← Great Lakes Retirement Planning, Llc
Form ADV (full filing)
as of Jul 10, 2026
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FORM ADV
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION AND REPORT BY EXEMPT REPORTING ADVISERS
Primary Business Name: GREAT LAKES RETIREMENT PLANNING, LLC CRD Number: 290434
Annual Amendment - All Sections Rev. 10/2021
7/10/2026 3:23:03 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):
CLE RETIREMENT PLANNING LLC
B. (1) Name under which you primarily conduct your advisory business, if different from Item 1.A.
GREAT LAKES RETIREMENT PLANNING 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:
GREAT LAKES RETIREMENT PLANNING, LLC
D. (1) If you are registered with the SEC as an investment adviser, your SEC file number:
(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:
No Information Filed
E. (1) If you have a number ("CRD Number") assigned by the FINRA's CRD system or by the IARD system, your CRD number: 290434
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:
1300 EAST 9TH STREET SUITE 750
City: State: Country: ZIP+4/Postal Code:
CLEVELAND Ohio United States 44114
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:
9:00 AM - 5:00 PM
(3) Telephone number at this location:
216-230-4643
(4) Facsimile number at this location, if any:
(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?
0
G. Mailing address, if different from your principal office and place of business address:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
If this address is a private residence, check this box:
H. If you are a sole proprietor, state your full residence address, if different from your principal office and place of business address in Item 1.F.:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Yes No
I. Do you have one or more websites or accounts on publicly available social media platforms (including, but not limited to, Twitter, Facebook and
LinkedIn)?
If "yes," list all firm website addresses and the address for each of the firm's accounts on publicly available social media platforms on Section 1.I. of Schedule D. If a
website address serves as a portal through which to access other information you have published on the web, you may list the portal without listing addresses for all
of the other information. You may need to list more than one portal address. Do not provide the addresses of websites or accounts on publicly available social media
platforms where you do not control the content. Do not provide the individual electronic mail (e-mail) addresses of employees or the addresses of employee accounts
on publicly available social media platforms.
J. Chief Compliance Officer
(1) Provide the name and contact information of your Chief Compliance Officer. If you are an exempt reporting adviser, you must provide the contact information
for your Chief Compliance Officer, if you have one. If not, you must complete Item 1.K. below.
Name: Other titles, if any:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if Chief Compliance Officer has one:
(2) If your Chief Compliance Officer is compensated or employed by any person other than you, a related person or an investment company registered under the
Investment Company Act of 1940 that you advise for providing chief compliance officer services to you, provide the person's name and IRS Employer
Identification Number (if any):
Name:
IRS Employer Identification Number:
K. Additional Regulatory Contact Person: If a person other than the Chief Compliance Officer is authorized to receive information and respond to questions about
this Form ADV, you may provide that information here.
Name: Titles:
Telephone number: Facsimile number, if any:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Electronic mail (e-mail) address, if contact person has one:
Yes No
L. Do you maintain some or all of the books and records you are required to keep under Section 204 of the Advisers Act, or similar state law, somewhere
other than your principal office and place of business?
If "yes," complete Section 1.L. of Schedule D.
Yes No
M. Are you registered with a foreign financial regulatory authority?
Answer "no" if you are not registered with a foreign financial regulatory authority, even if you have an affiliate that is registered with a foreign financial regulatory
authority. If "yes," complete Section 1.M. of Schedule D.
Yes No
N. Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934?
Yes No
O. Did you have $1 billion or more in assets on the last day of your most recent fiscal year?
If yes, what is the approximate amount of your assets:
$1 billion to less than $10 billion
$10 billion to less than $50 billion
$50 billion or more
For purposes of Item 1.O. only, "assets" refers to your total assets, rather than the assets you manage on behalf of clients. Determine your total assets using the
total assets shown on the balance sheet for your most recent fiscal year end.
P. Provide your Legal Entity Identifier if you have one:
A legal entity identifier is a unique number that companies use to identify each other in the financial marketplace. You may not have a legal entity identifier.
