701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
512-542-3200 512-542-3275
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
101 S SRATFORD ROAD SUITE 200
City: State: Country: ZIP+4/Postal Code:
WINSTON-SALEM North Carolina United States 27104
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
336-251-0400 336-251-0410
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
3100 WEST END AVENUE ONE AMERICAN CENTER, SUITE 630
City: State: Country: ZIP+4/Postal Code:
NASHVILLE Tennessee United States 37203
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
615-279-4300 615-279-4365
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
DTCC/ITP
Number and Street 1: Number and Street 2:
55 WATER STREET
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10041
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-888-382-2721
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.
DTCC ITP IS THIRD-PARTY RECORDKEEPER FOR TRADE CONFIRMATIONS PREPARED AND ISSUED BY DTCC ITP THROUGH ITS TRADESUITE ID SERVICE (TRADESUITE
CONFIRMATIONS OR ID CONFIRMS
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
9 GREENWAY PLAZA SUITE 1910
City: State: Country: ZIP+4/Postal Code:
HOUSTON Texas United States 77046
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
713-993-0380 713-993-4220
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
161 TELEVISION HILL ROAD
City: State: Country: ZIP+4/Postal Code:
HOT SPRINGS Arkansas United States 71913
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
501-609-4100 501-609-4115
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
140 TOWNSHIP AVENUE SUITE 202
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:
601-605-5675 601-605-5680
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
225 COMMERCIAL AVENUE SUITE 500
City: State: Country: ZIP+4/Postal Code:
PORTLAND Maine United States 04101
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
207-808-5025 207-808-5023
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
703 CHESTNUT STREET
City: State: Country: ZIP+4/Postal Code:
CONWAY Arkansas United States 72032
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
501-328-4000 501-328-4090
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
300 CRESCENT COURT SUITE 600
City: State: Country: ZIP+4/Postal Code:
DALLAS Texas United States 75201
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
214-258-2700 214-258-2750
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
3100 MARKET STREET SUITE 301
City: State: Country: ZIP+4/Postal Code:
ROGERS Arkansas United States 72758
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
479-286-0200 479-286-0210
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISOR
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
2479 BROWNS LANE
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:
870-819-0300 870-819-0310
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
3344 PEACHTREE ROAD SUITE 2000
City: State: Country: ZIP+4/Postal Code:
ATLANTA Georgia United States 30326
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
404-461-5100 404-461-5140
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
PERSHING LLC
Number and Street 1: Number and Street 2:
ONE PERSHING PLAZA 4TH FLR
City: State: Country: ZIP+4/Postal Code:
JERSEY CITY New Jersey United States 07399
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
1-201-413-2000
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 IN A VARIETY OF MEDIA FORMATS ARE MAINTAINED BY OUR QUALIFIED CUSTODIAN
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
1 INTERNATIONAL PLACE 100 OLIVER ST, 29TH FLOOR
City: State: Country: ZIP+4/Postal Code:
BOSTON Massachusetts United States 02110
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
617-239-7500 617-239-7540
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
191 NORTH WACKER SUITE 925
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:
312-292-5750 312-292-5760
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.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
7600 FERN AVE BUILDING 1300
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:
318-934-6100 318-934-6100
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISOR.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
1320 MAIN STREET SUITE 550
City: State: Country: ZIP+4/Postal Code:
COLUMBIA South Carolina United States 29201
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
803-343-0100 803-343-0110
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
VITAL RECORDS CONTROL OF ARKANSAS
Number and Street 1: Number and Street 2:
1401 MURPHY DRIVE SUITE 14
City: State: Country: ZIP+4/Postal Code:
MAUMELLE Arkansas United States 72113
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
501-374-7775 501-374-7117
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 IN A VARIETY OF MEDIA FORMATS ARE MAINTAINED BY VITAL RECORDS CONTROL OF ARKANSAS, SOME OF WHICH ARE IN A SECURED VAULT.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
150 SECOND AVENUE NORTH SUITE 700
City: State: Country: ZIP+4/Postal Code:
ST PETERSBURG Florida United States 33701
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
727-502-3500 727-502-3550
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
601 13TH STREET, NW
City: State: Country: ZIP+4/Postal Code:
WASHINGTON District of Columbia United States 20005
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
202-807-0600
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
660 FIFTH AVE FLOOR 26
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10103
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
212-891-1700 212-891-1750
This is (check one):
one of your branch offices or affiliates.
a third-party unaffiliated recordkeeper.
other.
Briefly describe the books and records kept at this location.
ORIGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER.
Name of entity where books and records are kept:
STEPHENS INC.
Number and Street 1: Number and Street 2:
6075 POPLAR AVENUE SUITE 200
City: State: Country: ZIP+4/Postal Code:
MEMPHIS Tennessee United States 38119
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
901-681-1300 901-681-1375
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.
ORGINAL OR COPIES OF CERTAIN COMMUNICATIONS SENT TO OR RECEIVED BY THE ADVISER
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
List the name and country, in English, of each foreign financial regulatory authority with which you are registered. You must complete a separate Schedule D Section
1.M. for each foreign financial regulatory authority with whom you are registered.
