Form ADV (full filing)

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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS

Primary Business Name: JANNEY MONTGOMERY SCOTT LLC CRD Number: 463
Other-Than-Annual Amendment - All Sections Rev. 10/2021
6/30/2026 5:32:52 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):
JANNEY MONTGOMERY SCOTT LLC

B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
JANNEY MONTGOMERY SCOTT LLC

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: 801-7258
(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
200401
1329948

E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 463

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:
1717 ARCH STREET
City: State: Country: ZIP+4/Postal Code:
PHILADELPHIA Pennsylvania United States 19103

If this address is a private residence, check this box:

List on Section 1.F. of Schedule D any office, other than your principal office and place of business, at which you conduct investment advisory business. If
you are applying for registration, or are registered, with one or more state securities authorities, you must list all of your offices in the state or states to
which you are applying for registration or with whom you are registered. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are reporting to the SEC as an exempt reporting adviser, list the largest twenty-five offices in terms of numbers of employees as of the end of your
most recently completed fiscal year.

(2) Days of week that you normally conduct business at your principal office and place of business:
Monday - Friday Other:

Normal business hours at this location:
9:00AM TO 5:00PM
(3) Telephone number at this location:
215-665-6000
(4) Facsimile number at this location, if any:
215-665-0824
(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?
138

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:
549300QQRY1JCFQHYS08

A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity
identifier.

SECTION 1.B. Other Business Names

No Information Filed

SECTION 1.F. Other Offices

Complete the following information for each office, other than your principal office and place of business, at which you conduct investment advisory business.
You must complete a separate Schedule D Section 1.F. for each location. If you are applying for SEC registration, if you are registered only with the SEC, or
if you are an exempt reporting adviser, list only the largest twenty-five offices (in terms of numbers of employees).

Number and Street 1: Number and Street 2:
1767 SENTRY PKWY WEST SUITE 110
City: State: Country: ZIP+4/Postal Code:
BLUE BELL Pennsylvania United States 19422

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(215)619-3900 (215)619-3909

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:
150834

How many employees perform investment advisory functions from this office location?
21

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:
SALES RETAIL

Number and Street 1: Number and Street 2:
1 PPG PLACE SUITE 2200
City: State: Country: ZIP+4/Postal Code:
PITTSBURGH Pennsylvania United States 15219
If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
412-562-8000 412-562-7997

How many employees perform investment advisory functions from this office location?
37

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL SALES INSTITUTIONAL PUBLIC FINANCE

Number and Street 1: Number and Street 2:
60 STATE STREET SUITE 1350
City: State: Country: ZIP+4/Postal Code:
BOSTON Massachusetts United States 02109

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
617-720-0600 617-720-5358

How many employees perform investment advisory functions from this office location?
22

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
40 MORRIS AVENUE SUITE 200, 220, & 140
City: State: Country: ZIP+4/Postal Code:
BRYN MAWR Pennsylvania United States 19010

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
610-526-7200 610-526-9894

How many employees perform investment advisory functions from this office location?
26

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
8950 SW 74TH CT SUITE 2005
City: State: Country: ZIP+4/Postal Code:
MIAMI Florida United States 33156

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
786-646-6030 786-646-9571

How many employees perform investment advisory functions from this office location?
18

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
1010 STONY HILL ROAD SUITE 300
City: State: Country: ZIP+4/Postal Code:
YARDLEY Pennsylvania United States 19067

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(267) 685-8140 (267) 685-1022

How many employees perform investment advisory functions from this office location?
27

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
95 GLASTONBURY BLVD. 4TH FLOOR, SUITE 202
City: State: Country: ZIP+4/Postal Code:
GLASTONBURY Connecticut United States 06033

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
860-657-1780 860-633-2584

How many employees perform investment advisory functions from this office location?
24

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
2 MORROCROFT CENTRE SUITE 450 4064 COLONY RD
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)367-9700 (704)367-9778

How many employees perform investment advisory functions from this office location?
34

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
15 N. MAIN STREET SUITE 300 & 102
City: State: Country: ZIP+4/Postal Code:
WEST HARTFORD Connecticut United States 06107

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(860)561-3760 (860)561-3712

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:
SALES RETAIL

Number and Street 1: Number and Street 2:
3560 LENOX ROAD NE SUITE 1100
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:
404-233-5744 404-233-5580

How many employees perform investment advisory functions from this office location?
23

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
210 WEST PENNSYLVANIA AVENUE SUITE 610
City: State: Country: ZIP+4/Postal Code:
TOWSON Maryland United States 21204

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(410)494-9500 (410)296-7104
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:
150855

How many employees perform investment advisory functions from this office location?
26

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
4140 PARKLAKE AVENUE GLENLAKE ONE, SUITE 300
City: State: Country: ZIP+4/Postal Code:
RALEIGH North Carolina United States 27612

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
919-789-3091 919-788-2051

How many employees perform investment advisory functions from this office location?
23

Describe any other investment-related business activities conducted from this office location:

Number and Street 1: Number and Street 2:
1700 WESTGATE DRIVE SUITE 103
City: State: Country: ZIP+4/Postal Code:
YORK Pennsylvania United States 17404
If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
717-779-2720 717-779-2750

How many employees perform investment advisory functions from this office location?
21

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
1166 AVENUE OF THE AMERICAS 21ST FLOOR
City: State: Country: ZIP+4/Postal Code:
NEW YORK New York United States 10036

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
212-906-1950 212-223-1023

How many employees perform investment advisory functions from this office location?
30

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
856-291-5000 856-235-0594

How many employees perform investment advisory functions from this office location?
28

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
1420 RTE 206 N. 2ND FLOOR
City: State: Country: ZIP+4/Postal Code:
BEDMINSTER New Jersey United States 07921

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(908) 781-2500 (908) 781-9690

How many employees perform investment advisory functions from this office location?
19

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL
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:
3001 PGA BLVD SUITE 200
City: State: Country: ZIP+4/Postal Code:
PALM BEACH GARDENS Florida United States 33410

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
561-630-9101 561-630-0416

How many employees perform investment advisory functions from this office location?
28

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
309 SE OSECEOLA STREET SUITE 207-2088
City: State: Country: ZIP+4/Postal Code:
STUART Florida United States 34994

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
772-219-2000 772-219-2025

How many employees perform investment advisory functions from this office location?
19

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
1650 CROOKED OAK DRIVE SUITE 100
City: State: Country: ZIP+4/Postal Code:
LANCASTER Pennsylvania United States 17601

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
717-560-4100 717-581-1272

How many employees perform investment advisory functions from this office location?
20

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
20 MONTCHANIN RD SUITES 120, 137, & 145
City: State: Country: ZIP+4/Postal Code:
GREENVILLE Delaware United States 19807

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
302-428-1818 302-428-1822

How many employees perform investment advisory functions from this office location?
27

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
22 CORPORATE WOODS BLVD SUITE 402
City: State: Country: ZIP+4/Postal Code:
ALBANY New York United States 12211

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
518-426-8227 518-426-3038

How many employees perform investment advisory functions from this office location?
22

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
6000 SAGEMORE DRIVE SUITE 6201
City: State: Country: ZIP+4/Postal Code:
MARLTON New Jersey United States 08053

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
(856) 985-4900 (856) 596-0465

How many employees perform investment advisory functions from this office location?
22

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
1233 20TH STREET NW SUITE 710
City: State: Country: ZIP+4/Postal Code:
WASHINGTON District of Columbia United States 20037

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
202-955-4300 202-872-1906

How many employees perform investment advisory functions from this office location?
26

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

Number and Street 1: Number and Street 2:
2200 GEORGETOWN DRIVE SUITE 400
City: State: Country: ZIP+4/Postal Code:
SEWICKLEY Pennsylvania United States 15143

If this address is a private residence, check this box:
Telephone Number: Facsimile Number, if any:
(724) 934-1888 (724) 934-3798

How many employees perform investment advisory functions from this office location?
27

Describe any other investment-related business activities conducted from this office location:
RETAIL SALES

Number and Street 1: Number and Street 2:
1001 FRANKLIN AVE SUITE 202
City: State: Country: ZIP+4/Postal Code:
GARDEN CITY New York United States 11530

If this address is a private residence, check this box:

Telephone Number: Facsimile Number, if any:
516-294-0917 516-294-8969

How many employees perform investment advisory functions from this office location?
27

Describe any other investment-related business activities conducted from this office location:
SALES RETAIL

SECTION 1.I. Website Addresses

List your website addresses, including addresses for accounts on publicly available social media platforms where you control the content (including, but not
limited to, Twitter, Facebook and/or LinkedIn). You must complete a separate Schedule D Section 1.I. for each website or account on a publicly available
social media platform.
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/JANNEYMONTGOMERYSCOTT

Address of Website/Account on Publicly Available Social Media Platform: HTTPS://TWITTER.COM/JANNEY1832

Address of Website/Account on Publicly Available Social Media Platform: HTTP://WWW.JANNEY.COM

Address of Website/Account on Publicly Available Social Media Platform: https://vimeo.com/user22855811

Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.LINKEDIN.COM/COMPANY/JANNEY-MONTGOMERY-SCOTT/

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:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
100 HARBOR DRIVE
City: State: Country: ZIP+4/Postal Code:
JERSEY CITY New Jersey United States 07305

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
1201 FREEDOM ROAD
City: State: Country: ZIP+4/Postal Code:
CRANBERRY TWP Pennsylvania United States 16066

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
2500 HENDERSON DRIVE
City: State: Country: ZIP+4/Postal Code:
SHARON HILL Pennsylvania United States 19079

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
13700 NW 2ND STREET
City: State: Country: ZIP+4/Postal Code:
SUNRISE Florida United States 33325

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
8200 PRESTON COURT
City: State: Country: ZIP+4/Postal Code:
JESSUP Maryland United States 20794

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
6100-A HARRIS TECHNOLOGY BLVD
City: State: Country: ZIP+4/Postal Code:
CHARLOTTE North Carolina United States 28269

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
175 BEARFOOT RD
City: State: Country: ZIP+4/Postal Code:
NORTHBOROUGH Massachusetts United States 01532

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
448 BROADWAY
City: State: Country: ZIP+4/Postal Code:
ULSTER PARK New York United States 12487

If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
5560 SHAWLAND ROAD
City: State: Country: ZIP+4/Postal Code:
JACKSONVILLE Florida United States 32254

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
1100 KENNEDY RD
City: State: Country: ZIP+4/Postal Code:
WINDSOR Connecticut United States 06095

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
6667 DEERE ROAD
City: State: Country: ZIP+4/Postal Code:
SYRACUSE New York United States 13206

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
2120 BUZICK DRIVE
City: State: Country: ZIP+4/Postal Code:
OBETZ Ohio United States 43207

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN

Number and Street 1: Number and Street 2:
6 LEE BLVD
City: State: Country: ZIP+4/Postal Code:
MALVERN Pennsylvania United States 19355

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

Name of entity where books and records are kept:
IRON MOUNTAIN
Number and Street 1: Number and Street 2:
19200 TREAT RD
City: State: Country: ZIP+4/Postal Code:
WALTON HILLS Ohio United States 44146

If this address is a private residence, check this box:

Telephone Number: Facsimile number, if any:
800-899-4766

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.
CERTAIN BOOKS AND RECORDS REQUIRED TO BE MAINTAINED BY LAW.

SECTION 1.M. Registration with Foreign Financial Regulatory Authorities

No Information Filed

Item 2 SEC Registration/Reporting

Responses to this Item help us (and you) determine whether you are eligible to register with the SEC. Complete this Item 2.A. only if you are applying for
SEC registration or submitting an annual updating amendment to your SEC registration. If you are filing an umbrella registration, the information in Item 2
should be provided for the filing adviser only.

A. To register (or remain registered) with the SEC, you must check at least one of the Items 2.A.(1) through 2.A.(12), below. If you are submitting an
annual updating amendment to your SEC registration and you are no longer eligible to register with the SEC, check Item 2.A.(13). Part 1A Instruction 2
provides information to help you determine whether you may affirmatively respond to each of these items.
You (the adviser):

(1) are a large advisory firm that either:

(a) has regulatory assets under management of $100 million (in U.S. dollars) or more; or

(b) has regulatory assets under management of $90 million (in U.S. dollars) or more at the time of filing its most recent annual updating
amendment and is registered with the SEC;

(2) are a mid-sized advisory firm that has regulatory assets under management of $25 million (in U.S. dollars) or more but less than $100
million (in U.S. dollars) and you are either:

(a) not required to be registered as an adviser with the state securities authority of the state where you maintain your principal office and place
of business; or

(b) not subject to examination by the state securities authority of the state where you maintain your principal office and place of business;

Click HERE for a list of states in which an investment adviser, if registered, would not be subject to examination by the state securities
authority.

(3) Reserved

(4) have your principal office and place of business outside the United States;

(5) are an investment adviser (or subadviser) to an investment company registered under the Investment Company Act of 1940;

(6) are an investment adviser to a company which has elected to be a business development company pursuant to section 54 of the
Investment Company Act of 1940 and has not withdrawn the election, and you have at least $25 million of regulatory assets under
management;

(7) are a pension consultant with respect to assets of plans having an aggregate value of at least $200,000,000 that qualifies for the exemption
in rule 203A-2(a);

(8) are a related adviser under rule 203A-2(b) that controls, is controlled by, or is under common control with, an investment adviser that is
registered with the SEC, and your principal office and place of business is the same as the registered adviser;

If you check this box, complete Section 2.A.(8) of Schedule D.