SECTION 1.B. Other Business Names
No Information Filed
SECTION 1.F. Other Offices
No Information Filed
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.linkedin.com/company/cle-retirement-planning/about/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.GREATLAKES-RETIREMENT.COM
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://WWW.FACEBOOK.COM/GREATLAKES-RETIREMENT-PLANNING-406433579717543/
Address of Website/Account on Publicly Available Social Media Platform: HTTPS://TWITTER.COM/GLRETIREMENT
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:
THE CAPITAL CLIENT GROUP, INC.
Number and Street 1: Number and Street 2:
333 S. HOPE STREET 55TH FLOOR
City: State: Country: ZIP+4/Postal Code:
LOS ANGELES California United States 90071
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
800-421-4225
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.
CCG IS OUR CUSTODIAN FOR MUTUAL FUND BASED ACCOUNTS AS WELL AS MOST RETIREMENT IRA ACCOUNTS. CCG DISTRIBUTES AND RETAINS STATEMENTS,
TRANSACTION CONFIRMATIONS AND TAX DOCUMENTS TO CLIENTS.
Name of entity where books and records are kept:
INTERACTIVE BROKERS, LLC
Number and Street 1: Number and Street 2:
PICKWICK PLAZA
City: State: Country: ZIP+4/Postal Code:
GREENWICH Connecticut United States 06830
If this address is a private residence, check this box:
Telephone Number: Facsimile number, if any:
877-442-2757
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.
INTERACTIVE BROKERS, LLC IS OUR CUSTODIAN FOR OUR SEPERERAIELY MANAGED ACCOUNTS HOLDING INDIVIDUAL SECURITIES. THEY DISTRIBUTE AND HOUSE
STATEMENTS, TRANSACTION CONFIRMATIONS AND TAX DOCUMENTS TO CLIENTS.
SECTION 1.M. Registration with Foreign Financial Regulatory Authorities
No Information Filed
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
Ohio 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.
2
B. (1) Approximately how many of the employees reported in 5.A. perform investment advisory functions (including research)?
2
(2) Approximately how many of the employees reported in 5.A. are registered representatives of a broker-dealer?
0
(3) Approximately how many of the employees reported in 5.A. are registered with one or more state securities authorities as investment adviser
representatives?
2
(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?
1
(5) Approximately how many of the employees reported in 5.A. are licensed agents of an insurance company or agency?
1
(6) Approximately how many firms or other persons solicit advisory clients on your behalf?
0
In your response to Item 5.B.(6), do not count any of your employees and count a firm only once – do not count each of the firm's employees that solicit on your
behalf.
Clients
In your responses to Items 5.C. and 5.D. do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those
investors.
C. (1) To approximately how many clients for whom you do not have regulatory assets under management did you provide investment advisory services during
your most recently completed fiscal year?
66
(2) Approximately what percentage of your clients are non-United States persons?
0%
D. For purposes of this Item 5.D., the category "individuals" includes trusts, estates, and 401(k) plans and IRAs of individuals and their family members, but does not
include businesses organized as sole proprietorships.
The category "business development companies" consists of companies that have made an election pursuant to section 54 of the Investment Company Act of 1940.
Unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the Investment Company Act of 1940,
do not answer (1)(d) or (3)(d) below.
Indicate the approximate number of your clients and amount of your total regulatory assets under management (reported in Item 5.F. below) attributable to
each of the following type of client. If you have fewer than 5 clients in a particular category (other than (d), (e), and (f)) you may check Item 5.D.(2) rather than
respond to Item 5.D.(1).
The aggregate amount of regulatory assets under management reported in Item 5.D.(3) should equal the total amount of regulatory assets under
management reported in Item 5.F.(2)(c) below.
If a client fits into more than one category, select one category that most accurately represents the client to avoid double counting clients and assets. If you
advise a registered investment company, business development company, or pooled investment vehicle, report those assets in categories (d), (e), and (f) as
applicable.