Name of Country/Foreign Financial Regulatory Authority:
Canada - Ontario Securities Commission
Other:
Item 2 SEC Registration/Reporting
Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for SEC
registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2 should be
provided for the filing adviser only.
A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an annual
updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2 provides
information to help you determine whether you may affirmatively respond to each of these items.
You (the adviser):
(1) are a large advisory firm that either:
(a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or
(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating amendment
and is registered with the SEC;
(2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100 million (in
U.S. dollars) and you are either:
(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place of
business; or
(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;
Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities authority.
(3) Reserved
(4) have your principal office and place of business outside the United States;
(5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;
(6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the Investment
Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under management;
(7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption in rule
203A-2(a);
(8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is registered
with the SEC, and your principal office and place of business is the same as the registered adviser;
If you check this box, complete Section 2.A.(8) of Schedule D.
(9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;
If you check this box, complete Section 2.A.(9) of Schedule D.
(10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);
If you check this box, complete Section 2.A.(10) of Schedule D.
(11) are an Internet adviser relying on rule 203A-2(e);
If you check this box, complete Section 2.A.(11) of Schedule D.
(12) have received an SEC order exempting you from the prohibition against registration with the SEC;
If you check this box, complete Section 2.A.(12) of Schedule D.
(13) are no longer eligible to remain registered with the SEC.
State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they file with
the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy of reports and
any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would like to receive notice of
this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to additional state(s), check the
box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to
your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck the box(es) next to those state(s).
Jurisdictions
AL IL NE SC
AK IN NV SD
AZ IA NH TN
AR KS NJ TX
CA KY NM UT
CO LA NY VT
CT ME NC VI
DE MD ND VA
DC MA OH WA
FL MI OK WV
GA MN OR WI
GU MS PA WY
HI MO PR
ID MT RI
If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that state's
notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).
SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control with an
investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser, provide the following
information:
Name of Registered Investment Adviser
CRD Number of Registered Investment Adviser
SEC Number of Registered Investment Adviser
-
SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days
If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration within
120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to
have made the required representations. You must make both of these representations:
I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to register
with the SEC within 120 days after the date my registration with the SEC becomes effective.
I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section
203A(a) of the Advisers Act from registering with the SEC.
SECTION 2.A.(10) Multi-State Adviser
If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations about
your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.
If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:
I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an investment
adviser with the state securities authorities in those states.
I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15 states
to register as an investment adviser with the state securities authorities of those states.
If you are submitting your annual updating amendment, you must make this representation:
Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required by the
laws of at least 15 states to register as an investment adviser with the state securities authorities in those states.
SECTION 2.A.(11) Internet Adviser
If you are relying on rule 203A-2(e), the Internet adviser exemption from the prohibition on registration, you are required to make a representation about your
eligibility for SEC registration. By checking the appropriate box, you will be deemed to have made the required representation.
If you are applying for registration as an investment adviser with the SEC or changing your existing Item 2 response regarding your eligibility for SEC registration,
you must make this representation:
I will provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
If you are filing an annual updating amendment to your existing registration and are continuing to rely on the Internet adviser exemption for SEC registration, you
must make this representation:
I have provided and will continue to provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
SECTION 2.A.(12) SEC Exemptive Order
If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:
Application Number:
803-
Date of order:
Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation
Sole Proprietorship
Limited Liability Partnership (LLP)
Partnership
Limited Liability Company (LLC)
Limited Partnership (LP)
Other (specify):
If you are changing your response to this Item, see Part 1A Instruction 4.
B. In what month does your fiscal year end each year?
DECEMBER
C. Under the laws of what state or country are you organized?
State Country
Arkansas 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.
611
B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
247
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
611
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives?
247
(4) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives for an investment adviser other than you?
0
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
137
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
0
In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your
behalf.
Clients
In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those
investors.
C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during
your most recently completed fiscal year?
170
(2) Approximately what percentage of your clients are non-United States persons?
1%
D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not
include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940.
Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940,
do not answer (1)(d) or (3)(d) below.
Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to
each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than
respond to Item 5.D.(1).
The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under
management reported in Item 5.F.(2)(c) below.
If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you
advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as
applicable.
(1) Number of (2) Fewer than 5 (3) Amount of Regulatory Assets
Type of Client Client(s) Clients under Management
(a) Individuals (other than high net worth individuals) 18080 $ 4,125,401,840
(b) High net worth individuals 3088 $ 10,111,333,840
(c) Banking or thrift institutions 1 $ 29,055,020
(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 249 $ 226,541,669
government pension plans)
(h) Charitable organizations 21 $ 17,589,555
(i) State or municipal government entities (including government pension 11 $ 361,877,601
plans)
(j) Other investment advisers 0 $0
(k) Insurance companies 15 $ 123,129,132
(l) Sovereign wealth funds and foreign official institutions 0 $0
(m) Corporations or other businesses not listed above 188 $ 620,733,625
(n) Other: NON- CORPORATE ORGANZATIONS 338 $ 2,429,181,951
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) $ 13,826,378,185 (d) 12,927
Non-Discretionary: (b) $ 4,218,466,048 (e) 9,064
Total: (c) $ 18,044,844,233 (f) 21,991
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?