(9) are an adviser relying on rule 203A-2(c) because you expect to be eligible for SEC registration within 120 days;

If you check this box, complete Section 2.A.(9) of Schedule D.

(10) are a multi-state adviser that is required to register in 15 or more states and is relying on rule 203A-2(d);
If you check this box, complete Section 2.A.(10) of Schedule D.

(11) are an Internet adviser relying on rule 203A-2(e);

If you check this box, complete Section 2.A.(11) of Schedule D.

(12) have received an SEC order exempting you from the prohibition against registration with the SEC;

If you check this box, complete Section 2.A.(12) of Schedule D.

(13) are no longer eligible to remain registered with the SEC.

State Securities Authority Notice Filings and State Reporting by Exempt Reporting Advisers
C. Under state laws, SEC-registered advisers may be required to provide to state securities authorities a copy of the Form ADV and any amendments they
file with the SEC. These are called notice filings. In addition, exempt reporting advisers may be required to provide state securities authorities with a copy
of reports and any amendments they file with the SEC. If this is an initial application or report, check the box(es) next to the state(s) that you would
like to receive notice of this and all subsequent filings or reports you submit to the SEC. If this is an amendment to direct your notice filings or reports to
additional state(s), check the box(es) next to the state(s) that you would like to receive notice of this and all subsequent filings or reports you submit
to the SEC. If this is an amendment to your registration to stop your notice filings or reports from going to state(s) that currently receive them, uncheck
the box(es) next to those state(s).

Jurisdictions

AL IL NE SC
AK IN NV SD
AZ IA NH TN
AR KS NJ TX
CA KY NM UT
CO LA NY VT
CT ME NC VI
DE MD ND VA
DC MA OH WA
FL MI OK WV
GA MN OR WI
GU MS PA WY
HI MO PR
ID MT RI

If you are amending your registration to stop your notice filings or reports from going to a state that currently receives them and you do not want to pay that
state's notice filing or report filing fee for the coming year, your amendment must be filed before the end of the year (December 31).

SECTION 2.A.(8) Related Adviser
If you are relying on the exemption in rule 203A-2(b) from the prohibition on registration because you control, are controlled by, or are under common control
with an investment adviser that is registered with the SEC and your principal office and place of business is the same as that of the registered adviser,
provide the following information:

Name of Registered Investment Adviser

CRD Number of Registered Investment Adviser

SEC Number of Registered Investment Adviser
-

SECTION 2.A.(9) Investment Adviser Expecting to be Eligible for Commission Registration within 120 Days
If you are relying on rule 203A-2(c), the exemption from the prohibition on registration available to an adviser that expects to be eligible for SEC registration
within 120 days, you are required to make certain representations about your eligibility for SEC registration. By checking the appropriate boxes, you will b e
deemed to have made the required representations. You must make both of these representations:
I am not registered or required to be registered with the SEC or a state securities authority and I have a reasonable expectation that I will be eligible to
register with the SEC within 120 days after the date my registration with the SEC becomes effective.
I undertake to withdraw from SEC registration if, on the 120th day after my registration with the SEC becomes effective, I would be prohibited by Section
203A(a) of the Advisers Act from registering with the SEC.

SECTION 2.A.(10) Multi-State Adviser
If you are relying on rule 203A-2(d), the multi-state adviser exemption from the prohibition on registration, you are required to make certain representations
about your eligibility for SEC registration. By checking the appropriate boxes, you will be deemed to have made the required representations.

If you are applying for registration as an investment adviser with the SEC, you must make both of these representations:
I have reviewed the applicable state and federal laws and have concluded that I am required by the laws of 15 or more states to register as an
investment adviser with the state securities authorities in those states.
I undertake to withdraw from SEC registration if I file an amendment to this registration indicating that I would be required by the laws of fewer than 15
states to register as an investment adviser with the state securities authorities of those states.

If you are submitting your annual updating amendment, you must make this representation:
Within 90 days prior to the date of filing this amendment, I have reviewed the applicable state and federal laws and have concluded that I am required
by the laws of at least 15 states to register as an investment adviser with the state securities authorities in those states.

SECTION 2.A.(11) Internet Adviser
If you are relying on rule 203A-2(e), the Internet adviser exemption from the prohibition on registration, you are required to make a representation about
your eligibility for SEC registration. By checking the appropriate box, you will be deemed to have made the required representation.

If you are applying for registration as an investment adviser with the SEC or changing your existing Item 2 response regarding your eligibility for SEC
registration, you must make this representation:
I will provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive website.
If you are filing an annual updating amendment to your existing registration and are continuing to rely on the Internet adviser exemption for SEC
registration, you must make this representation:
I have provided and will continue to provide investment advice on an ongoing basis to more than one client exclusively through an operational interactive
website.

SECTION 2.A.(12) SEC Exemptive Order
If you are relying upon an SEC order exempting you from the prohibition on registration, provide the following information:

Application Number:
803-

Date of order:

Item 3 Form of Organization
If you are filing an umbrella registration, the information in Item 3 should be provided for the filing adviser only.
A. How are you organized?
Corporation

Sole Proprietorship

Limited Liability Partnership (LLP)

Partnership

Limited Liability Company (LLC)

Limited Partnership (LP)

Other (specify):

If you are changing your response to this Item, see Part 1A Instruction 4.

B. In what month does your fiscal year end each year?
DECEMBER

C. Under the laws of what state or country are you organized?
State Country
Delaware 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.
2404

B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
1614
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
1525
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives?
1284
(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?
1062
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
18

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?
1031
(2) Approximately what percentage of your clients are non-United States persons?
0%

D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does
not include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of
1940. Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment
Company Act of 1940, do not answer (1)(d) or (3)(d) below.

Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below)
attributable to each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check
Item 5.D.(2) rather than respond to Item 5.D.(1).

The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under
management reported in Item 5.F.(2)(c) below.

If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If
you advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e),
and (f) as applicable.

(1) Number of (2) Fewer than (3) Amount of Regulatory Assets
Type of Client Client(s) 5 Clients under Management
(a) Individuals (other than high net worth individuals) 139021 $ 21,060,208,234
(b) High net worth individuals 100743 $ 76,460,262,772
(c) Banking or thrift institutions 0 $0
(d) Investment companies 0 $0
(e) Business development companies 0 $0
(f) Pooled investment vehicles (other than investment companies and 0 $0
business development companies)
(g) Pension and profit sharing plans (but not the plan participants or 664 $ 7,043,418,173
government pension plans)
(h) Charitable organizations 1810 $ 2,134,400,387
(i) State or municipal government entities (including government pension 145 $ 717,291,350
plans)
(j) Other investment advisers 0 $0
(k) Insurance companies 0 $0
(l) Sovereign wealth funds and foreign official institutions 0 $0
(m) Corporations or other businesses not listed above 1425 $ 2,698,109,160
(n) Other: N/A 0 $0

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): FEE PLUS COMMISSION

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) $ 76,213,694,173 (d) 187,981
Non-Discretionary: (b) $ 33,899,995,903 (e) 55,827
Total: (c) $ 110,113,690,076 (f) 243,808

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?
$ 409,412,046

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?
16,000 (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
$ 5,298,309,432
(b) portfolio manager for a wrap fee program?
$0
(c) sponsor to and portfolio manager for the same wrap fee program?
$ 99,121,799,862

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))?

(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
ADVISER'S

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
CLASSIC

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463
Name of Wrap Fee Program
COMPASS

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
ETF ADVANTAGE

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
GOALS-BASED PORTFOLIO SOLUTIONS (GPS) PROGRAM

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
INVESTORS SELECT

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
JANNEY CAPITAL MANAGEMENT DIRECT

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
JANNEY UMA

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
KEYSTONE

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
PARTNERS ADVISORY

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

Name of Wrap Fee Program
PIONEER

Name of Sponsor
JANNEY MONTGOMERY SCOTT LLC

Sponsor's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-):
801 - 7258

Sponsor's CRD Number (if any):
463

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 62 % 63 %
(ii) Non Exchange-Traded Equity Securities 2% 2%
(iii) U.S. Government/Agency Bonds 2% 2%
(iv) U.S. State and Local Bonds 4% 4%
(v) Sovereign Bonds 0% 0%
(vi) Investment Grade Corporate Bonds 2% 2%
(vii) Non-Investment Grade Corporate Bonds 0% 0%
(viii) Derivatives 0% 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 23 % 22 %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business 0% 0%
Development Companies)
(xi) Cash and Cash Equivalents 4% 4%
(xii) Other 1% 0%
Generally describe any assets included in "Other"
ONLY ANNUITIES ARE LISTED IN THE OTHER CATEGORY.

(b) Asset Type End of year
(i) Exchange-Traded Equity Securities %
(ii) Non Exchange-Traded Equity Securities %
(iii) U.S. Government/Agency Bonds %
(iv) U.S. State and Local Bonds %
(v) Sovereign Bonds %
(vi) Investment Grade Corporate Bonds %
(vii) Non-Investment Grade Corporate Bonds %
(viii) Derivatives %
(ix) Securities Issued by Registered Investment Companies or Business Development Companies %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development %
Companies)
(xi) Cash and Cash Equivalents %
(xii) Other %
Generally describe any assets included in "Other"

SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives

No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)

If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your
regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete
Question (b).
(a) In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately
managed account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date
used to calculate your regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before
the end of year date.

In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross
notional exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the
dollar amount of any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.

In column 2, provide the dollar amount of borrowings for the accounts included in column 1.

In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts
included in column 1 with respect to each category of derivatives specified in 3(a) through (f).

You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of
less than $10,000,000.

Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.

(i) Mid-Year

Gross Notional (1) Regulatory Assets (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(a) Interest (b) Foreign
Rate Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ 5,352,300,760 $ 58,567 0% 0% 0% 0.11 % 0% 0%

10-149% $ 217,000,567 $ 42,496,293 0% 0% 0% 40.16 % 0% 0.03 %

150% or more $ 77,109,548 $0 0% 0% 0% 198.38 % 0% 0%

Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.

(ii) End of Year

10-149% $ 298,560,285 $ 37,231,905 0% 0% 0% 32.46 % 0% 4.57 %

150% or more $ 98,968,375 $ 10,430,494 0% 0% 0% 190.52 % 0% 0%

(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 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

No Information Filed

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.
JANNEY IS A FULL SERVICE, DUALLY REGISTERED BROKER-DEALER AND INVESTMENT ADVISER.

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:
KOHLBERG KRAVIS ROBERTS & CO. L.P.

2. Primary Business Name of Related Person:
KOHLBERG KRAVIS ROBERTS & CO. L.P.

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 69634
or
Other

4. Related Person's
(a) CRD Number (if any):
144533
(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:
GLOBAL ATLANTIC DISTRIBUTORS, LLC

2. Primary Business Name of Related Person:
GLOBAL ATLANTIC DISTRIBUTORS, LLC

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
8 - 25027
or
Other

4. Related Person's
(a) CRD Number (if any):
8326
(b) CIK Number(s) (if any):
No Information Filed

(b) If the answer is yes, under what exemption?

12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
JANNEY TRUST CO LLC

2. Primary Business Name of Related Person:
JANNEY TRUST CO LLC

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

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

12. Do you and the related person share the same physical location?

1. Legal Name of Related Person:
GLOBAL ATLANTIC INVESTMENT ADVISORS, LLC

2. Primary Business Name of Related Person:
GLOBAL ATLANTIC INVESTMENT ADVISORS, LLC

3. Related Person's SEC File Number (if any) (e.g., 801-, 8-, 866-, 802-)
801 - 78132
or
Other

4. Related Person's
(a) CRD Number (if any):
167429
(b) CIK Number(s) (if any):
No Information Filed

7. Are you and the related person under common control?

(b) If the answer is yes, under what exemption?

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) $ 104,087,007,793 (b) 243,528

If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not
include the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in
connection with advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2).
Instead, include that information in your response to Item 9.B.(2).

B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a) cash or bank accounts?

(b) securities?

You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).

(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which
your related persons have custody:

U.S. Dollar Amount Total Number of Clients
(a) $ (b)

C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following
that apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements
are distributed to the investors in the pools.
(3) An independent public accountant conducts an annual surprise examination of client funds and securities.
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons
are qualified custodians for client funds and securities.

If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare
an internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this
information with respect to the private funds you advise in Section 7.B.(1) of Schedule D).

D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian

(2) your related person(s) act as qualified custodian(s)

If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule
206(4)-2(b)(1)) must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent
under rule 206(4)-2 of the Advisers Act.