(1) Number of (2) Fewer than 5 (3) Amount of Regulatory Assets
Type of Client Client(s) Clients under Management
(a) Individuals (other than high net worth individuals) 66 $ 5,289,000
(b) High net worth individuals 0 $
(c) Banking or thrift institutions 0 $
(d) Investment companies 0 $
(e) Business development companies 0 $
(f) Pooled investment vehicles (other than investment companies and 0 $
business development companies)
(g) Pension and profit sharing plans (but not the plan participants or 0 $
government pension plans)
(h) Charitable organizations 0 $
(i) State or municipal government entities (including government pension 0 $
plans)
(j) Other investment advisers 0 $
(k) Insurance companies 0 $
(l) Sovereign wealth funds and foreign official institutions 0 $
(m) Corporations or other businesses not listed above 0 $
(n) Other: 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):
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) $ 5,289,000 (d) 66
Non-Discretionary: (b) $0 (e) 0
Total: (c) $ 5,289,000 (f) 66
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?
$0
Item 5 Information About Your Advisory Business - Advisory Activities
Advisory Activities
G. What type(s) of advisory services do you provide? Check all that apply.
(1) Financial planning services
(2) Portfolio management for individuals and/or small businesses
(3) Portfolio management for investment companies (as well as "business development companies" that have made an election pursuant to section 54
of the Investment Company Act of 1940)
(4) Portfolio management for pooled investment vehicles (other than investment companies)
(5) Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other
pooled investment vehicles)
(6) Pension consulting services
(7) Selection of other advisers (including private fund managers)
(8) Publication of periodicals or newsletters
(9) Security ratings or pricing services
(10) Market timing services
(11) Educational seminars/workshops
(12) Other(specify):
Do not check Item 5.G.(3) unless you provide advisory services pursuant to an investment advisory contract to an investment company registered under the
Investment Company Act of 1940, including as a subadviser. If you check Item 5.G.(3), report the 811 or 814 number of the investment company or investment
companies to which you provide advice in Section 5.G.(3) of Schedule D.
H. If you provide financial planning services, to how many clients did you provide these services during your last fiscal year?
0
1 - 10
11 - 25
26 - 50
51 - 100
101 - 250
251 - 500
More than 500
If more than 500, how many?
(round to the nearest 500)
In your responses to this Item 5.H., do not include as "clients" the investors in a private fund you advise, unless you have a separate advisory relationship with those
investors.
Yes No
I. (1) Do you participate in a wrap fee program?
(2) If you participate in a wrap fee program, what is the amount of your regulatory assets under management attributable to acting as:
(a) sponsor to a wrap fee program
$
(b) portfolio manager for a wrap fee program?
$
(c) sponsor to and portfolio manager for the same wrap fee program?
$
If you report an amount in Item 5.I.(2)(c), do not report that amount in Item 5.I.(2)(a) or Item 5.I.(2)(b).
If you are a portfolio manager for a wrap fee program, list the names of the programs, their sponsors and related information in Section 5.I.(2) of Schedule D.
If your involvement in a wrap fee program is limited to recommending wrap fee programs to your clients, or you advise a mutual fund that is offered through a wrap
fee program, do not check Item 5.I.(1) or enter any amounts in response to Item 5.I.(2).
Yes No
J. (1) In response to Item 4.B. of Part 2A of Form ADV, do you indicate that you provide investment advice only with respect to limited types of
investments?
(2) Do you report client assets in Item 4.E. of Part 2A that are computed using a different method than the method used to compute your regulatory
assets under management?
K. Separately Managed Account Clients
Yes No
(1) Do you have regulatory assets under management attributable to clients other than those listed in Item 5.D.(3)(d)-(f) (separately managed
account clients)?
If yes, complete Section 5.K.(1) of Schedule D.
(2) Do you engage in borrowing transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(3) Do you engage in derivative transactions on behalf of any of the separately managed account clients that you advise?
If yes, complete Section 5.K.(2) of Schedule D.
(4) After subtracting the amounts in Item 5.D.(3)(d)-(f) above from your total regulatory assets under management, does any custodian hold ten
percent or more of this remaining amount of regulatory assets under management?
If yes, complete Section 5.K.(3) of Schedule D for each custodian.
L. Marketing Activities
Yes No
(1) Do any of your advertisements include:
(a) Performance results?