$ 22,761,053
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?
1,000 (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
$0
(b) portfolio manager for a wrap fee program?
$0
(c) sponsor to and portfolio manager for the same wrap fee program?
$ 18,044,844,233
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
PROFESSIONAL WEALTH MANAGEMENT
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS ADVISOR - NON DISCRETIONARY PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS ALLOCATION STRATIGIES PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS CAPITAL MANAGEMENT - HEALTH MANAGEMENT TRUST
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS CAPITAL MANAGEMENT - PENSION MANAGEMENT TRUST PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS CAPITAL MANAGEMENT FIXED INCOME STRATEGY
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS CAPITAL MANAGEMENT NON-DISCRETIONARY
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS CAPITAL MANAGMENT DISCRETIONARY PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS FIXED INCOME MANAGMENT
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS MANAGED ASSETS PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS RETIREMENT ACCESS
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS RETIREMENT SOLUTIONS PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS SMALL-MID CAP CORE GROWTH PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS SPECTRUM 401K
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS SPECTRUM PROGRAM
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENS UNIFIED MANAGED ACCOUNT
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
Name of Wrap Fee Program
STEPHENSCHOICE
Name of Sponsor
STEPHENS
Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 15510
Sponsor's CRD Number (if any):
3496
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 59 % 59 %
(ii) Non Exchange-Traded Equity Securities 1% 1%
(iii) U.S. Government/Agency Bonds 7% 7%
(iv) U.S. State and Local Bonds 3% 4%
(v) Sovereign Bonds 0% 0%
(vi) Investment Grade Corporate Bonds 1% 1%
(vii) Non-Investment Grade Corporate Bonds 1% 1%
(viii) Derivatives 0% 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 19 % 19 %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development 1 % 1%
Companies)
(xi) Cash and Cash Equivalents 4% 4%
(xii) Other 4% 3%
Generally describe any assets included in "Other"
MORTGAGE BACKS = LESS THAN 1% ALTERNATIVE INVESTMENTS = LESS THAN 1% EXTERNAL ASSETS = LESS THAN 1%
(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
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 16,444,534,017 $0 0% 0% 0% 0% 0% 0%
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(ii) End of Year
Gross Notional (1) Regulatory Assets (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 18,044,844,233 $0 0% 0% 0% 0% 0% 0%
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory
assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only
provide information with respect to the portion of the account that you subadvise.
In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional
exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of
any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.
In column 2, provide the dollar amount of borrowings for the accounts included in column 1.
You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than
$10,000,000.
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings
Less than 10% $ $
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?
$ 17,007,525,999
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.
FULL SERVICE BROKER DEALER
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:
STEPHENS INSURANCE, LLC
2. Primary Business Name of Related Person:
STEPHENS INSURANCE
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption
that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a
surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
STEPHENS EUROPE LIMITED
2. Primary Business Name of Related Person:
STEPHENS EUROPE LIMITED
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
-
or
Other
FCA616589
4. Related Person's
(a) CRD Number (if any):
(b) CIK Number(s) (if any):
No Information Filed
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption
that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a
surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
Name of Country/English Name of Foreign Financial Regulatory Authority
United Kingdom - Financial Conduct Authority
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
1. Legal Name of Related Person:
STEPHENS INVESTMENT MANAGEMENT GROUP, LLC
2. Primary Business Name of Related Person:
STEPHENS INVESTMENT MANAGEMENT GROUP, LLC
3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 64675
or
Other
4. Related Person's
(a) CRD Number (if any):
136369
(b) CIK Number(s) (if any):
CIK Number
1314440
5. Related Person is: (check all that apply)
(a) broker-dealer, municipal securities dealer, or government securities broker or dealer
(b) other investment adviser (including financial planners)
(c) registered municipal advisor
(d) registered security-based swap dealer
(e) major security-based swap participant
(f) commodity pool operator or commodity trading advisor (whether registered or exempt from registration)
(g) futures commission merchant
(h) banking or thrift institution
(i) trust company
(j) accountant or accounting firm
(k) lawyer or law firm
(l) insurance company or agency
(m) pension consultant
(n) real estate broker or dealer
(o) sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
(p) sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Yes No
6. Do you control or are you controlled by the related person?
7. Are you and the related person under common control?
8. (a) Does the related person act as a qualified custodian for your clients in connection with advisory services you provide to clients?
(b) If you are registering or registered with the SEC and you have answered "yes," to question 8.(a) above, have you overcome the presumption
that you are not operationally independent (pursuant to rule 206(4)-2(d)(5)) from the related person and thus are not required to obtain a
surprise examination for your clients' funds or securities that are maintained at the related person?