E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last
fiscal year, provide the date (MM/YYYY) the examination commenced:
08/2025

F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act
as qualified custodians for your clients in connection with advisory services you provide to clients?
36

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:
GRANT THORNTON LLP

(2) The location of the independent public accountant's office responsible for the services provided:

Number and Street 1: Number and Street 2:
171 N. CLARK STREET SUITE 200
City: State: Country: ZIP+4/Postal Code:
CHICAGO Illinois United States 60601

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:
248

(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

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

B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting
company):
(1) Full legal name of the public reporting company: KKR & CO., INC.
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each reporting company): 1404912

B. If any person named in Schedules A, B, or C, or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please provide the following information (you must complete a separate Schedule D Section 10.B. for each public reporting
company):
(1) Full legal name of the public reporting company: KKR PRIVATE EQUITY
CONGLOMERATE LLC
(2) The public reporting company's CIK number (Central Index Key number that the SEC assigns to each 1957845
reporting company):

Item 11 Disclosure Information

In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to
determine whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an
investment adviser, and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than
one of the questions below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an
umbrella registration.

Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all
of your officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you.
If you are a "separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.

If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years
following the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your
disclosure to ten years following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of
calculating this ten-year period, the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary
orders, judgments, or decrees lapsed.

You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.

Yes No
Do any of the events below involve you or any of your supervised persons?

For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?

(2) been charged with any felony?

If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to
charges that are currently pending.

B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving:
investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury,
forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?

If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to
charges that are currently pending.

For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?

(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?

(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?

(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?

D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?

(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?

(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business
denied, suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?

(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory
affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?

E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?

(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule
violation" under a plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you
or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?

F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or
suspended?

G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C.,
11.D., or 11.E.?

For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?

(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?

(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by
a state or foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?

Item 12 Small Businesses

The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine
whether you meet the definition of "small business" or "small organization" under rule 0-7.

Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets
under management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a
current state registration, or switching from SEC to state registration.

For purposes of this Item 12 only:

Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total
assets, you may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with
subsidiaries included, if that amount is larger).
Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by
contract, or otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent
or more of the profits, of another person is presumed to control the other person.

Yes No
A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?

If "yes," you do not need to answer Items 12.B. and 12.C.

B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV)
of $25 million or more on the last day of its most recent fiscal year?
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal
year?

C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in
response to Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year?
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the
last day of its most recent fiscal year?

Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive
officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is
required if you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar
status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a
public reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a
class of your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild,
grandchild, parent, stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-
law, sharing the same residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to
purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has
contributed, 5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5%
or more of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No

4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or
member; and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last DE/FE/I Title or Status Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of
Name, First Name, Middle Name) Acquired MM/YYYY Code Person Birth, IRS Tax No. or Employer ID No.
MILLER, ANTHONY MATTHEW I DIRECTOR, 01/2024 NA Y N 4597116
PRESIDENT AND
CEO
MCSHEA, GREGORY BURNS I GENERAL 12/2012 NA N N 2870963
COUNSEL
DOWNEY, DANEEN ELIZABETH I DEPUTY GENERAL 06/2015 NA N N 4758790
COUNSEL
LEMPA, JESSICA ELLEN I IA CCO 05/2018 NA N N 5276453
MULLAN, DAVID MICHAEL I PRINCIPAL 10/2018 NA N N 2739186
OPERATIONS
OFFICER
HALL, CAROLINE KATHRYNE I CHIEF 03/2021 NA N N 6342772
COMPLIANCE
OFFICER
FUSCO, CHRISTOPHER I ROSFP 03/2021 NA N N 5858082
REED, KEVIN JUDE I EXECUTIVE 01/2023 NA Y N 2105832
OFFICER
HRICKO, MICHAEL J I CHIEF FINANCIAL 02/2023 NA N N 4509746
OFFICER
JUNE PURCHASER LLC DE OWNER 11/2024 E Y N
RIGGI, BRETT STEPHAN I CHIEF 02/2025 NA N N 4462496
OPERATING
OFFICER

Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct
the sale of, 25% or more of a class of a voting security of that corporation;

For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent,
grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence;
or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon
dissolution, or have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have
contributed, 25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of
the Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or
"I" if the owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or
members, the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does
not have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: DE/FE/I Entity in Which Interest Status Date Status Ownership Control PR CRD No. If None: S.S. No.
Last Name, First Name, Middle is Owned Acquired Code Person and Date of Birth, IRS Tax
Name) MM/YYYY No. or Employer ID No.
JUNE HOLDCO, LLC DE JUNE PURCHASER, LLC ACTIVE 11/2024 E Y N
JUNE INTERMEDIATE, LLC DE JUNE HOLDCO, LLC ACTIVE 11/2024 E Y N
JUNE TOPCO, LLC DE JUNE INTERMEDIATE, LLC ACTIVE 11/2024 E Y N
KKR JUNE AGGREGATOR L.P. DE JUNE TOPCO, L.L.C. SHAREHOLDER 11/2024 E Y N
K-PEC JUNE AGGREGATOR GP LLC DE KKR JUNE AGGREGATOR GENERAL 08/2024 F Y N
L.P. PARTNER
K-PEC HOLDINGS LLC DE K-PEC JUNE AGGREGATOR SHAREHOLDER 07/2024 E Y N
GP LLC
KKR PRIVATE EQUITY DE K-PEC HOLDINGS LLC SHAREHOLDER 01/2023 E N Y
CONGLOMERATE LLC
KKR JUNE AGGREGATOR GP LLC DE KKR JUNE AGGREGATOR GENERAL 11/2024 F Y N
L.P. PARTNER
KKR NORTH AMERICA FUND XIII DE KKR JUNE AGGREGATOR LIMITED 11/2024 E N N
(JUNE) L.P. L.P. PARTNER
JUNE TOPCO GP LLC DE KKR NORTH AMERICA GENERAL 11/2024 F Y N
FUND XIII (JUNE) L.P. PARTNER
KKR NORTH AMERICA XIII (JUNE) DE KKR NORTH AMERICA LIMITED 11/2024 D N N
BLOCKER LLC FUND XIII (JUNE) L.P. PARTNER
KKR NORTH AMERICA XIII (JUNE) DE KKR NORTH AMERICA XIII MEMBER 11/2024 E Y N
BLOCKER PARENT L.P. (JUNE) BLOCKER LLC
JUNE TOPCO GP LLC DE KKR NORTH AMERICA XIII GENERAL 11/2024 F Y N
(JUNE) BLOCKER PARENT PARTNER
L.P.
KKR GROUP ASSETS HOLDINGS III DE KKR PRIVATE EQUITY SHAREHOLDER 12/2022 E Y N
L.P. CONGLOMERATE LLC
KKR GROUP ASSETS III GP LLC DE KKR GROUP ASSETS SHAREHOLDER 08/2020 E Y N
HOLDINGS III L.P.
KKR GROUP PARTNERSHIP L.P. DE KKR GROUP ASSETS III GP SHAREHOLDER 08/2020 E Y N
LLC
KKR GROUP HOLDINGS CORP. DE KKR GROUP PARTNERSHIP GENERAL 01/2020 D Y N
L.P. PARTNER
KKR GROUP HOLDINGS CORP. DE KKR GROUP HOLDINGS GENERAL 05/2022 F Y N
L.P. PARTNER
KKR GROUP HOLDINGS L.P. FE KKR GROUP PARTNERSHIP LIMITED 01/2020 C N N
L.P. PARTNER
KKR GROUP CO. INC. DE KKR GROUP HOLDINGS LIMITED 05/2022 E N N
L.P. PARTNER
KKR GROUP CO. INC. DE KKR GROUP HOLDINGS SOLE 07/2018 E Y N
CORP. SHAREHOLDER
KKR & CO. INC. DE KKR GROUP CO. INC. SOLE 05/2022 E Y Y
SHAREHOLDER

Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Section 5.K.(1) Asset Categories Janney Montgomery Scott, LLC. used the following methodology to determine how to categorize assets that could be
classified in more than one category: 1. Common stock, preferred securities, structured products and units are included in the Exchange-Traded Equity
Securities category if the security traded on a national exchange and within the Non Exchange-Traded Equity Securities category if they do not traded on a
national exchange. 2. Investment Grade Corporate Bonds include corporate bonds, collateralized mortgage obligations and real estate mortgage investment
conduits that have an S&P rating of BBB or higher and a Moody’s rating of Baa or higher. Corporate bonds, collateralized mortgage obligations and real
estate mortgage investment conduits that have an S&P rating of below BBB or a Moody’s rating below Baa are categorized as NonInvestment Grade
Corporate Bonds. Those securities given opposing ratings by Moody’s and S&P (investmentgrade and noninvestment grade) automatically default to the
non-investment grade category. 3. Annuities have characteristics that are not primarily representative of any of the defined asset categories, therefore
annuity products are listed in the Other category. 4. Derivative regulatory asset values are calculated using the absolute market value of the security.
Section 7: Financial Industry Affiliations: We have a supplementary list of related persons who are not listed in Section 7.A because (1) we have no business
dealings with the related person in connection with advisory services we provide to our clients; (2) we do not conduct shared operations with the related
person; (3) we do not refer clients or business to the related person, and the related person does not refer prospective clients or business to us; (4) we do
not share supervised persons or premises with the related person; and (5) we have no reason to believe that our relationship with the related person
otherwise creates a conflict of interest with our clients. We will provide a copy of that list upon request.

Schedule R

No Information Filed

DRP Pages

CRIMINAL DISCLOSURE REPORTING PAGE (ADV)

No Information Filed

REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.

ADV DRP - ADVISORY AFFILIATE

CRD 7324
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: PARKER/HUNTER
INCORPORATED
(For individuals, Last, First,
Middle)

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)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):

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:

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
THE STATE OF ILLINOIS

2. Principal Sanction:
Revocation
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

12/01/2004 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
0400652

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
NO PRODUCT

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO PROHIBITION PURSUANT TO SECTION 8.E(1)(K) OF THE
ILLINOIS SECURITIES LAW BECAUSE RESPONDENT CONSENTED TO A SECURITIES AND EXCHANGE COMMISSION ORDER.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

06/02/2005 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:

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF DELAWARE
2. Principal Sanction:
Cease and Desist
Other Sanctions:
ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE

3. Date Initiated (MM/DD/YYYY):

06/29/2015 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
11-2-4

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):
IT WAS ALLEGED THAT FORMER FINANCIAL ADVISOR, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN UNSUITABLE
TRANSACTIONS AND THAT BLOCK WAS NOT REASONABLY SUPERVISED.

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):

06/29/2015 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 105,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT
ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE
FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN
UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE
OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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:
Censure
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/02/2003 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
SEC RELEASE NO. 33-8475

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):
IN THREE INSTANCES IN 1999 AND 2000, THE FIRM FAILED TO DISCLOSE THAT IT HAD RECEIVED A PAYMENT FOR PUBLISHING RESEARCH. IT WAS
ALSO ALLEGED THE FIRM FAILED TO MAINTAIN INTERNAL ELECTRONIC MAIL COMMUNICATIONS FROM JULY 1999 THROUGH JUNE 2001.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Settled

11. Resolution Date (MM/DD/YYYY):

09/16/2004 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: $ 875,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
DURING 1999 AND 2000, JANNEY MONTGOMERY RECEIVED THREE PAYMENTS IN CONSIDERATION FOR PUBLISHING RESEARCH ON THREE PUBLIC
COMPANIES. JANNEY MONTGOMERY DID NOT DISCLOSE THOSE PAYMENTS IN ITS RESEARCH REPORTS. THE FIRM'S FAILURE TO DISCLOSE THESE
PAYMENTS WERE IN VIOLATION OF SECTION 17(B) OF THE SECURITIES ACT. IN ADDITION, FROM JULY 1999 THROUGH JUNE 2001, JANNEY
MONTGOMERY FAILED TO PRESERVE BUSINESS-RELATED INTERNAL ELECTRONIC MAIL COMMUNICATIONS THAT IT WAS REQUIRED TO MAINTAIN
PURSUANT TO SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-4 THEREUNDER.

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.

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/04/2005 Exact Explanation
If not exact, provide explanation:
THIS REPRESENTS A FINAL DECISION OF A PREVIOUSLY REPORTED MATTER.

4. Docket/Case Number:
XY 2004 004

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
JANNEY MONTGOMERY SCOTT LLC

6. Principal Product Type:
Other
Other Product Types:
INVESTMENT ADVICE

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
JANNEY MONTGOMERY SCOTT (JMS) ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT
SECURITIES TRANSACTIONS WITH A COLORADO RESIDENT.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

05/04/2005 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:

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).
JMS ALLOWED ALBERT COPPERSTONE, AN UNLICENSED SALES REPRESENTATIVE IN COLORADO, TO CONDUCT SECURITIES TRANSACTIONS WITH A
COLORADO RESIDENT.

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.

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

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.