(b) A reference to specific investment advice provided by you (as that phrase is used in rule 206(4)-1(a)(5))?
(c) Testimonials (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(d) Endorsements (other than those that satisfy rule 206(4)-1(b)(4)(ii))?
(e) Third-party ratings?
(2) If you answer "yes" to L(1)(c), (d), or (e) above, do you pay or otherwise provide cash or non-cash compensation, directly or indirectly, in
connection with the use of testimonials, endorsements, or third-party ratings?
(3) Do any of your advertisements include hypothetical performance ?
(4) Do any of your advertisements include predecessor performance ?
SECTION 5.G.(3) Advisers to Registered Investment Companies and Business Development Companies
No Information Filed
SECTION 5.I.(2) Wrap Fee Programs
No Information Filed
SECTION 5.K.(1) Separately Managed Accounts
After subtracting the amounts reported in Item 5.D.(3)(d)-(f) from your total regulatory assets under management, indicate the approximate percentage of this
remaining amount attributable to each of the following categories of assets. If the remaining amount is at least $10 billion in regulatory assets under management,
complete Question (a). If the remaining amount is less than $10 billion in regulatory assets under management, complete Question (b).
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
If you are a subadviser to a separately managed account, you should only provide information with respect to the portion of the account that you subadvise.
End of year refers to the date used to calculate your regulatory assets under management for purposes of your annual updating amendment . Mid-year is the date
six months before the end of year date. Each column should add up to 100% and numbers should be rounded to the nearest percent.
Investments in derivatives, registered investment companies, business development companies, and pooled investment vehicles should be reported in those
categories. Do not report those investments based on related or underlying portfolio assets. Cash equivalents include bank deposits, certificates of deposit,
bankers' acceptances and similar bank instruments.
Some assets could be classified into more than one category or require discretion about which category applies. You may use your own internal methodologies and
the conventions of your service providers in determining how to categorize assets, so long as the methodologies or conventions are consistently applied and
consistent with information you report internally and to current and prospective clients. However, you should not double count assets, and your responses must be
consistent with any instructions or other guidance relating to this Section.
(a) Asset Type Mid-year End of year
(i) Exchange-Traded Equity Securities % %
(ii) Non Exchange-Traded Equity Securities % %
(iii) U.S. Government/Agency Bonds % %
(iv) U.S. State and Local Bonds % %
(v) Sovereign Bonds % %
(vi) Investment Grade Corporate Bonds % %
(vii) Non-Investment Grade Corporate Bonds % %
(viii) Derivatives % %
(ix) Securities Issued by Registered Investment Companies or Business Development Companies % %
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development % %
Companies)
(xi) Cash and Cash Equivalents % %
(xii) Other % %
Generally describe any assets included in "Other"
(b) Asset Type End of year
(i) Exchange-Traded Equity Securities 77 %
(ii) Non Exchange-Traded Equity Securities 0%
(iii) U.S. Government/Agency Bonds 10 %
(iv) U.S. State and Local Bonds 10 %
(v) Sovereign Bonds 0%
(vi) Investment Grade Corporate Bonds 3%
(vii) Non-Investment Grade Corporate Bonds 0%
(viii) Derivatives 0%
(ix) Securities Issued by Registered Investment Companies or Business Development Companies 0%
(x) Securities Issued by Pooled Investment Vehicles (other than Registered Investment Companies or Business Development Companies) 0%
(xi) Cash and Cash Equivalents 0%
(xii) Other 0%
Generally describe any assets included in "Other"
SECTION 5.K.(2) Separately Managed Accounts - Use of Borrowingsand Derivatives
No information is required to be reported in this Section 5.K.(2) per the instructions of this Section 5.K.(2)
If your regulatory assets under management attributable to separately managed accounts are at least $10 billion, you should complete Question (a). If your
regulatory assets under management attributable to separately managed accounts are at least $500 million but less than $10 billion, you should complete
Question (b).
(a) In the table below, provide the following information regarding the separately managed accounts you advise. If you are a subadviser to a separately managed
account, you should only provide information with respect to the portion of the account that you subadvise. End of year refers to the date used to calculate
your regulatory assets under management for purposes of your annual updating amendment. Mid-year is the date six months before the end of year date.