(c) If you have answered "yes" to question 8.(a) above, provide the location of the related person's office responsible for custody of your clients' assets:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
Yes No
9. (a) If the related person is an investment adviser, is it exempt from registration?
(b) If the answer is yes, under what exemption?
10. (a) Is the related person registered with a foreign financial regulatory authority ?
(b) If the answer is yes, list the name and country, in English of each foreign financial regulatory authority with which the related person is registered.
No Information Filed
11. Do you and the related person share any supervised persons?
12. Do you and the related person share the same physical location?
Item 7 Private Fund Reporting
Yes No
B. Are you an adviser to any private fund?
If "yes," then for each private fund that you advise, you must complete a Section 7.B.(1) of Schedule D, except in certain circumstances described in the next sentence
and in Instruction 6 of the Instructions to Part 1A. If you are registered or applying for registration with the SEC or reporting as an SEC exempt reporting adviser, and
another SEC-registered adviser or SEC exempt reporting adviser reports this information with respect to any such private fund in Section 7.B.(1) of Schedule D of its
Form ADV (e.g., if you are a subadviser), do not complete Section 7.B.(1) of Schedule D with respect to that private fund. You must, instead, complete Section 7.B.(2) of
Schedule D.
In either case, if you seek to preserve the anonymity of a private fund client by maintaining its identity in your books and records in numerical or alphabetical code, or
similar designation, pursuant to rule 204-2(d), you may identify the private fund in Section 7.B.(1) or 7.B.(2) of Schedule D using the same code or designation in place
of the fund's name.
SECTION 7.B.(1) Private Fund Reporting
No Information Filed
SECTION 7.B.(2) Private Fund Reporting
No Information Filed
Item 8 Participation or Interest in Client Transactions
In this Item, we request information about your participation and interest in your clients' transactions. This information identifies additional areas in which conflicts of
interest may occur between you and your clients. Newly-formed advisers should base responses to these questions on the types of participation and interest that
you expect to engage in during the next year.
Like Item 7, Item 8 requires you to provide information about you and your related persons, including foreign affiliates.
Proprietary Interest in Client Transactions
A. Do you or any related person: Yes No
(1) buy securities for yourself from advisory clients, or sell securities you own to advisory clients (principal transactions)?
(2) buy or sell for yourself securities (other than shares of mutual funds) that you also recommend to advisory clients?
(3) recommend securities (or other investment products) to advisory clients in which you or any related person has some other proprietary
(ownership) interest (other than those mentioned in Items 8.A.(1) or (2))?
Sales Interest in Client Transactions
B. Do you or any related person: Yes No
(1) as a broker-dealer or registered representative of a broker-dealer, execute securities trades for brokerage customers in which advisory client
securities are sold to or bought from the brokerage customer (agency cross transactions)?
(2) recommend to advisory clients, or act as a purchaser representative for advisory clients with respect to, the purchase of securities for which you
or any related person serves as underwriter or general or managing partner?
(3) recommend purchase or sale of securities to advisory clients for which you or any related person has any other sales interest (other than the
receipt of sales commissions as a broker or registered representative of a broker-dealer)?
Investment or Brokerage Discretion
C. Do you or any related person have discretionary authority to determine the: Yes No
(1) securities to be bought or sold for a client's account?
(2) amount of securities to be bought or sold for a client's account?
(3) broker or dealer to be used for a purchase or sale of securities for a client's account?
(4) commission rates to be paid to a broker or dealer for a client's securities transactions?
D. If you answer "yes" to C.(3) above, are any of the brokers or dealers related persons?
E. Do you or any related person recommend brokers or dealers to clients?
F. If you answer "yes" to E. above, are any of the brokers or dealers related persons?
G. (1) Do you or any related person receive research or other products or services other than execution from a broker-dealer or a third party ("soft
dollar benefits") in connection with client securities transactions?
(2) If "yes" to G.(1) above, are all the "soft dollar benefits" you or any related persons receive eligible "research or brokerage services" under section
28(e) of the Securities Exchange Act of 1934?
H. (1) Do you or any related person, directly or indirectly, compensate any person that is not an employee for client referrals?
(2) Do you or any related person, directly or indirectly, provide any employee compensation that is specifically related to obtaining clients for the firm
(cash or non-cash compensation in addition to the employee's regular salary)?
I. Do you or any related person, including any employee, directly or indirectly, receive compensation from any person (other than you or any related
person) for client referrals?
In your response to Item 8.I., do not include the regular salary you pay to an employee.
In responding to Items 8.H. and 8.I., consider all cash and non-cash compensation that you or a related person gave to (in answering Item 8.H.) or received from (in
answering Item 8.I.) any person in exchange for client referrals, including any bonus that is based, at least in part, on the number or amount of client referrals.
Item 9 Custody
In this Item, we ask you whether you or a related person has custody of client (other than clients that are investment companies registered under the Investment
Company Act of 1940) assets and about your custodial practices.