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:

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)
NASD

2. Principal Sanction:
Censure
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/21/2005 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
EAF0300920002

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 NASD ALLEGED THAT JANNEY ENGAGED IN CONDUCT WHICH PERMITTED TWO HEDGE FUND CLIENTS TO ENGAGE IN MARKET-TIMING. THE NASD
ALSO ALLEGED THAT JANNEY FAILED TO APPROPRIATELY RESPOND TO MARKET TIMING THAT WAS OCCURRING AND FAILED TO ESTABLISH AND
MAINTAIN SYSTEMS AND PROCEDURES REASONABLY DESIGNED TO PREVENT AND DETECT MARKET TIMING AND LATE TRADING. FURTHER, THE NASD
ALLEGED THAT JANNEY, FROM MAY 2, 2003 THROUGH SEPTEMBER 18, 2003, FAILED TO CREATE RECORDS REFLECTING THE TIME OF RECEIPT OF
MUTUAL FUND ORDERS. FINALLY, THE NASD ALLEGED THAT JANNEY FAILED TO ESTABLISH AND MAINTAIN SYSTEMS AND PROCEDURES REASONABLY
DESIGNED TO ENSURE THAT IT CONDUCTED ADEQUATE DUE DILIGENCE FOR ITS RESPONSES TO REGULATORY INQUIRIES.

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):

07/21/2005 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 1,200,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
PHILADELPHIA STOCK EXCHANGE

2. Principal Sanction:
Censure
Other Sanctions:
MONETARY/FINE OF $20,000.00

3. Date Initiated (MM/DD/YYYY):

07/17/2002 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
ENFORCEMENT NUMBER 2002-09

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Options
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS OR VIOLATIONS, RESPONDENT CONSENTED TO FINDINGS THAT FROM DECEMBER 3, 2001,
THROUGH MAY 8, 2002, IT VIOLATED PHLX RULES 707, 708, AND 748. SPECIFICALLY, (I) AN EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED
FOR RESPONDENT 46 ORDERS ON THE PHLX FLOOR AT A TIME WHEN SUCH EMPLOYEE WAS NOT A MEMBER OF THE PHLX ELIGIBLE TO CONDUCT
BUSINESS ON THE PHLX FLOOR; (II) ANTHER EMPLOYEE OF RESPONDENT REPRESENTED AND EXECUTED FOR RESPONDENT 41 ORDERS ON THE PHLX
FLOOR AT A TIME WHEN SUCH EMPLOYEE HAD NOT BECOME AN EFFECTIVE MEMBER OF THE PHLX BY TEMPORARILY ASSUMING LEGAL TITLE TO ONE OF
RESPONDENT'S PHLX MEMBERSHIPS; (III) RESPONDENT AVOIDED COSTS ASSOCIATED WITH ACQUIRING EQUITABLE TITLE TO A THIRD PHLX
MEMBERSHIP AND AVOIDED HAVING PAY TO THE PHLX CERTAIN DUES, FEES AND CHARGES; AND (IV) RESPONDENT FAILED TO MAINTAIN AND ENFORCE
WRITTEN SUPERVISORY PROCEDURES, AND A SYSTEM TO ENFORCE SUCH PROCEDURES, REGARDING ITS OPERATIONS ON THE PHLX FLOOR.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Decision & Order of Offer of Settlement

11. Resolution Date (MM/DD/YYYY):

11/24/2003 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: $ 20,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
RESPONDENT CONSENTED TO: (I) A CENSURE; (II) A FINE IN THE AMOUNT OF $20,000; AND (III) COMPLETION OF THE FOLLOWING
UNDERTAKINGS: (1) ISSUANCE OF WRITTEN POLICIES AND PROCEDURES (INCLUDING SUPERVISORY PROCEDURES) PERTAINING TO THE
CONDUCT OF BUSINESS BY RESPONDENT ON THE PHLX FLOOR. SUCH POLICIES AND PROCEDURES SHOULD INFORM RESPONDENT'S EXCHANGE
FLOOR PERSONNEL AND SUPERVISORS OF, AMONG OTHER THINGS, RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE
NOMINEE STATUS ON THE PHLX FLOOR; AND (2) ISSUANCE OF A COMPLIANCE BULLETIN, NOT UNACCEPTABLE TO PHLX STAFF, TO ALL MEMBERS
OF RESPONDENT'S EXCHANGE FLOOR OPERATIONS, EXPLAINING RESPONDENT'S POLICIES AND PROCEDURES CONCERNING INACTIVE NOMINEE
STATUS ON THE PHLX FLOOR.

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
THE STATE OF ILLINOIS
2. Principal Sanction:
Revocation
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/07/2004 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
0300927

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
RESPONDENT'S REGISTRATION AS A DEALER IN THE STATE OF ILLINOIS IS SUBJECT TO REVOCATION BECAUSE OF AN INADVERTENT REGISTRATION
ERROR RELATING TO THE REGISTRATION OF TWO FINANCIAL CONSULTANTS OF THE FIRM.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

08/16/2004 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 5,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
CONSENT ORDER OF CENSURE ISSUED. RESPONDENT, WHILE NEITHER ADMITTING NOR DENYING THE TRUTH OF THE ALLEGATIONS REGARDING THE
REGISTRATION OF TWO OF ITS FINANCIAL CONSULTANTS IN THE STATE OF ILLINOIS, CONSENTED TO A CENSURE AND WILL PAY FOR THE COST OF
INVESTIGATION.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
THE STATE OF GEORGIA

2. Principal Sanction:
Censure
Other Sanctions:
CIVIL PENALTY

3. Date Initiated (MM/DD/YYYY):

05/13/2004 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
CASE NUMBER EN-19766

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):
IT WAS ALLEGED JANNEY MONTGOMERY FAILED TO KEEP THE REQUIRED REGISTRATION RECORDS OF LICENSES AND REGISTRATIONS PERTAINING TO
TWO REGISTERED REPRESENTATIVES.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Order

11. Resolution Date (MM/DD/YYYY):

08/18/2004 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: $ 3,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
JANNEY MONTGOMERY SCOTT LLC NEITHER ADMITS NOR DENIES THE FINDING OF FACT AND CONCLUSIONS OF LAW CONTAINED HEREIN, BUT
CONSENTS TO THE ENTRY OF THE FOREGOING CONSENT ORDER.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
THE STATE OF RHODE ISLAND

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

10/12/2006 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

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):
IT WAS ALLEGED THERE WAS A VIOLATION OF SECTION 203 OF RIUSA IN JANNEY MONTGOMERY SCOTT LLC EMPLOYMENT OF ONE INDIVIDUAL AS AN
INVESTMENT ADVISOR REPRESENTATIVE WHO SERVICED ONE RHODE ISLAND ACCOUNT JANUARY 2006 WITHOUT EFFECTIVE LICENSING.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

12/21/2006 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: $ 10,250.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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 AN ADMINISTRATIVE ERROR A VIOLATION OF SECTION 203 OF RIUSA OCCURRED WHEN JANNEY MONTGOMERY SCOTT LLC PERMITTED ONE
INVESTMENT ADVISOR REPRESENTATIVE TO SERVICE ONE RHODE ISLAND ACCOUNT IN JANUARY 2006 WITHOUT EFFECTIVE LICENSING.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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)
NASD

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/27/2007 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
20050001285-01

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):
SEC RULE 604 OF REGULATION NMS (FORMERLY SEC RULE 11AC1-4) RESPONDENT MEMBER FAILED FROM APRIL 1, 2004 TO SEPTEMBER 30, 2004 TO
DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES IN ITS PUBLIC QUOTATION WHEN EACH SUCH ORDER WAS AT A PRICE THAT
WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SECURITY; OR WHEN THE ORDER WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND
THE NATIONAL BEST BID OR OFFER FOR EACH SECURITY AND THE SIZE OF THE ORDER REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION
TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SECURITY.

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):

07/27/2007 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 5,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
NEW YORK STOCK EXCHANGE DIVISION OF ENFORCEMENT

2. Principal Sanction:
Censure
Other Sanctions:
FINE & UNDERTAKING

3. Date Initiated (MM/DD/YYYY):

07/27/2006 Exact Explanation
If not exact, provide explanation:
ON OR AROUND JULY 27, 2006, THE NYSE DIVISION OF ENFORCEMENT INFORMED THE FIRM THAT IT WAS BEING REFERRED FOR DISCIPLINARY
PROCEEDINGS.

4. Docket/Case Number:
HPD#07-107

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
SECURITIES LENDING AND BORROWING

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE NYSE ALLEGED THAT JANNEY (1) ENGAGED IN AWAY-FROM-MARKET STOCK LOAN TRANSACTIONS; (2) COMPENSATED ALLEGED FINDERS IN
CONNECTION WITH STOCK LOAN TRANSACTIONS WHEN THOSE FINDERS HAD PURPORTEDLY NOT PERFORMED ANY SERVICES IN CONNECTION WITH
THOSE TRANSACTIONS; (3) FAILED TO REASONABLY SUPERVISE OR CONTROL CERTAIN OF ITS BUSINESS ACTIVITIES; (4) FAILED TO PROVIDE FOR
APPROPRIATE PROCEDURES OF SUPERVISION AND CONTROL AND ESTABLISH A SEPARATE SYSTEM OF FOLLOW-UP AND REVIEW TO DETERMINE THAT
DELEGATED AUTHORITY AND RESPONSIBILITY WAS BEING PROPERLY EXERCISED; AND (5) FAILED TO MAKE AND KEEP ACCURATE RECORDS
REFLECTING ITS STOCK LOAN ACTIVITIES.

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:
Stipulation and Consent

11. Resolution Date (MM/DD/YYYY):

08/10/2007 Exact Explanation
If not exact, provide explanation:
THE NYSE'S HEARING BOARD DECISION CONFIRMING THE STIPULATION OF FACTS AND CONSENT TO PENALTY BECAME FINAL ON THE CLOSE OF
BUSINESS ON AUGUST 10, 2007.

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 2,500,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
WITHOUT ADMITTING OR DENYING GUILT, THE FIRM CONSENTED TO (1) A CENSURE; (2) A FINE IN THE AMOUNT OF $2,500,000; AND (3) AN
UNDERTAKING TO REQUIRING THE FIRM TO CONTINUE TO RECORD THE TELEPHONE CONVERSATIONS OF ITS STOCK LOAN DEPARTMENT AND
RETAIN THE RECORDINGS FOR A PERIOD OF NO LESS THAN ONE YEAR.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
IN RESOLVING THIS MATTER, THE NYSE CONSIDERED (1) THAT THE FIRM IMMEDIATELY AND VOLUNTARILY UNDERTOOK NUMEROUS REMEDIAL EFFORTS,
(2) IMPLEMENTED REVISED AND ENHANCED WRITTEN SUPERVISORY PROCEDURES, (3) VOLUNTARILY COMMENCED RECORDING ALL TELEPHONE
CONVERSATIONS IN THE STOCK LOAN DEPARTMENT, (4) THE FIRM'S COOPERATION WITH NYSE REGULATION AND (5) THAT NO CUSTOMER ACCOUNTS
WERE AFFECTED BY THE ALLEGED IMPROPER ACTIVITIES IN THE STOCK LOAN DEPARTMENT.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
FLORIDA OFFICE OF FINANCIAL REGULATION

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CEASE AND DESIST

3. Date Initiated (MM/DD/YYYY):

04/19/2011 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
0356-S-07/10

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):
IT WAS ALLEGED THAT JANNEY DID NOT COMPLY WITH CERTAIN ITEMS IN THE REGISTRATION AGREEMENTS OF SEVERAL REGISTERED
REPRESENTATIVES.

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):

04/19/2011 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: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
WITHOUT ADMITTING OR DENYING THE ALLEGATIONS RAISED BY THE STATE OF FLORIDA, OFFICE OF FINANCIAL REGULATION, JANNEY MONTGOMERY
SCOTT LLC ENTERED INTO A STIPULATION AND CONSENT AGREEMENT WITH THE OFFICE, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL
ORDER DATED APRIL 19, 2011. JANNEY CONSENTED TO THE FINDING THAT IT DID NOT COMPLY WITH CERTAIN TERMS OF THE REGISTRATION
AGREEMENTS BELONGING TO SEVERAL OF ITS REGISTERED REPRESENTATIVES, AGREED TO CEASE AND DESIST FROM ANY OTHER VIOLATIONS OF
FLORIDA'S ADMINISTRATIVE RULES AND PAID AN ADMINISTRATIVE FINE OF $10,000. THE OFFICE OF FINANCIAL REGULATION AGREED TO RELEASE
THREE REGISTERED REPRESENTATIVES FROM THEIR REGISTRATION AGREEMENTS.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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:
Censure
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/10/2011 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2009018503501

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Debt - Municipal
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IT IS ALLEGED THAT JANNEY DID NOT COMPLY WITH MSRB RULES G-8, G-17, G-27, G-32, RELATED TO THE DELIVERY OF OFFICIAL STATEMENTS.

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):

05/10/2011 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: $ 75,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $75,000 RELATED TO VIOLATIONS OF MSRB RULES G-32, G-8,
G-27 AND G-17, STEMMING FROM ITS UNTIMELY DELIVERY OF OFFICIAL STATEMENTS TO CUSTOMERS WHO PURCHASED MUNICIPAL SECURITIES
DURING THE PRIMARY OFFERING DISCLOSURE PERIOD, IN TRANSACTIONS IN WHICH JANNEY WAS NEITHER AN UNDERWRITER NOR PART OF THE
UNDERWRITING SYNDICATE. IN RESPONSE, JANNEY ENHANCED ITS POLICIES AND PROCEDURES RELATING TO TIMELY DELIVERY OF OFFICIAL
STATEMENTS AND PROVIDED STAFF TRAINING ON RULE REQUIREMENTS AND THE ENHANCED PROCEDURES. JANNEY ALSO NOTIFIED CLIENTS WHO MAY
NOT HAVE RECEIVED AN OFFICIAL STATEMENT BY SETTLEMENT DATE AND PROVIDED INSTRUCTIONS AS TO HOW ONE MIGHT BE OBTAINED. JANNEY IS
CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS, INCLUDING ITS
OBLIGATIONS AS TO MUNICIPAL SECURITIES DISCLOSURE OBLIGATIONS.