In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional
exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of
any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.
In column 2, provide the dollar amount of borrowings for the accounts included in column 1.
In column 3, provide aggregate gross notional value of derivatives divided by the aggregate regulatory assets under management of the accounts included in
column 1 with respect to each category of derivatives specified in 3(a) through (f).
You may, but are not required to, complete the table with respect to any separately managed account with regulatory assets under management of less than
$10,000,000.
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
(i) Mid-Year
Gross Notional (1) Regulatory Assets (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ $ % % % % % %
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(ii) End of Year
Gross Notional (1) Regulatory Assets (2)
Exposure Under Management Borrowings (3) Derivative Exposures
(b) Foreign
(a) Interest Exchange (c) Credit (d) Equity (e) Commodity (f) Other
Rate Derivative Derivative Derivative Derivative Derivative Derivative
Less than 10% $ $ % % % % % %
10-149% $ $ % % % % % %
150% or more $ $ % % % % % %
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
(b) In the table below, provide the following information regarding the separately managed accounts you advise as of the date used to calculate your regulatory
assets under management for purposes of your annual updating amendment. If you are a subadviser to a separately managed account, you should only provide
information with respect to the portion of the account that you subadvise.
In column 1, indicate the regulatory assets under management attributable to separately managed accounts associated with each level of gross notional
exposure. For purposes of this table, the gross notional exposure of an account is the percentage obtained by dividing (i) the sum of (a) the dollar amount of
any borrowings and (b) the gross notional value of all derivatives, by (ii) the regulatory assets under management of the account.
In column 2, provide the dollar amount of borrowings for the accounts included in column 1.
You may, but are not required to, complete the table with respect to any separately managed accounts with regulatory assets under management of less than
$10,000,000.
Any regulatory assets under management reported in Item 5.D.(3)(d), (e), and (f) should not be reported below.
Gross Notional Exposure (1) Regulatory Assets Under Management (2) Borrowings
Less than 10% $ $
10-149% $ $
150% or more $ $
Optional: Use the space below to provide a narrative description of the strategies and/or manner in which borrowings and derivatives are used in the
management of the separately managed accounts that you advise.
SECTION 5.K.(3) Custodians for Separately Managed Accounts
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.
FIXED ANNUITIES; FIXED INDEXED ANNUITIES; TERM & WHOLE LIFE; AD&D INSURANCE; LONG TERM CARE; MEDICARE SUPPLEMENT; AND P&C INSURANCE POLICIES
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
No Information Filed
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) $ (b)
If you are registering or registered with the SEC and you have custody solely because you deduct your advisory fees directly from your clients' accounts, do not include
the amount of those assets and the number of those clients in your response to Item 9.A.(2). If your related person has custody of client assets in connection with
advisory services you provide to clients, do not include the amount of those assets and number of those clients in your response to 9.A.(2). Instead, include that
information in your response to Item 9.B.(2).
B. (1) In connection with advisory services you provide to clients, do any of your related persons have custody of any of your advisory clients': Yes No
(a) cash or bank accounts?
(b) securities?
You are required to answer this item regardless of how you answered Item 9.A.(1)(a) or (b).
(2) If you checked "yes" to Item 9.B.(1)(a) or (b), what is the approximate amount of client funds and securities and total number of clients for which your
related persons have custody:
U.S. Dollar Amount Total Number of Clients
(a) $ (b)
C. If you or your related persons have custody of client funds or securities in connection with advisory services you provide to clients, check all the following that
apply:
(1) A qualified custodian(s) sends account statements at least quarterly to the investors in the pooled investment vehicle(s) you manage.
(2) An independent public accountant audits annually the pooled investment vehicle(s) that you manage and the audited financial statements are
distributed to the investors in the pools.
(3) An independent public accountant conducts an annual surprise examination of client funds and securities.
(4) An independent public accountant prepares an internal control report with respect to custodial services when you or your related persons are
qualified custodians for client funds and securities.