A. (1) Do you have custody of any advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
If you are registering or registered with the SEC, answer "No" to Item 9.A.(1)(a) and (b) if you have custody solely because (i) you deduct your advisory fees directly
from your clients' accounts, or (ii) a related person has custody of client assets in connection with advisory services you provide to clients, but you have overcome the
presumption that you are not operationally independent (pursuant to Advisers Act rule 206(4)-2(d)(5)) from the related person.
(2) If you checked "yes" to Item 9.A.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which you have
custody:
U.S. Dollar Amount Total Number of Clients
(a) $ 0 (b) 0
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:
11/2025
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?
1
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 63102-1821
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 Ownership Control PR CRD No. If None: S.S. No.
Last Name, First Name, Middle Status Acquired Code Person and Date of Birth, IRS Tax
Name) MM/YYYY No. or Employer ID No.
BRADBURY, CURTIS FRANKLIN JR I VICE CHAIRMAN OF BOARD 05/2023 NA Y N 810347
DORAMUS, MARK CHRISTOPHER I SENIOR EXECUTIVE VICE 01/2006 NA Y N 1888235
PRESIDENT/CFO/SECRETARY/TREASURER
HINES, ZOE ANN I EXECUTIVE VP, ASSISTANT CFO & 01/2005 NA N N 709945
CONTROLLER, DESIGNATED NYSE CHIEF
OPERATIONS OFFICER
SI HOLDINGS INC. DE SHAREHOLDER COMMON 09/2006 E Y N
CHANEY, DONALD LAWRENCE I SENIOR VICE PRESIDENT AND CHIEF 07/2015 NA N N 4341765
COMPLIANCE OFFICER - BROKER
DEALER/INVESTMENT ADVISOR
MAYO, RACHEL ELIZABETH MONDL I EXECUTIVE VICE PRESIDENT/GENERAL 07/2022 NA N N 7341761
COUNSEL
EICHLER, JOSEPH BRADFORD I SR EXEC VP, CHIEF OPERATING OFFICER, 05/2023 NA Y N 1999320
DIRECTOR
STEPHENS, WARREN MILES I CO-CHIEF EXECUTIVE OFFICER 01/2025 NA Y N 5399161
AMERINE
STEPHENS, JOHN CALHOUN I CO-CHIEF EXECUTIVE OFFICER 01/2025 NA Y N 5384316
BROOKSHIRE, LAURA STEPHENS I SENIOR EXECUTIVE VICE PRESIDENT 01/2025 NA Y N 6513303
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the
sale of, 25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent,
spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she
has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed,
25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the
Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if
the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members,
the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not
have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control
persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: DE/FE/I Entity in Which Interest is Status Date Status Ownership Control PR CRD No. If None: S.S. No. and
Last Name, First Name, Middle Owned Acquired Code Person Date of Birth, IRS Tax No. or
Name) MM/YYYY Employer ID No.
STEPHENS, WARREN AMERINE I WARREN A. STEPHENS TRUSTEE 06/2006 E Y N 1033710
REVOCABLE TRUST #TWO UID
6/14/2006
WARREN A. STEPHENS REVOCABLE DE STEPHENS FINANCIAL MEMBERSHIP 05/2010 E Y N
TRUST #TWO UID 6/14/2006 SERVICES LLC INTEREST
STEPHENS FINANCIAL SERVICES LLC DE SI HOLDINGS INC. SHAREHOLDER 05/2010 E Y N
COMMON
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Reference Item 5.G(1) Stephens offers comprehensive financial planning services to its clients in order to assist clients in identifying and striving to achieve their
financial goals. The financial plans are prepared in a centralized location by a Little Rock based financial planning team. Stephens doesn’t currently charge for
financial planning services. The client and Stephens jointly review many of the of the client’s applicable financial considerations including, but not limited to: time
horizon, liquidity needs, risk tolerance, net worth, cash flows, education goals, retirement goals, wealth transfer goals and insurance (disability, life, long term care)
needs. Stephens provides the client with personalized financial planning and investment recommendations based upon the information provided by the client and
the results of the financial plan. The client is under no obligation to act upon the recommendations of Stephens. If the client does elect to act on any of the
recommendations, the client is under no obligation to effect the transactions through Stephens.
Schedule R
No Information Filed
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
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 Sanctions:
3. Date Initiated (MM/DD/YYYY):
02/03/2016 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2014042543901
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
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, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO IDENTIFY
AND APPLY SALES CHARGE DISCOUNTS TO CERTAIN CUSTOMERS' ELIGIBLE PURCHASES OF UNIT INVESTMENT TRUSTS (UITS) THAT RESULTED IN CUSTOMERS
PAYING EXCESSIVE SALES CHARGES OF APPROXIMATELY $458,747. THE FINDINGS STATED THAT THE FIRM HAS PAID RESTITUTION TO ALL AFFECTED
CUSTOMERS. THE FINDINGS ALSO STATED THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN AND ENFORCE A SUPERVISORY SYSTEM AND WSPS REASONABLY
DESIGNED TO ENSURE CUSTOMERS RECEIVED SALES CHARGE DISCOUNTS ON ALL ELIGIBLE UIT PURCHASES. THE FIRM RELIED PRIMARILY ON ITS
REGISTERED REPRESENTATIVES TO ENSURE THAT CUSTOMERS RECEIVED APPROPRIATE UIT SALES CHARGE DISCOUNTS DESPITE THE FACT THAT THE FIRM DID
NOT EFFECTIVELY INFORM AND TRAIN REPRESENTATIVES AND THEIR SUPERVISORS TO IDENTIFY AND APPLY SUCH SALES CHARGE DISCOUNTS.