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.

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 it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CEASE AND DESIST, CENSURE AND AN UNDERTAKING TO RETAIN A QUALIFIED, INDEPENDENT CONSULTANT TO REVIEW THE FIRM'S RELEVANT
POLICIES AND PROCEDURES RELATED TO SECTION 15(G) OF THE EXCHANGE ACT.

3. Date Initiated (MM/DD/YYYY):

07/11/2011 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
3-14459

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):
IT IS ALLEGED THAT JANNEY FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICIES AND PROCEDURES REASONABLY DESIGNED,
TAKING INTO CONSIDERATION OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO SECTION 15(G) OF
THE EXCHANGE ACT AND IN CERTAIN INSTANCES, FAILED TO PROPERLY IMPLEMENT OR ENFORCE SUCH POLICIES AND 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:
Order

11. Resolution Date (MM/DD/YYYY):
07/11/2011 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: $ 850,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
JANNEY HAS UNDERTAKEN TO RETAIN A QUALIFIED, INDEPENDENT CONSULTANT TO REVIEW THE FIRM'S RELEVANT POLICIES AND PROCEDURES
RELATED TO SECTION 15(G) OF THE EXCHANGE ACT.
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:
CIVIL MONETARY PENALTY OF $850,000 PAID IN FULL BY JANNEY MONTGOMERY SCOTT LLC ON JULY 12, 2011.

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).
JANNEY SUBMITTED AN OFFER OF SETTLEMENT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, AND CONSENTED TO THE FINDING THAT FROM
2005 THROUGH 2009, THE FIRM FAILED TO ADEQUATELY ESTABLISH, MAINTAIN AND ENFORCE POLICITES AND PROCEDURES REASONABLE DESIGNED,
TAKING INTO CONSIDERATION THE NATURE OF ITS BUSINESS, TO PREVENT THE MISUSE OF MATERIAL, NONPUBLIC INFORMATION PURSUANT TO
SECTION 15(G) OF THE EXCHANGE ACT AND IN CERTAIN INSTANCES, SUCH POLICIES AND PROCEDURES WERE NOT PROPERLY IMPLEMENTED OR
ENFORCED. THROUGHOUT THE COURSE OF THIS MATTER, JANNEY COMMITTED SIGNIFIGANT RESOURCES TO IMPROVING ITS SECTION 15(G) POLICIES
AND PROCEDURES AND WILL CONTINUE TO EVALUATE THESE PROCEDURES WHILE WORKING WITH AN INDEPENDENT CONSULTANT.

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.

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

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:

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:
Censure
Other Sanctions:
A CENSURE, FINE AND UNDERTAKING

3. Date Initiated (MM/DD/YYYY):

12/16/2011 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
20080141700-01

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Equity - OTC
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
BETWEEN JUNE 1, 2007 AND MAY 31, 2009, IT IS ALLEGED THAT JANNEY REPORTED 12,733 TRANSACTIONS ON OTC SECURITIES WHICH IT WAS NOT
REQUIRED TO REPORT AND THAT THE FIRM'S SUPERVISORY SYSTEM WAS NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH APPLICABLE
SECURITIES LAWS CONCERNING TRADE REPORTING.

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):

12/16/2011 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: $ 12,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKING TO REVIEW FIRM'S RELEVANT SUPERVISORY PROCEDURES AND ADVISE FINRA IN WRITING WITHIN 30 DAYS OF AWC ACCEPTANCE
OF ANY REVISIONS TO SUCH PROCEDURES.
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:
$12,500.00 PAID BY CREDIT CARD ON 12/28/2011.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE FIRM HAS UPDATED ITS WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO TRADE REPORTING TRANSACTIONS BY WAY OF A GIVE UP
AGREEMENT.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE

3. Date Initiated (MM/DD/YYYY):

11/03/2010 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
LETTER OF ACCEPTANCE, WAIVER AND CONSENT ("AWC"), NO. 2007009458001

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):
JANNEY ENTERED INTO AN AWC ARISING FROM ISSUES IDENTIFIED IN FINRA'S ROUTINE CYCLE EXAMINATIONS OF THE FIRM IN THE YEARS 2003
THROUGH 2005. THE VIOLATIONS SET FORTH IN THE AWC, WHICH JANNEY NEITHER ADMITTED NOR DENIED, INCLUDE 1) A FAILURE TO ADEQUATELY
MONITOR AND SUPERVISE CERTAIN ELEMENTS OF COMPLIANCE WITH ITS AML PROGRAM AND 2) FAILURE TO ESTABLISH AND MAINTAIN CERTAIN
ELEMENTS OF ITS BRANCH SUPERVISION PROGRAM RELATED TO REGISTERED REPRESENTATIVES AND OTHER ASSOCIATED PERSONS, INCLUDING
FAILURE TO SUPERVISE CERTAIN ACTIVITIES OF BRANCH MANAGERS, FAILURE TO REVIEW BLOOMBERG EMAILS AND INSTANT MESSAGES OF SOME
EMPLOYEES, FAILURE TO ESTABLISH PROCEDURES FOR APPROVAL AND SUPERVISION OF USE OF PERSONAL COMPUTERS, FAILURE TO DETERMINE THE
NUMBER OF OUTSIDE ACCOUNTS MAINTAINED BY EMPLOYEES , IN 2003 A FAILURE TO DOCUMENT SUPERVISORY REVIEW OF TRADING IN OPTIONS
ACCOUNTS, AND SEVERAL INSTANCES EACH YEAR OF FAILURE TO PRE-REVIEW AND APPROVE COMMUNICATIONS WITH THE PUBLIC.

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):

11/03/2010 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: $ 175,000.00
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:
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM WAS CENSURED AND FINED $175,000, WITH $25,000 RELATED TO VIOLATIONS OF
MSRB RULE G-41. JANNEY ALSO SUBMITTED A CORRECTIVE ACTION STATEMENT WHICH SETS FORTH THE ENHANCEMENTS MADE TO THE FIRM'S
COMPLIANCE AND SUPERVISORY POLICIES AND PROCEDURES. THE ENHANCEMENTS INCLUDE IMPLEMENTING NEW PROCEDURES, CONTRACTING
NEW VENDORS, AND ADOPTING NEW TECHNOLOGIES, AS WELL BOLSTERING SUPERVISORY EFFORTS IN CERTAIN AREAS. IN ADDITION, JANNEY
PLACED A FIRM-WIDE EMPHASIS ON ITS AML PROGRAM, INCLUDING FIRM-WIDE AML TRAINING AND ENHANCED SURVEILLANCE TOOLS. JANNEY IS
CONFIDENT THAT THESE MEASURES DEMONSTRATE ITS ONGOING COMMITMENT TO COMPLIANCE IN ALL AREAS OF ITS BUSINESS.
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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
FINRAFINANCIAL INDUSTRY REGULATORY AUTHORITY (FINRA)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):
01/20/2010 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2007009222201

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
TRACE-ELIGIBLE SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
RESPONDENT JANNEY FAILED IN 2007 TO REPORT TO TRACE LARGE BLOCK TRANSACTIONS IN TRACE-ELIGIBLE SECURITIES WITHIN 15 MINUTES OF
THE TIME OF EXECUTION IN VIOLATION OF NASD RULES 2110 AND 6230(A)

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Acceptance, Waiver & Consent(AWC)

11. Resolution Date (MM/DD/YYYY):

01/20/2010 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 5,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
FINANCIAL INDUSTRY REGULATORY AUTHORITY

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:
CENSURE; COMPLETE VOLUNTARY PURCHASE OF ELIGIBLE ARS FROM INVESTORS IN RELEVANT CLASS; MAKE BEST EFFORTS TO PROVIDE LIQUIDITY TO
ARS PURCHASERS NOT IN RELEVANT CLASS; PAY DIFFERENCE BETWEEN PAR & PRICE AT WHICH ANY INVESTOR IN RELEVANT CLASS WHO SOLD
ELIGIBLE ARS AT BELOW PAR; AGREE TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY THOSE IN RELEVANT CLASS THROUGH A
SPECIAL ARBITRATION PROGRAM; PROVIDE FINRA WITH REPORTS OF THE REPURCHASE & LIQUIDITY PROVISIONS OF AWC.

3. Date Initiated (MM/DD/YYYY):

05/06/2009 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2008013056401

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
AUCTION RATE SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE VIOLATIONS SET FORTH IN THE AWC WHICH JANNEY ENTERED INTO WITHOUT ADMITTING OR DENYING WERE: 1) FAILURE TO ADEQUATELY
DISCLOSE THE RISK OF INVESTING IN ARS, THAT ARS COULD BECOME ILLIQUID AND THAT CUSTOMERS MIGHT BE UNABLE TO OBTAIN ACCESS TO
FUNDS INVESTED IN ARS FOR SUBSTANTIAL PERIODS OF TIME; 2) FAILURE TO ESTABLISH AND MAINTAIN PROCEDURES REASONABLY DESIGNED TO
ENSURE THAT ARS WERE MARKETED AND SOLD IN COMPLIANCE WITH APPLICABLE RULES AND LAWS; 3) FAILURE TO MAINTAIN POLICIES AND
PROCEDURES REASONABLY DESIGNED TO ENSURE ACCURATE DESCRIPTIONS OF ARS TO CUSTOMERS DURING SALES PRESENTATIONS; AND 4) FAILURE
TO PROVIDE ADEQUATE TRAINING TO REGISTERED REPRESENTATIVES REGARDING ARS CHARACTERISTICS.

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):

05/06/2009 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: $ 200,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
COMPLETE ITS VOLUNTARY PURCHASE AT PAR OF ELIGIBLE AUCTION RATE SECURITIES (ARS) (AS DEFINED IN THE AWC) FROM INVESTORS IN
RELEVANT CLASS; MAKE BEST EFFORTS TO PROVIDE LIQUIDITY TO OTHER INVESTORS NOT IN RELEVANT CLASS (AS DEFINED IN THE AWC) WHO
PURCHASED ARS FROM MEMBER FIRM; PAY THE DIFFERENCE BETWEEN PAR AND THE PRICE AT WHICH ANY INVESTOR IN RELEVANT CLASS WHO
SOLD ELIGIBLE ARS AT BELOW PAR; AGREE TO ARBITRATE CLAIMS FOR CONSEQUENTIAL DAMAGES FILED BY INVESTORS IN THE RELEVANT CLASS
RELATING TO ELIGIBLE ARS THROUGH A SPECIAL ARBITRATION PROGRAM (SAP); PROVIDE FINRA WITH REPORTS OF THE REPURCHASE AND
LIQUIDITY PROVISIONS OF THE AWC.
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:
PRIOR TO THE ACCEPTANCE BY FINRA OF THE AWC, JANNEY COMPLETED ITS VOLUNTARY REPURCHASE OF ELIGIBLE ARS, REPAID THE
DIFFERENCE TO THE SINGLE INVESTOR IT REASONABLY IDENTIFIED WHO SOLD FOR LESS THAN PAR DURING THE RELEVANT CLASS PERIOD.
JANNEY ALSO COMPLETED AN OFFER AND REPURCHASE TO 14 FORMER CUSTOMERS WHO HAD PURCHASED WITHIN THE RELEVANT CLASS
PERIOD BUT TRANSFERRED THEIR POSITION. JANNEY PAID THE FINE ON MAY 11, 2009.