If you checked Item 9.C.(2), C.(3) or C.(4), list in Section 9.C. of Schedule D the accountants that are engaged to perform the audit or examination or prepare an
internal control report. (If you checked Item 9.C.(2), you do not have to list auditor information in Section 9.C. of Schedule D if you already provided this information
with respect to the private funds you advise in Section 7.B.(1) of Schedule D).
D. Do you or your related person(s) act as qualified custodians for your clients in connection with advisory services you provide to clients? Yes No
(1) you act as a qualified custodian
(2) your related person(s) act as qualified custodian(s)
If you checked "yes" to Item 9.D.(2), all related persons that act as qualified custodians (other than any mutual fund transfer agent pursuant to rule 206(4)-2(b)(1))
must be identified in Section 7.A. of Schedule D, regardless of whether you have determined the related person to be operationally independent under rule 206(4)-2 of
the Advisers Act.
E. If you are filing your annual updating amendment and you were subject to a surprise examination by an independent public accountant during your last fiscal
year, provide the date (MM/YYYY) the examination commenced:
F. If you or your related persons have custody of client funds or securities, how many persons, including, but not limited to, you and your related persons, act as
qualified custodians for your clients in connection with advisory services you provide to clients?
SECTION 9.C. Independent Public Accountant
No Information Filed
Item 10 Control Persons
In this Item, we ask you to identify every person that, directly or indirectly, controls you. If you are filing an umbrella registration, the information in Item 10 should be
provided for the filing adviser only.
If you are submitting an initial application or report, you must complete Schedule A and Schedule B. Schedule A asks for information about your direct owners and
executive officers. Schedule B asks for information about your indirect owners. If this is an amendment and you are updating information you reported on either
Schedule A or Schedule B (or both) that you filed with your initial application or report, you must complete Schedule C.
Yes No
A. Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies?
If yes, complete Section 10.A. of Schedule D.
B. If any person named in Schedules A, B, or C or in Section 10.A. of Schedule D is a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934, please complete Section 10.B. of Schedule D.
SECTION 10.A. Control Persons
No Information Filed
SECTION 10.B. Control Person Public Reporting Companies
No Information Filed
Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary history and the disciplinary history of all your advisory affiliates. We use this information to determine
whether to grant your application for registration, to decide whether to revoke your registration or to place limitations on your activities as an investment adviser,
and to identify potential problem areas to focus on during our on-site examinations. One event may result in "yes" answers to more than one of the questions
below. In accordance with General Instruction 5 to Form ADV, "you" and "your" include the filing adviser and all relying advisers under an umbrella registration.
Your advisory affiliates are: (1) all of your current employees (other than employees performing only clerical, administrative, support or similar functions); (2) all of your
officers, partners, or directors (or any person performing similar functions); and (3) all persons directly or indirectly controlling you or controlled by you. If you are a
"separately identifiable department or division" (SID) of a bank, see the Glossary of Terms to determine who your advisory affiliates are.
If you are registered or registering with the SEC or if you are an exempt reporting adviser, you may limit your disclosure of any event listed in Item 11 to ten years following
the date of the event. If you are registered or registering with a state, you must respond to the questions as posed; you may, therefore, limit your disclosure to ten years
following the date of an event only in responding to Items 11.A.(1), 11.A.(2), 11.B.(1), 11.B.(2), 11.D.(4), and 11.H.(1)(a). For purposes of calculating this ten-year period,
the date of an event is the date the final order, judgment, or decree was entered, or the date any rights of appeal from preliminary orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page ("DRP") for "yes" answers to the questions in this Item 11.
Yes No
Do any of the events below involve you or any of your supervised persons?
For "yes" answers to the following questions, complete a Criminal Action DRP:
A. In the past ten years, have you or any advisory affiliate: Yes No
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?
(2) been charged with any felony?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.A.(2) to charges that
are currently pending.
B. In the past ten years, have you or any advisory affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments
or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery,
counterfeiting, extortion, or a conspiracy to commit any of these offenses?
(2) been charged with a misdemeanor listed in Item 11.B.(1)?