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):
02/03/2016 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 235,000.00
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, FINED $235,000, AND ORDERED TO PAY $458,747.07 IN RESTITUTION TO AFFECTED CUSTOMERS.
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).
DUE TO THE GROWTH OF STEPHENS' PRIVATE CLIENT GROUP AND, AS A RESULT, THE INCREASE IN THE FIRM'S UIT BUSINESS, THE FIRM UNDERTOOK A
REVIEW OF ITS UIT TRADING PROCEDURES. BASED UPON THE REVIEW, IN LATE FEBRUARY 2014 IT WAS DETERMINED THAT THE EXECUTION OF UITS SHOULD
BE MOVED FROM THE FIXED INCOME TRADING DESK TO THE PRIVATE CLIENT GROUP TRADING DESK ("DESK"). IN ADDITION TO THE MOVE, NEW PROCEDURES
WERE DEVELOPED WHICH INCLUDE, BUT ARE NOT LIMITED TO, ADDITIONAL FRONT-END ACCOUNT REVIEWS, POST EXECUTION REVIEWS, THIRTY-DAY LOOK
BACK REVIEWS AND A ROLLOVER TEMPLATE WHICH MUST BE COMPLETED BY THE FINANCIAL CONSULTANT AND PROVIDED TO THE DESK FOR REVIEW PRIOR
TO THE EXECUTION OF A ROLLOVER TRANSACTION.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered
or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2. Principal Sanction:
Other Sanctions:
3. Date Initiated (MM/DD/YYYY):
05/11/2016 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2014041823201
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 DID NOT ADEQUATELY
SUPERVISE THE CONTENT AND DISSEMINATION OF FIRM-WIDE "FLASH" EMAILS THROUGH WHICH ITS RESEARCH ANALYSTS ALERTED OTHER FIRM PERSONNEL
TO NEWS AND INSIGHTS CONCERNING COMPANIES AND INDUSTRIES COVERED BY THE FIRM'S RESEARCH DEPARTMENT. THE FINDINGS STATED THAT THE FIRM
ALSO FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE WRITTEN SUPERVISORY PROCEDURES CONCERNING SECURITIES TRADING IN CONNECTION
WITH THESE FLASH EMAILS. THESE FAILURES COLLECTIVELY CREATED THE RISK THAT FLASH EMAILS COULD POTENTIALLY INCLUDE MATERIAL NONPUBLIC
INFORMATION THAT MIGHT BE MISUSED BY SALES AND TRADING PERSONNEL. ALTHOUGH THE FLASH EMAIL PROGRAM WAS INTENDED TO CONVEY ONLY
PUBLICLY-AVAILABLE INFORMATION, THE FIRM DID NOT HAVE ADEQUATE POLICIES AND PROCEDURES TO SUPERVISE THE CONTENT OF THE FLASH EMAILS,
AND IN PRACTICE FLASH EMAILS SOMETIMES CONVEYED MORE THAN THAT. THE FLASH EMAILS WERE NOT SUBJECT TO THE LEVEL OF SYSTEMATIC
SUPERVISORY REVIEW AND APPROVAL APPLIED TO PUBLISHED RESEARCH, EITHER BEFORE OR AFTER THEY WERE CIRCULATED, UNLESS AN ISSUER
MENTIONED IN THE EMAIL WAS ON A FIRM RESTRICTED LIST. MOREOVER, FLASH EMAILS DID NOT CONTAIN THE DISCLOSURES REQUIRED BY SEC
REGULATIONS AND FINRA RULES FOR PUBLISHED RESEARCH. THE FINDINGS ALSO STATED THAT IN AT LEAST ONE INSTANCE, THE CONTENT FROM AN
UNAPPROVED, DRAFT RESEARCH REPORT WAS CUT AND PASTED INTO A FLASH EMAIL. THE FINDINGS ALSO INCLUDED THAT ALTHOUGH FLASH EMAILS WERE
MARKED FOR INTERNAL USE ONLY, THE FIRM'S PERSONNEL SOMETIMES FORWARDED THEM TO FIRM CUSTOMERS OR CUT AND PASTED THE TEXT OF A FLASH
EMAIL INTO A SEPARATE COMMUNICATION SENT TO A FIRM CUSTOMER. THE FINDINGS ALSO INCLUDED THAT WHEN THE FIRM PUBLISHED A RESEARCH
REPORT CONTAINING A RATINGS CHANGE, FIRM POLICY PROHIBITED EMPLOYEES FROM TRADING THE SECURITIES OF THE AFFECTED ISSUER IN THE
DIRECTION OF THE NEW RATING DURING THE TWO BUSINESS DAYS FOLLOWING PUBLICATION OF THE REPORT. HOWEVER, THE FIRM DID NOT
SYSTEMATICALLY MONITOR FOR TRADING THAT OCCURRED SHORTLY BEFORE THE PUBLICATION OF RESEARCH REPORTS CONTAINING RATING, ESTIMATE, OR
PRICE TARGET CHANGES OR DURING THE PERIOD BETWEEN THE TIME A FLASH EMAIL WAS DISTRIBUTED AND THE PUBLICATION OF A SUBSEQUENT RESEARCH
REPORT CONTAINING SUCH CHANGES. FINRA FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE ADEQUATE SYSTEMS AND PROCEDURES
TO SUPERVISE FLASH EMAILS AND RELATED TRADING. FINRA ALSO FOUND THAT THE FIRM FAILED TO ESTABLISH, MAINTAIN, AND ENFORCE POLICIES AND
PROCEDURES REASONABLY DESIGNED TO RESTRICT OR LIMIT THE INFORMATION FLOW BETWEEN RESEARCH DEPARTMENT PERSONNEL AND TRADING
DEPARTMENT PERSONNEL SO AS TO PREVENT TRADING DEPARTMENT PERSONNEL FROM USING MATERIAL, NON-PUBLIC ANALYST RESEARCH FOR THE BENEFIT
OF THE FIRM, ITS EMPLOYEES, AND ITS CUSTOMERS.