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).
JANNEY ENTERED INTO THE AWC WITHOUT ADMITTING OR DENYING THE ALLEGATIONS. IN THE AWC FINRA TOOK INTO ACCOUNT THE SIGNIFICANT
STEPS JANNEY HAD TAKEN TO ADDRESS POTENTIAL HARM SUSTAINED BY CUSTOMERS AS A RESULT OF THE ILLIQUIDITY IN THE ARS MARKET THAT
BEGAN IN FEBRUARY 2008. ADDITIONALLY JANNEY BEGAN THE FOLLOWING ACTIONS PRIOR TO FINRA INVESTIGATION: EXTENDING COST NEUTRAL
MARGIN OR NONPURPOSE LOANS TO CUSTOMERS WHO HAD LIQUIDITY NEEDS. IN AUGUST 2008 JANNEY CHOSE TO REPURCHASE ALL CUSTOMERS' ARS
HOLDINGS THAT WERE PART OF NONFUNCTIONING MARKETS ARS HOLDINGS THAT WERE NOT PURCHASED AT JANNEY AS LONG AS THEY WERE IN A
JANNEY ACCOUNT BY AUGUST 15, 2008.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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:
Censure
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

04/24/2012 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2009020826501

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
NATIONAL MARKET SYSTEM (NMS) STOCKS

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA RULE 2010, 6380A, 6182, 7450; NASD RULE 2111(A), 2320, 3010; SEC RULE 17A-3, 17A-4, 200(G), AND RULE 611(A)(1). IN THE THIRD QUARTER
OF 2009 IN CERTAIN INSTANCES THE FIRM FAILED TO EXECUTE ORDERS FULLY AND PROMPTLY AND FAILED TO USE REASONABLE DILIGENCE TO
ASCERTAIN THE BEST INTERDEALER MARKET AVAILABLE. ADDITIONALLY IN DECEMBER 2009 IN CERTAIN INSTANCES THE FIRM INCORRECTLY MARKED
ITS LEDGER AS LONG WHEN THE FIRMS POSITION WAS SHORT, FAILED TO MAINTAIN CUSTOMER CONFIRMATIONS, FAILED TO ACCURATELY DOCUMENT
PROPRIETARY POSITIONS, FAILED TO SHOW CORRECT ORDER ENTRY AND FAILED TO PROVIDE ORDER MEMORANDA. THE FIRM ALSO INCORRECTLY
REPORTED THE SECOND LEG OF CERTAIN RISKLESS PRINCIPAL TRANSACTIONS AND TRANSMITTED INACCURATE FORMATTED ORDERS TO OATS. THE
FIRM EXECUTED SHORT SALE TRANSACTIONS AND FAILED TO APPEND A SHORT SALE MODIFIER TO TRF AND EXECUTED SHORT SALE ORDERS AND
FAILED TO MARK THE ORDER AS SHORT. ADDITIONALLY THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO PROVIDE FOR THE MINIMUM
REQUIREMENTS WITH RESPECT TO THE RULES OF FINRA AND THE SEC IN THE FOLLOWING SUBJECT AREAS: ORDER HANDLING; BEST EXECUTION;
ANTI-INTIMIDATION; TRADE REPORTING; SALE TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES;
ELECTRONIC COMMUNICATION; TRADE THROUGHS OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.

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):

04/24/2012 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: $ 55,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
A CENSURE, A FINE OF $55,000 AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE
ABOVE REFERENCED ALLEGATIONS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM CONSENTED TO A CENSURE, A FINE IN THE AMOUNT OF $55,000 AND AN
UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO ORDER HANDLING; BEST EXECUTION; ANTI-INTIMIDATION; TRADE REPORTING; SALE
TRANSACTIONS; TRADE HALTS; ERRORS; SOFT DOLLAR ACCOUNTS; OATS; SUB-PENNY RULES; ELECTRONIC COMMUNICATION; TRADE THROUGHS
OF PROTECTED QUOTATIONS IN NMS STOCKS; BACKING AWAY; AND INFORMATION BARRIERS.

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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED INTO AN AWC CONSENTING TO A CENSURE AND FINE OF $55,000 RELATED TO
NASD AND FINRA RULE VIOLATIONS STEMMING FROM A MARKET ORDER TIMELINESS("MOT") SWEEP FOR THE 3RD QUARTER OF 2009 AS WELL AS
FINDINGS RELATED TO THE TRADING AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION OF THE FIRM IN JANUARY 2010. THE FIRM HAS
UPDATED ITS WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE FINDINGS.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
NASDAQ STOCK MARKET

2. Principal Sanction:
Censure
Other Sanctions:
CENSURE AND FINE

3. Date Initiated (MM/DD/YYYY):

04/24/2012 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
20090208265-02

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
NASDAQ SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
NASDAQ RULES 4755, 2110, AND 3010: DURING DECEMBER 2009 THE FIRM ENTERED 29 ORDERS TO THE NASDAQ MARKET THAT FAILED TO CORRECTLY
INDICATE WHETHER THE ORDERS WERE A BUY, LONG SALE OR SHORT SALE. IN ADDITION THE FIRM'S WRITTEN SUPERVISORY PROCEDURES FAILED TO
PROVIDE FOR THE MINIMUM REQUIREMENTS WITH RESPECT TO THE RULES OF NASDAQ IN THE FOLLOWING SUBJECT AREAS: ACCURACY OF NASDAQ
ORDER ENTRY INFORMATION; REFRAINING FROM LOCKING OR CROSSING AN EXISTING QUOTE ON NASDAQ; AND CLEARLY ERRONEOUS TRANSACTIONS.
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):

04/24/2012 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: $ 10,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
A $10,000 FINE AND AN UNDERTAKING TO REVISE THE FIRM'S WRITTEN SUPERVISORY PROCEDURES WITH RESPECT TO THE ABOVE
ALLEGATIONS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS THE FIRM CONSENTED TO A CENSURE, A FINE IN THE AMOUNT OF $10,000 AND AN
UNDERTAKING TO REVISE ITS WSPS WITH RESPECT TO NASDAQ ORDER ENTRY INFORMATION, QUOTE SURVEILLANCE AND CLEARLY ERRONEOUS
TRANSACTIONS.

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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, JANNEY ENTERED INTO AN AWC WITH NASDAQ CONSENTING TO A CENSURE AND FINE OF $10,000
FOR VIOLATIONS OF NASDAQ RULES 4755, 2110, AND 3010. THESE VIOLATIONS RELATING TO FINDINGS FROM THE FIRM'S JANUARY 2010 TRADING
AND MARKET MAKING SURVEILLANCE ("TMMS") EXAMINATION. THE FIRM HAS UPDATED IT WRITTEN SUPERVISORY PROCEDURES TO ADDRESS THESE
FINDINGS.

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.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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:
Censure
Other Sanctions:
CIVIL AND ADMINISTRATIVE PENALTY/FINE

3. Date Initiated (MM/DD/YYYY):

08/08/2012 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2011028261501

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types:
MUNICIPAL SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN CONNECTION WITH A SETTLEMENT OF MATTERS ARISING OUT OF AN EXAMINATION FOR THE 2009-2010 PERIOD, FINRA ALLEGED THE FIRM
VIOLATED REG SHO RULES 204(A) AND 204(B) BY FAILING TO CLOSE OUT FAILS TO DELIVER RESULTING FROM SALE TRANSACTIONS IN CERTAIN
PROPRIETARY ACCOUNTS AND AS A RESULT NOT DETERMINING SECURITIES SHOULD HAVE BEEN RESTRICTED FROM FURTHER SHORT SALES, FAILING
TO COMPLY WITH THE CLOSE-OUT REQUIREMENTS IN CERTAIN CUSTOMER ACCOUNTS AND FAILING TO MAINTAIN AND APPLY CERTAIN
CORRESPONDING WRITTEN SUPERVISORY PROCEDURES AS REQUIRED BY FINRA RULE 3010, 3010(A) AND (B). FINRA ALSO ALLEGED THE FIRM
VIOLATED MSRB RULES IN CONNECTION WITH CERTAIN OFFERINGS DURING THE PERIOD BY FILING FORM G-32 WITH THE MUNICIPAL SECURITIES
RULEMAKING BOARD (MSRB) CONTAINING AN INCORRECT DATE FOR THREE OFFERINGS AND LATE TO EMMA FOR TEN OFFERINGS, FAILING TO TIMELY
SEND THE FINAL SETTLEMENT LETTERS TO ACCOMPLISH FINAL SETTLEMENT REQUIRED BY G-11 FOR TWO OFFERINGS, AND AMENDING BY ONE DAY
LATE THE OFFICIAL STATEMENT WITH MSRB REQUIRED BY G-36 IN THREE OFFERINGS. FINALLY FINRA ALLEGED THE FIRM VIOLATED RULE 3010 AND
MSRB G-27 BY FAILING TO ENFORCE ITS WRITTEN POLICIES AND PROCEDURES PERTAINING TO DEPOSITS OF LOW-PRICED SECURITIES THAT TRADED
ON THE OTCBB BY ACCEPTING A CERTIFICATE FOR 5 MILLION SHARES IN ONE BRANCH OFFICE WITHOUT OBTAINING AN EXCEPTION AS REQUIRED AND
EXECUTING FOUR RETAIL VARIABLE RATE DEMAND OBLIGATION (VRDO) SECURITIES TRADES WITHOUT UPDATING ITS WRITTEN SUPERVISORY
PROCEDURES (WSPS) TO ADDRESS THE DISCLOSURE OF ALL MATERIAL INFORMATION TO CUSTOMERS IN CONNECTION WITH SUCH TRANSACTIONS.

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):

08/08/2012 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: $ 52,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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):

12/12/2012 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2009020223601

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Debt - Municipal
Other Product Types:
EQUITY SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FINRA ALLEGED THE FIRM DID NOT CLOSE OUT FAIL-TO-DELIVER POSITIONS BY PURCHASING SECURITIES OF LIKE KIND AND QUANTITY WITHIN THE
TIME FRAME PRESCRIBED BY REG SHO AND RULE 204 AND 204T. FURTHER, THE FIRM DID NOT PROPERLY TRANSMIT REPORTABLE ORDER EVENTS
(ROES) TO THE ORDER AUDIT TRAIL SYSTEM (OATS) WITHIN THE APPROPRIATE TIME PERIOD DUE TO CONTEXT OR SYNTAX ERRORS. THE FIRM ALSO DID
NOT PROPERLY REPAIR OR RESUBMIT CERTAIN INACCURATE ROES WITHIN THE APPROPRIATE TIME PERIOD AS PRESCRIBED BY FINRA RULE 7450 .
FINALLY, AS REQUIRED BY MSRB RULE G-17 AND G-30(A), THE FIRM DID NOT REASONABLY PRICE CERTAIN MUNICIPAL SECURITIES THAT WERE
PURCHASED IN THE AGGREGATE FROM CUSTOMER ACCOUNTS.

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):

12/12/2012 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: $ 45,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THE
FIRM WAS ALSO CENSURED, FINED $45,000, ORDERED TO PAY $5,758.36 IN RESTITUTION TO CUSTOMERS RELATING TO THE MUNICIPAL
SECURITIES PRICING, AND REQUIRED TO REVISE ITS WRITTEN SUPERVISORY PROCEDURES REGARDING OATS.

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
COMMONWEALTH OF MASSACHUSETTS, DIVISION OF INSURANCE

2. Principal Sanction:
Cease and Desist
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

05/28/2013 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
SIU NO 7511

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):
THE MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION
ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1).

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Decision & Order of Offer of Settlement

11. Resolution Date (MM/DD/YYYY):

05/28/2013 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:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE MASSACHUSETTS DIVISION OF INSURANCE ALLEGES JANNEY MONTGOMERY SCOTT FAILED TO ACCURATELY ANSWER A BACKGROUND QUESTION
ON ITS 2010 LICENSE APPLICATION IN VIOLATION OF M.G.L. C.175 162R(A)(1). IN LIGHT OF ALL THE FACTS AND CIRCUMSTANCES, THE DIVISION
PROPOSED TO RESOLVE THIS MATTER THROUGH A SETTLEMENT IF JANNEY, WITHOUT ADMITTING TO ANY VIOLATION OF MASSACHUSETTS INSURANCE
LAWS, AGREES TO CEASE AND DESIST FROM THE ABOVE ALLEGED CONDUCT. THIS MATTER WAS RESOLVED ON MAY 28, 2013.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/02/2015 Exact Explanation
If not exact, provide explanation:
4. Docket/Case Number:
20120341461-01

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):
FINRA ALLEGED THE FIRM FAILED TO SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE
ORDERS DURING THE REVIEW PERIOD IN VIOLATION OF SEC RULE 17A-3 AND FINRA RULE 4511. ADDITIONALLY, DURING THE REVIEW PERIOD, THE
FIRM TRANSMITTED TO OATS 50 REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA. SPECIFICALLY, THE
REPORTS CONTAINED 50 INACCURATE ORDER RECEIPT TIMESTAMPS, 33 INACCURATE ACCOUNT TYPE CODES, 33 INACCURATE CAPACITY CODES, AND
50 INCOMPLETE SPECIAL HANDLING CODES IN VIOLATION OF FINRA RULE 7450(A).

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):

03/02/2015 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 17,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT FAILED TO
SHOW THE CORRECT TIME OF ENTRY AND THE TERMS AND CONDITIONS ON THE MEMORANDUM OF 50 BROKERAGE ORDERS AND TRANSMITTED 50
REPORTS THAT CONTAINED INACCURATE, INCOMPLETE, OR IMPROPERLY FORMATTED DATA TO THE ORDER AUDIT TRAIL SYSTEM (OATS). THE FIRM HAS
PAID THE REQUIRED PENALTY ($17,500) AND THE PROCESSES IN QUESTION HAVE SINCE BEEN AUTOMATED AND THE FIRMS POLICIES AND
PROCEDURES UPDATED ACCORDINGLY.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
NASDAQ STOCK MARKET

2. Principal Sanction:
Censure
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/11/2014 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2012034405001

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Equity - OTC
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
DISPLAY IMMEDIATELY CUSTOMER LIMIT ORDERS IN NASDAQ SECURITIES (INCLUDING THE ORDERS' FULL SIZE AND PRICE) IN ITS PUBLIC QUOTATION,
WHEN EACH SUCH ORDER WAS AT A PRICE THAT WOULD HAVE IMPROVED THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY; OR WHEN THE ORDER
WAS PRICED EQUAL TO THE FIRM'S BID OR OFFER AND THE NATIONAL BEST BID OR OFFER FOR EACH SUCH SECURITY, AND THE SIZE OF THE ORDER
REPRESENTED MORE THAN A DE MINIMIS CHANGE IN RELATION TO THE SIZE ASSOCIATED WITH THE FIRM'S BID OR OFFER IN EACH SUCH SECURITY, IN
VIOLATION OF SEC RULE 604 OF REGULATION NMS.

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):

07/11/2014 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: $ 12,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).

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.

PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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):

10/27/2015 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2015045368001

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):
WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF FINDINGS THAT CERTAIN RETIREMENT PLAN AND
CHARITABLE ORGANIZATION CUSTOMERS ELIGIBLE TO PURCHASE CERTAIN MUTUAL FUNDS AT A DISCOUNT WERE NOT ISSUED APPLICABLE
DISCOUNTS. THE FINDINGS FURTHER STATED THAT THE FIRM FAILED TO MAINTAIN POLICIES AND PROCEDURES DESIGNED TO ENSURE SUCH
DISCOUNTS WERE OFFERED AS APPROPRIATE.

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):
10/27/2015 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM WAS CENSURED AND AGREED TO PAY APPROXIMATELY $1,030,235, IN RESTITUTION PLUS INTEREST TO ELIGIBLE 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).
IN MAY 2015, THE FIRM SELF-REPORTED THAT SOME ELIGIBLE CUSTOMERS HAD NOT RECEIVED AVAILABLE SALES CHARGE WAIVERS. AS A RESULT, THE
FIRM ESTIMATES THAT ELIGIBLE CUSTOMERS WERE OVERCHARGED BY APPROXIMATELY $1,030,235 FOR MUTUAL FUND PURCHASES MADE BETWEEN
JULY 1, 2009 AND JUNE 24, 2015. AS PART OF THIS SETTLEMENT, THE FIRM AGREES TO PAY RESTITUTION PLUS INTEREST. THE FIRM WILL ALSO
ENSURE THAT RETIREMENT AND CHARITABLE ACCOUNT MUTUAL FUND FEE WAIVERS ARE APPROPRIATELY APPLIED TO ALL FUTURE TRANSACTIONS. IN
RESOLVING THIS MATTER, FINRA HAS RECOGNIZED THE EXTRAORDINARY COOPERATION OF THE FIRM FOR HAVING: (1) INITIATED, PRIOR TO
DETECTION OR INTERVENTION BY A REGULATOR, AN INVESTIGATION TO IDENTIFY WHETHER ELIGIBLE CUSTOMERS RECEIVED SALES CHARGE WAIVERS
DURING THE RELEVANT PERIOD; (2) PROMPTLY ESTABLISHED A PLAN OF REMEDIATION FOR ELIGIBLE CUSTOMERS WHO DID NOT RECEIVE
APPROPRIATE SALES CHARGE WAIVERS; (3) PROMPTLY SELF-REPORTED TO FINRA; (4) PROMPTLY TAKEN ACTION AND REMEDIAL STEPS TO CORRECT
THE VIOLATIVE CONDUCT; AND (5) EMPLOYED SUBSEQUENT CORRECTIVE MEASURES, PRIOR TO DETECTION OR INTERVENTION BY A REGULATOR, TO
REVISE ITS PROCEDURES TO AVOID RECURRENCE OF THE MISCONDUCT.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

02/02/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
3-17090

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Debt - Municipal
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
RESPONDENT WILLFULLY VIOLATED SECTION 17(A)(2) OF THE SECURITIES ACT. THIS MATTER INVOLVES VIOLATIONS OF AN ANTIFRAUD PROVISION OF
THE FEDERAL SECURITIES LAWS IN CONNECTION WITH RESPONDENT'S UNDERWRITING OF CERTAIN MUNICIPAL SECURITIES OFFERINGS.
RESPONDENT, A REGISTERED BROKER-DEALER, CONDUCTED INADEQUATE DUE DILIGENCE IN CERTAIN OFFERINGS AND AS A RESULT, FAILED TO FORM
A REASONABLE BASIS FOR BELIEVING THE TRUTHFULNESS OF CERTAIN MATERIAL REPRESENTATIONS IN OFFICIAL STATEMENTS ISSUED IN
CONNECTION WITH THOSE OFFERINGS. THIS RESULTED IN RESPONDENT OFFERING AND SELLING MUNICIPAL SECURITIES ON THE BASIS OF
MATERIALLY MISLEADING DISCLOSURE DOCUMENTS. THE VIOLATIONS WERE SELF-REPORTED BY RESPONDENT TO THE COMMISSION PURSUANT TO
THE DIVISION OF ENFORCEMENT'S (THE "DIVISION") MUNICIPALITIES CONTINUING DISCLOSURE COOPERATION (MCDC) INITIATIVE.

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):

02/02/2016 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: $ 500,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKING
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE RESPONDENT SHALL CEASE AND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTION 17(A)
(2)OF THE SECURITIES ACT, PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $500,000 AND 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).
WITHOUT ADMITTING OR DENYING THE VIOLATIONS, THE FIRM CONSENTED TO THE ENTRY OF AN SEC ORDER INSTITUTING ADMINISTRATIVE CEASE
AND DESIST PROCEEDINGS PURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933 AND SECTION 15(B) OF THE SECURITIES EXCHANGE ACT OF
1934 (THE "ORDER"). THE ORDER STEMS FROM THE FIRM'S SELF-REPORTING OF CERTAIN ACTIVITIES RELATED TO CONTINUING DISCLOSURE
OBLIGATIONS SPECIFIED IN RULES 15C2-12 UNDER THE SECURITIES EXCHANGE ACT WHEREBY THE FIRM MUST 1) CEASE AND DESIST FROM
COMMITTING OR CAUSING ANY FUTURE VIOLATIONS OF SECTION 17(A)(2) OF THE SECURITIES ACT, 2) PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF
$500,000, AND 3) COMPLY WITH CERTAIN UNDERTAKINGS, INCLUDING RETENTION OF AN INDEPENDENT CONSULTANT TO CONDUCT A REVIEW OF THE
FIRM'S POLICIES AND PROCEDURES AS THEY RELATE TO MUNICIPAL SECURITIES UNDERWRITING DUE DILIGENCE.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
COMMONWEALTH OF PENNSYLVANIA

2. Principal Sanction:
Other
Other Sanctions:
ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE

3. Date Initiated (MM/DD/YYYY):

07/18/2016 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
160041

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):
THE COMMONWEALTH OF PENNSYLVANIA CONDUCTED AN INVESTIGATION OF JANNEY MONTGOMERY SCOTT LLC ("JANNEY") REGARDING A FORMER
FINANCIAL ADVISOR, WHO WAS TERMINATED BY THE FIRM ON JULY 27, 2010. IT IS ALLEGED THAT JANNEY FAILED TO REASONABLY SUPERVISE THE
FINANCIAL ADVISOR DURING THE TERM OF HER EMPLOYMENT, RESULTING IN FAILURE TO DETECT AND PREVENT A FRAUDULENT SCHEME CONDUCTED
BY THE FORMER FINANCIAL ADVISOR.

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):

07/18/2016 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: $ 125,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE COMMONWEALTH OF PENNSYLVANIA, DEPARTMENT OF BANKING AND SECURITIES, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN
ADMINISTRATIVE CONSENT AGREEMENT AND ORDER, WHICH WAS ADOPTED BY THE COMMONWEALTH THROUGH A FINAL ORDER FILED ON JULY 18,
2016. BASED ON THE RESULTS OF THE INVESTIGATION, WHICH INCLUDED THE FULL COOPERATION OF JANNEY, THE FIRM CONSENTED TO THE
FINDINGS, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, THAT THE FIRM OPERATED IN VIOLATION OF THE PENNSYLVANIA SECURITIES ACT OF
1972, HAVING FAILED TO REASONABLY SUPERVISE THE SECURITIES ACTIVITIES OF THE FORMER FINANCIAL ADVISOR.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Cease and Desist
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/11/2019 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
3-19087

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):
IN JUNE OF 2018, THE FIRM VOLUNTARILY SELF-REPORTED THAT SOME CUSTOMERS ELIGIBLE TO PURCHASE MUTUAL FUNDS WHICH DID NOT CHARGE
12B-1 FEES DID NOT RECEIVE THE AVAILABLE LESS EXPENSIVE SHARE CLASS. AS A RESULT, THE FIRM ESTIMATED THAT ELIGIBLE CUSTOMERS WERE
OVERCHARGED $215,761 PLUS PRE JUDGEMENT INTEREST FOR MUTUAL FUND PURCHASES MADE SINCE JANUARY 1, 2014. THE FIRM AGREES TO PAY
RESTITUTION PLUS INTEREST, AS WELL AS TO REVIEW ITS RELATED DISCLOSURES AND PROCEDURES. THE FIRM HAS HAD PROCEDURES IN PLACE
INTENDED TO ADDRESS THIS ISSUE FOR MORE THAN A DECADE.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Other

11. Resolution Date (MM/DD/YYYY):

03/11/2019 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKINGS AND PREJUDGMENT INTEREST
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
THE FIRM HAS SUBMITTED AN OFFER OF SETTLEMENT, WHICH HAS BEEN ACCEPTED BY THE COMMISSION. THE FIRM SHALL CEASE AND DESIST
FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 206(2) AND 207 OF THE ADVISERS ACT.
RESPONDENT IS CENSURED, SHALL PAY DISGORGEMENT OF $215,761.17 AND PREJUDGMENT INTEREST OF $25,465.87, AND SHALL COMPLY
WITH THE UNDERTAKINGS ENUMERATED IN THE OFFER OF SETTLEMENT.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
OR
11.E., 11.F. or 11.G. of Form ADV.

Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
MASSACHUSETTS

2. Principal Sanction:
Cease and Desist
Other Sanctions:
ACCOUNTING RESTITUTION FINE

3. Date Initiated (MM/DD/YYYY):

05/07/2019 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2019-0050
5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
JANNEY MONTGOMERY SCOTT LLC

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):
SALES PRACTICE VIOLATIONS INVOLVING SHORT TERM TRADING IN CLASS A SHARES OF MUTUAL FUNDS BY AN ADVISOR WHO LEFT JANNEY IN 2018.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

04/01/2020 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 286,622.02
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
PROVIDE ACCOUNTING OF IMPACTED CUSTOMERS; PROVIDE WRITTEN OFFERS OF RESTITUTION; REVIEW WRITTEN POLICIES AND PROCEDURES
RELATED TO TRADING OF CLASS A SHARES OF MUTUAL FUNDS
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 AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02. PAYMENT WAS MADE ON APRIL 3, 2020.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON APRIL 1, 2020, JANNEY ENTERED INTO A CONSENT ORDER WITH THE STATE OF MASSACHUSETTS. WITHOUT ADMITTING OR DENYING ANY FINDINGS,
THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE OF $286,622.02 IN CONNECTION WITH AN ALLEGED FAILURE TO SUPERVISE THE MUTUAL FUND A
SHARE SALES PRACTICES OF A FORMER FINANCIAL ADVISOR UNDER SECTION 204(A)(2)(J) OF THE MASS GENERAL LAWS CHAPTER 110A. THE FIRM
FURTHER AGREED TO PROVIDE AN ACCOUNTING OF IMPACTED CUSTOMERS AND SUBSEQUENTLY PROVIDE WRITTEN OFFERS OF RESTITUTION; REVIEW
ITS WRITTEN POLICIES AND PROCEDURES RELATED TO TRADING OF CLASS A SHARES OF MUTUAL FUNDS; ACCEPTED A CENSURE AND AGREED TO
CEASE AND DESIST FROM SUCH ALLEGED VIOLATIONS.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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)
NASDAQ STOCK MARKET

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/22/2019 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2016051140601

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
UNSPECIFIED SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON MARCH 21, 2019, THE FIRM ENTERED INTO AN AWC WITH NASDAQ. WITHOUT ADMITTING OR DENYING ANY FINDINGS BY NASDAQ, THE FIRM
AGREED TO A FINE OF $27,500 WITH RESPECT TO ITS FAILURE BETWEEN 2015 AND 2017 TO MAINTAIN A CONTINUOUS TWO-SIDED TRADING
INTEREST DURING REGULAR MARKET HOURS AT PRICES WITHIN CERTAIN PERCENTAGES AWAY FROM THE NATIONAL BEST BID OR OFFER (NBBO).
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):

03/22/2019 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: $ 27,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

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).
CASE NO. 20160511406 (INCLUDES 20170545706 (INCLUDES 20170567114) AND 20180594816). SUBSEQUENT TO THE REVIEW PERIOD, THE FIRM
UPDATED ITS SUPERVISORY SYSTEMS, INCLUDING T+1 SURVEILLANCE AND AN INTRADAY REVIEW, THEREFORE, ENFORCEMENT IS NOT RECOMMENDING
AN UNDERTAKING.

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.