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):
05/11/2016 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 900,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
UNDERTAKINGS
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary
compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived:
THE FIRM IS CENSURED, FINED $900,000 AND UNDERTAKES WITHIN 60 DAYS OF THE DATE OF THE NOTICE OF ACCEPTANCE OF THIS AWC, THE FIRM
SHALL CERTIFY TO FINRA IN A SUBMISSION SIGNED BY AN OFFICER OF THE FIRM THAT IT HAS CEASED DISTRIBUTING FLASH EMAILS. FURTHERMORE,
THE FIRM UNDERTAKES WITHIN 90 DAYS OF THE DATE OF NOTICE OF ACCEPTANCE OF THIS AWC, SUBMIT TO FINRA A WRITTEN PLAN OF HOW IT WILL
CONDUCT A COMPREHENSIVE REVIEW OF THE ADEQUACY AND IMPLEMENTATION OF ITS POLICIES AND PROCEDURES (WRITTEN AND OTHERWISE) AND
TRAINING IN THE RESEARCH AREA.
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).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered
or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
UNITED STATES SECURITIES AND EXCHANGE COMMISSION
2. Principal Sanction:
Other
Other Sanctions:
N/A
3. Date Initiated (MM/DD/YYYY):
03/11/2019 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
FILE NO. 3-19099
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
Mutual Fund(s)
Other Product Types:
7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE ORDER ALLEGES STEPHENS INC. BREACHED ITS FIDUCIARY DUTY TO CLIENTS AND VIOLATED SECTIONS 206(2) AND 207 OF THE ADVISERS ACT IN THAT
STEPHENS INC. PURCHASED, RECOMMENDED OR HELD FOR CLIENT ACCOUNTS MUTUAL FUND SHARE CLASSES THAT PAID STEPHENS INC. 12B-1 FEES BUT
FAILED TO ADEQUATELY DISCLOSE CONFLICTS OF INTEREST WITH THESE SHARE CLASSES IN THAT CHEAPER SHARE CLASSES OF THE SAME FUNDS WERE
AVAILABLE TO CLIENTS WHICH DID NOT PAY 12B-1 FEES.
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:
STEPHENS INC. WAS ORDERED TO CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS
206(2) AND 207 OF THE INVESTMENT ADVISERS ACT OF 1940. FURTHER, STEPHENS INC. WAS CENSURED AND ORDERED TO PAY DISGORGEMENT OF
$5,000,738.11 AND PREJUDGMENT INTEREST OF $488,381.23 AND ORDERED TO 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).
STEPHENS INC. VOLUNTARILY PARTICIPATED IN THE SEC'S SHARE CLASS SELECTION DISCLOSURE INITIATIVE WHICH RELATED TO MUTUAL FUND SHARES
SOLD TO STEPHENS INC. ADVISORY CLIENTS. THE ORDER ALLEGED THAT STEPHENS INC. DID NOT ADEQUATELY DISCLOSE CONFLICTS OF INTEREST RELATED
TO THE SELECTION OF MUTUAL FUND SHARE CLASSES FOR ADVISORY CLIENTS WHICH PAID STEPHENS INC. 12B-1 FEES WHEN LESS EXPENSIVE SHARE
CLASSES OF THE SAME FUND WERE AVAILABLE WHICH DID NOT PAY STEPHENS INC. THESE 12B-1 FEES. STEPHENS AGREED TO RESTITUTION TO AFFECTED
CLIENTS OF THESE FEES IN THE AMOUNT OF $5,000,738.11 PLUS PREJUDGMENT INTEREST OF $488,381.23. (IA RELEASE NUMBER 40-5196, MARCH 11, 2019).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same
event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered
or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA
2. Principal Sanction:
Other
Other Sanctions:
N/A
3. Date Initiated (MM/DD/YYYY):
08/12/2025 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
2022075470401
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 ESTABLISH,
MAINTAIN, AND ENFORCE A SUPERVISORY SYSTEM, INCLUDING WSPS, REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH THE PROVISIONS OF MSRB
RULE G-37(B) GOVERNING POLITICAL CONTRIBUTIONS BY FIRMS AND MUNICIPAL FINANCE PROFESSIONALS (MFPS). THE FINDINGS STATED THAT THE FIRM'S
WSPS CONCERNING POLITICAL CONTRIBUTIONS BY THE FIRM'S MFPS INCLUDED PROCEDURES DESIGNED TO DETERMINE WHETHER THE INTENDED RECIPIENT
OF A POLITICAL CONTRIBUTION WAS AN ISSUER OFFICIAL. HOWEVER, THE FIRM EMPLOYED A DIFFERENT PROCESS WHICH WAS NOT MEMORIALIZED IN THE
FIRM'S WSPS OR ELSEWHERE FOR THE MAJORITY OF MFP POLITICAL CONTRIBUTIONS TO CANDIDATES FOR STATE-LEVEL OFFICES, WHICH WERE MADE BY
ONE OF THE FIRM'S MFPS. FOR THESE POLITICAL CONTRIBUTIONS, THE FIRM OUTSOURCED ITS RESPONSIBILITY TO DETERMINE WHETHER THE CANDIDATES
WERE ISSUER OFFICIALS TO A THIRD PARTY. THE FIRM DIRECTED THE THIRD PARTY TO OBTAIN A SIGNED CERTIFICATION FROM EACH CANDIDATE ATTESTING
THAT THE CANDIDATE WAS NOT AN ISSUER OFFICIAL WITHIN THE MEANING OF MSRB RULE G-37 BEFORE THE MFP'S CONTRIBUTION WAS MADE. HOWEVER,
THE FIRM HAD NO SYSTEM OR PROCEDURES TO REVIEW WHETHER THE THIRD PARTY OBTAINED A SIGNED CERTIFICATION FROM THE CANDIDATE AS
REQUIRED BEFORE DELIVERING A POLITICAL CONTRIBUTION, AND THE FIRM DID NOT CONDUCT SUCH REVIEWS. THE FIRM THEREFORE FAILED TO TIMELY
DETECT THAT, IN SOME INSTANCES, THE THIRD PARTY DELIVERED CONTRIBUTIONS FROM THE MFP WITHOUT FIRST RECEIVING SIGNED CERTIFICATIONS,
INCLUDING ONE INSTANCE IN WHICH A POLITICAL CONTRIBUTION WAS MADE TO AN ISSUER OFFICIAL AND EXCEEDED MSRB RULE G-37'S DE MINIMIS
EXCEPTION. THE FIRM'S UNREASONABLE SUPERVISION CREATED THE RISK THAT THE FIRM WOULD ENGAGE IN MUNICIPAL SECURITIES BUSINESS IN
VIOLATION OF MSRB RULE G-37. ULTIMATELY, THE FIRM TERMINATED ITS RELATIONSHIP WITH THE THIRD PARTY INVOLVED IN DETERMINING WHETHER
CANDIDATES WERE ISSUER OFFICIALS AND BEGAN REQUIRING THE LEGAL DEPARTMENT TO REVIEW AND PRE-APPROVE ALL MFP POLITICAL CONTRIBUTIONS.
SUBSEQUENTLY, THE FIRM UPDATED ITS WSPS TO REFLECT THESE NEW PROCEDURES.
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):
08/12/2025 Exact Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 90,000.00
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 $90,000.
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).
THIS ACTION CONCLUDED ON AUGUST 12, 2025, WHEN STEPHENS INC. SUBMITTED AND FINRA ACCEPTED A LETTER OF ACCEPTANCE, WAIVER AND CONSENT,
WHEREBY STEPHENS SETTLED THE MATTER BY CONSENTING TO A CENSURE AND A $90,000 FINE.
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)
4718 ADV PART 2 A Selection of Other Advisers/Solicitors, Individuals, High
net worth individuals, Pension plans/profit sharing
plans, Pension consulting, Foundations/charities,
Government/municipal, Other institutional, Wrap
program
4728 STEPHENS FIXED INCOME Individuals, High net worth individuals, Pension
MANAGEMENT plans/profit sharing plans, Foundations/charities, Other
institutional, Wrap program
321980 STEPHENS CAPITAL MANAGEMENT Other institutional, Wrap program, Financial Planning
ADVISORY PROGRAMS Services, Individuals, High net worth individuals,
Pension plans/profit sharing plans, Pension consulting,
Foundations/charities, Government/municipal
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
DONALD CHANEY 06/25/2026
Printed Name: Title:
DONALD CHANEY SVP - CHIEF COMPLIANCE OFFICER
Adviser CRD Number:
3496
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:
3496