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

ADV DRP - ADVISORY AFFILIATE
No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF DELAWARE

2. Principal Sanction:
Cease and Desist
Other Sanctions:
ADMINISTRATIVE CONSENT ORDER AND MONETARY FINE

3. Date Initiated (MM/DD/YYYY):

06/29/2015 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
11-2-4

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:

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):

06/29/2015 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 105,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE STATE OF DELAWARE, OFFICE OF INVESTOR PROTECTION, AND JANNEY MONTGOMERY SCOTT LLC ENTERED INTO AN ADMINISTRATIVE CONSENT
ORDER, WHICH WAS ADOPTED BY THE OFFICE THROUGH A FINAL ORDER DATED JUNE 10, 2015 AND RECEIVED BY THE FIRM ON JUNE 29, 2015. THE
FIRM CONSENTED TO FINDINGS THAT ONE OF ITS FINANCIAL ADVISORS, WHO LEFT THE FIRM ON NOVEMBER 7, 2008, RECOMMENDED CERTAIN
UNSUITABLE TRANSACTIONS AND THAT FINANCIAL ADVISOR WAS NOT REASONABLY SUPERVISED. THE FIRM AGREED TO PAY AN ADMINISTRATIVE FINE
OF $75,000, $30,000 TOWARD THE COST OF THE STATE'S INVESTIGATION AND REFRAIN FROM ANY FUTURE VIOLATIONS.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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)
PENNSYLVANIA SECURITIES COMMISSION

2. Principal Sanction:
Censure
Other Sanctions:
BAR FOR 30 DAYS FROM SELLING LIMITED PARTNERSHIP INTERESTS EXCEPT PUBLICLY TRADED LIMITED PARTNERSHIPS.

3. Date Initiated (MM/DD/YYYY):

12/09/1993 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
9504-01LC

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Direct Investment(s) - DPP & LP Interest(s)
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FAILURE TO SUPERVISE; VIOLATION OF SECTION 305(A)(VII) OF THE PA SECURITIES ACT.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

11/06/1996 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: $ 100,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
PAID COSTS OF $28,550.24. RESPONDENT WAS ORDERED TO ENGAGE AN INDEPENDENT CONSULTANT ACCEPTABLE TO COMMISSION STAFF,
CONDUCT A REVIEW OF EXISTING PROCEDURES, PRACTICES AND POLICIES CONCERNING THE FIRM'S PENNSYLVANIA OFFICES AND THE FIRM'S
SUPERVISION OF ITS PENNSYLVANIA OPERATIONS.
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 FINE OF $100000.00 AND COSTS OF $28550.24 WAS PAID 10/30/1998.
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).
JANNEY MONTGOMERY SCOTT, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, CONSENTED TO THE ISSUANCE OF AND ACCEPTED THE FINDINGS
OF FACT, CONCLUSIONS OF LAW AND ORDER OF THE PENNSYLVANIA SECURITIES COMMISSION IN CONNECTION WITH THE SALE TO PENNSYLVANIA
RESIDENTS OF CERTIN LIMITED PARTNERSHIPS.

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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):

09/08/2020 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2017054220101

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):
IT IS ALLEGED THE FIRM SUBMITTED INACCURATE OR INCOMPLETE REPORTABLE ORDER EVENTS (ROES) TO OATS, FAILED TO REASONABLY SUPERVISE
FOR COMPLIANCE WITH ITS OATS REPORTING REQUIREMENTS, AND FAILED TO REASONABLY RESPOND TO IDENTIFIED OATS REPORTING
DEFICIENCIES. THE FINDINGS STATE THE FIRM TRANSMITTED DESK REPORTS INCLUDING INACCURATE DESK TYPE CODE AND NEW ORDER TYPE EVENTS
THAT FAILED TO REPORT AN INFORMATION BARRIER ID, SUBMITTING DESK REPORTS CODING ITS EQUITY RETAIL DESK AS DESK TYPE CODE OF "T",
INDICATING ITS TRADING DESK RECEIVED THE RELEVANT ORDERS FOR EXECUTION. SINCE ALL ORDERS SENT THROUGH THE FIRM'S AGENCY DESK
WERE ROUTED TO OTHER MARKET DESTINATIONS FOR EXECUTION, THE FIRM SHOULD HAVE USED THE DESK TYPE CODE OF "A" FOR AGENCY WHEN
REPORTING THESE ORDERS TO OATS. THE FIRM'S WRITTEN SUPERVISORY PROCEDURES (WSPS) DID NOT REQUIRE A REVIEW OF THE OATS DATA
SUBMISSIONS TO ASSESS THE ACCURACY OF THE DESK TYPE CODE AND INFORMATION BARRIER IDS. THE FIRM'S REVISED WSPS FAILED TO PROVIDE
REASONABLE GUIDANCE ON HOW THE OATS REVIEW SHOULD OCCUR AND WERE NOT REASONABLY DESIGNED TO ACHIEVE COMPLIANCE WITH ITS
OATS REPORTING OBLIGATIONS.

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):

09/08/2020 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 90,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
UNDERTAKING
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:
HE FIRM WAS CENSURED, FINED $90,000 AND REQUIRED TO REVISE ITS WSPS WITH RESPECT TO OATS COMPLIANCE.

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.,
OR
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

10/21/2020 Exact Explanation
If not exact, provide explanation:
REPRESENTS CONSENT ORDER ENTRY DATE.

4. Docket/Case Number:
CO-20-8388-S

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type:
No Product
Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON OCTOBER 21, 2020, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC ("JANNEY") AGREED TO ENTRY OF AN
ORDER ALLEGING THAT JANNEY PERMITTED A FORMER EMPLOYEE TO ACT AS EXECUTOR OF A CLIENT'S ESTATE IN CONTRAVENTION OF WRITTEN
SUPERVISORY PROCEDURES. THE CONSENT ORDER ALSO ALLEGED THAT JANNEY FAILED TO TIMELY PRODUCE RECORDS REQUESTED BY THE AGENCY
OR AMEND THE FORM U-5 PREVIOUSLY FILED RELATED TO THE FORMER EMPLOYEE.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

10/21/2020 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
THE ORDER DIRECTED THE FIRM TO CEASE AND DESIST FROM ANY RELATED VIOLATIONS. THE ORDER FURTHER ACKNOWLEDGED THAT THE FIRM
HAD REIMBURSED $108,459.68 TO THE ESTATE OF THE AFFECTED CLIENT AND ASSESSED A FINE OF $150,000, $100,000 IN INVESTIGATE COST
REIMBURSEMENT AND $100,000 TO THE STATE INVESTOR EDUCATION FUND. JANNEY ALSO AGREED TO RETAIN AN INDEPENDENT CONSULTANT
TO REVIEW PROCEDURES RELATED TO OUTSIDE BUSINESS ACTIVITIES AND HANDLING OF DECEASED CLIENT ACCOUNTS AND CODUCT TRAINING
RELATED TO REGULATORY PRODUCTIONS.
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:
N/A

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).

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.

You and one or more of your
advisory affiliates
One or more of your
advisory affiliates

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

03/29/2021 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
21-17219

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):
THE STATE PUBLISHED ADMINISTRATIVE ORDER 2020-45 THAT PROVIDES FIRMS LICENSED IN MAINE TEMPORARY RELIEF FROM ON-SITE BRANCH
OFFICE INSPECTIONS DUE TO ONGOING COVID-19 PANDEMIC. THE ORDER REQUIRED FIRMS WITH BRANCH OFFICES IN MAINE TO PROVIDE THE STATE
WITH A LIST OF THE DATE(S) ON WHICH THE FIRM LAST CONDUCTED AN ON-SITE INSPECTION AT EACH BRANCH OFFICE IN MAINE. JANNEY DID NOT
COMPLY WITH THE ADMINISTRATIVE ORDER BY PROVIDING A RESPONSE TO THE STATE; THOUGH JANNEY DID CONDUCT AN ON-SITE INSPECTION OF
ITS SINGLE BRANCH OFFICE IN MAINE IN 2019 AND 2020. THE STATE DEEMS JANNEY IS OUT OF COMPLIANCE DUE TO ITS LACK OF RESPONSE TO THE
ORDER REQUIRED BY NOVEMBER 13, 2020.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

03/29/2021 Exact Explanation
If not exact, provide explanation:

12. Resolution Detail:

A. Were any of the following Sanctions Ordered (check all appropriate items)?

Monetary/Fine Amount: $ 2,500.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
NONE
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 FINED $2,500.

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

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):

10/19/2022 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2016051156903

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:
Other
Other Product Types:
ENERGY-SECTOR SECURITIES

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):
FROM DECEMBER 2013 THROUGH DECEMBER 2016, JANNEY FAILED TO REASONABLY SUPERVISE TWO FORMER REGISTERED REPRESENTATIVES WHO
RECOMMENDED THAT THEIR CUSTOMERS INVEST AN UNSUITABLY HIGH PERCENTAGE OF THEIR ASSETS IN ENERGY-SECTOR SECURITIES IN VIOLATION
OF NASD RULE 3010 AND FINRA RULES 3110 AND 2010.

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):

10/19/2022 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: $ 100,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension
B. Other Sanctions Ordered:
INTEREST ON RESTITUTION
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 $100,000, AND ORDERED TO PAY $145,019, PLUS INTEREST, IN RESTITUTION TO 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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
STATE OF DELAWARE

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

11/02/2022 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
20-0026

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):
IN NOVEMBER 2022, WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, JANNEY MONTGOMERY SCOTT LLC VOLUNTARILY ENTERED INTO A CONSENT
ORDER WITH THE STATE OF DELAWARE RELATED TO FAILURE TO SUPERVISE THE SUITABILITY OF CERTAIN ACTIVITIES BY A FINANCIAL ADVISOR.

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
Consent

11. Resolution Date (MM/DD/YYYY):

11/02/2022 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: $ 72,255.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:
IN THE ORDER THE FIRM AGREED TO A FINE OF $40,000, CLIENT REMEDIATION OF $32,255 AND TO PLACE THE FINANCIAL ADVISOR ON FIRM
HEIGHTENED SUPERVISION FOR THE PERIOD OF ONE YEAR.
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:
SEE SANCTIONS ABOVE

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).

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.

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

ADV DRP - ADVISORY AFFILIATE

No Information Filed

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:

Yes No

NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.

PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
FINRA

2. Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

07/23/2024 Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:
2022074617402

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):
FINRA ALLEGED THAT JANNEY DID NOT ACCURATELY REPORT CERTAIN TRANSACTIONS TO THE MUNICIPAL SECURITIES RULEMAKING BOARD ("MSRB")
FROM JULY 2019 TO MAY 2021; AND TRADE REPORTING AND COMPLIANCE ENGINE ("TRACE") FROM MARCH 2022 TO MARCH 2023. FINRA ALSO
ALLEGED THAT JANNEY DID NOT HAVE PROPER SUPERVISORY SYSTEMS AND WRITTEN SUPERVISORY PROCEDURES REGARDING SUCH TRADE
REPORTING.

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):

07/23/2024 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: $ 150,000.00
Revocation/Expulsion/Denial Disgorgement/Restitution
Censure Cease and Desist/Injunction
Bar Suspension

B. Other Sanctions Ordered:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON JULY 23, 2024, JANNEY ENTERED INTO AN AWC WITH FINRA, WITHOUT ADMITTING OR DENYING ANY FINDINGS, THE FIRM AGREED TO A $150,000
SETTLEMENT WITH RESPECT TO THE ALLEGATIONS AND UPDATED APPLICABLE WRITTEN SUPERVISORY PROCEDURES.

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.

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

ADV DRP - ADVISORY AFFILIATE

CRD 8326
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: GLOBAL ATLANTIC
DISTRIBUTORS, LLC
(For individuals, Last, First,
Middle)

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:

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)

2. Principal Sanction:

Other Sanctions:

3. Date Initiated (MM/DD/YYYY):

Exact Explanation
If not exact, provide explanation:

4. Docket/Case Number:

5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):

6. Principal Product Type:

Other Product Types:

7. Describe the allegations related to this regulatory action (your response must fit within the space provided):

8. Current Status? Pending On Appeal Final

9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:

If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.

10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):

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:

13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).

CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)

No Information Filed

Part 2
Exemption from brochure delivery requirements for SEC-registered advisers

SEC rules exempt SEC-registered advisers from delivering a firm brochure to some kinds of clients. If these exemptions excuse you from delivering a
brochure to all of your advisory clients, you do not have to prepare a brochure.
Yes No
Are you exempt from delivering a brochure to all of your clients under these rules?

If no, complete the ADV Part 2 filing below.

Amend, retire or file new brochures:

Brochure ID Brochure Name Brochure Type(s)
145697 JANNEY MONTGOMERY SCOTT Wrap program, Financial Planning Services, Selection
INVESTMENT MANAGEMENT of Other Advisers/Solicitors, Individuals, High net
DISCLOSURE BROCHURE worth individuals, Pension plans/profit sharing plans,
Foundations/charities, Other institutional
145698 JANNEY MONTGOMERY SCOTT WRAP High net worth individuals, Pension plans/profit
FEE DISCLOSURE BROCHURE sharing plans, Foundations/charities, Other
institutional, Wrap program, Financial Planning
Services, Selection of Other Advisers/Solicitors,
Individuals

Part 3

CRS Type(s) Affiliate Info Retire

Dual
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
ERIN E. ANTILL 06/30/2026
Printed Name: Title:
ERIN E. ANTILL INVESTMENT ADVISORY COMPLIANCE ANALYST
Adviser CRD Number:
463

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.

Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
463