If you are registered or registering with the SEC, or if you are reporting as an exempt reporting adviser, you may limit your response to Item 11.B.(2) to charges that
are currently pending.
For "yes" answers to the following questions, complete a Regulatory Action DRP:
C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: Yes No
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?
(3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) entered an order against you or any advisory affiliate in connection with investment-related activity?
(5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority:
(1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?
(2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?
(3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?
(5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by
order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?
E. Has any self-regulatory organization or commodities exchange ever:
(1) found you or any advisory affiliate to have made a false statement or omission?
(2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation"
under a plan approved by the SEC)?
(3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied,
suspended, revoked, or restricted?
(4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the
advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?
F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?
G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or
11.E.?
For "yes" answers to the following questions, complete a Civil Judicial Action DRP:
H. (1) Has any domestic or foreign court: Yes No
(a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?
(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?
(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state
or foreign financial regulatory authority?
(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H.(1)?
Item 12 Small Businesses
The SEC is required by the Regulatory Flexibility Act to consider the effect of its regulations on small entities. In order to do this, we need to determine whether you
meet the definition of "small business" or "small organization" under rule 0-7.
Answer this Item 12 only if you are registered or registering with the SEC and you indicated in response to Item 5.F.(2)(c) that you have regulatory assets under
management of less than $25 million. You are not required to answer this Item 12 if you are filing for initial registration as a state adviser, amending a current state
registration, or switching from SEC to state registration.
For purposes of this Item 12 only:
Total Assets refers to the total assets of a firm, rather than the assets managed on behalf of clients. In determining your or another person's total assets, you
may use the total assets shown on a current balance sheet (but use total assets reported on a consolidated balance sheet with subsidiaries included, if that
amount is larger).
Control means the power to direct or cause the direction of the management or policies of a person, whether through ownership of securities, by contract, or
otherwise. Any person that directly or indirectly has the right to vote 25 percent or more of the voting securities, or is entitled to 25 percent or more of the
profits, of another person is presumed to control the other person.
Yes No
A. Did you have total assets of $5 million or more on the last day of your most recent fiscal year?
If "yes," you do not need to answer Items 12.B. and 12.C.
B. Do you:
(1) control another investment adviser that had regulatory assets under management (calculated in response to Item 5.F.(2)(c) of Form ADV) of $25
million or more on the last day of its most recent fiscal year?
(2) control another person (other than a natural person) that had total assets of $5 million or more on the last day of its most recent fiscal year?
C. Are you:
(1) controlled by or under common control with another investment adviser that had regulatory assets under management (calculated in response to
Item 5.F.(2)(c) of Form ADV) of $25 million or more on the last day of its most recent fiscal year?
(2) controlled by or under common control with another person (other than a natural person) that had total assets of $5 million or more on the last day
of its most recent fiscal year?
Schedule A
Direct Owners and Executive Officers
1. Complete Schedule A only if you are submitting an initial application or report. Schedule A asks for information about your direct owners and executive officers.
Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below the names of:
(a) each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance Officer(Chief Compliance Officer is required if
you are registered or applying for registration and cannot be more than one individual), director, and any other individuals with similar status or functions;
(b) if you are organized as a corporation, each shareholder that is a direct owner of 5% or more of a class of your voting securities, unless you are a public
reporting company (a company subject to Section 12 or 15(d) of the Exchange Act);
Direct owners include any person that owns, beneficially owns, has the right to vote, or has the power to sell or direct the sale of, 5% or more of a class of
your voting securities. For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent,
stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same
residence; or (ii) that he/she has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(c) if you are organized as a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or have
contributed, 5% or more of your capital;
(d) in the case of a trust that directly owns 5% or more of a class of your voting securities, or that has the right to receive upon dissolution, or has contributed,
5% or more of your capital, the trust and each trustee; and
(e) if you are organized as a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed, 5% or more
of your capital, and (ii) if managed by elected managers, all elected managers.
3. Do you have any indirect owners to be reported on Schedule B? Yes No
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner or executive officer is an individual.
5. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole proprietor, elected manager, shareholder, or member;
and for shareholders or members, the class of securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5% B - 10% but less than 25% D - 50% but less than 75%
A - 5% but less than 10% C - 25% but less than 50% E - 75% or more
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not have
control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
FULL LEGAL NAME (Individuals: Last Name, DE/FE/I Title or Date Title or Status Ownership Control PR CRD No. If None: S.S. No. and Date of Birth,
First Name, Middle Name) Status Acquired MM/YYYY Code Person IRS Tax No. or Employer ID No.
SHABAZZ, SEKU, N I OWNER 10/2017 E Y N 5988727
WILDE, DOUGLAS, MEYER I CIO 06/2026 NA Y N 2089465
Schedule B
Indirect Owners
1. Complete Schedule B only if you are submitting an initial application or report. Schedule B asks for information about your indirect owners; you must first
complete Schedule A, which asks for information about your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation, each of its shareholders that beneficially owns, has the right to vote, or has the power to sell or direct the sale
of, 25% or more of a class of a voting security of that corporation;
For purposes of this Schedule, a person beneficially owns any securities: (i) owned by his/her child, stepchild, grandchild, parent, stepparent, grandparent,
spouse, sibling, mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same residence; or (ii) that he/she
has the right to acquire, within 60 days, through the exercise of any option, warrant, or right to purchase the security.
(b) in the case of an owner that is a partnership, all general partners and those limited and special partners that have the right to receive upon dissolution, or
have contributed, 25% or more of the partnership's capital;
(c) in the case of an owner that is a trust, the trust and each trustee; and
(d) in the case of an owner that is a limited liability company ("LLC"), (i) those members that have the right to receive upon dissolution, or have contributed,
25% or more of the LLC's capital, and (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25% owners at each level. Once a public reporting company (a company subject to Sections 12 or 15(d) of the
Exchange Act) is reached, no further ownership information need be given.
4. In the DE/FE/I column below, enter "DE" if the owner is a domestic entity, "FE" if the owner is an entity incorporated or domiciled in a foreign country, or "I" if the
owner is an individual.
5. Complete the Status column by entering the owner's status as partner, trustee, elected manager, shareholder, or member; and for shareholders or members,
the class of securities owned (if more than one is issued).
6. Ownership codes are: C - 25% but less than 50% E - 75% or more
D - 50% but less than 75% F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter "Yes" if the person has control as defined in the Glossary of Terms to Form ADV, and enter "No" if the person does not
have control. Note that under this definition, most executive officers and all 25% owners, general partners, elected managers, and trustees are control
persons.
(b) In the PR column, enter "PR" if the owner is a public reporting company under Sections 12 or 15(d) of the Exchange Act.
(c) Complete each column.
No Information Filed
Schedule D - Miscellaneous
You may use the space below to explain a response to an Item or to provide any other information.
Schedule R
No Information Filed
DRP Pages
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
No Information Filed
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an INITIAL AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E.,
OR
11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5)
11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5)
11.E(1) 11.E(2) 11.E(3) 11.E(4)
11.F. 11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event.
If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your
advisory affiliates
One or more of your
advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD 290434
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: GREAT LAKES RETIREMENT
PLANNING LLC
(For individuals, Last, First,
Middle)
CRD 5988727
This advisory affiliate is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, N
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered
or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and
only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11
that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances:
B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD
or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC Other Federal State Foreign
SRO
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
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:
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:
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
Arbitration DRPs
No Information Filed
Bond DRPs
No Information Filed
Judgment/Lien DRPs
This Disclosure Reporting Page (DRP ADV) is an response used to report details for affirmative responses to Item 2.D. of Part 1B of
INITIAL OR AMENDED
Form ADV.
Judgment/Lien
Check Part 1B item(s) being responded to:
2D
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 or
advisory affiliates management persons
One or more of your or
advisory affiliates management persons
If this DRP is being filed for an advisory affiliate or a management person, give the full name of the advisory affiliate or management person below (for
individuals, Last name, First name, Middle name).
If the advisory affiliate or management person has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate checkbox.
ADV DRP - ADVISORY AFFILIATE or MANAGEMENT PERSON
CRD 5988727
This advisory affiliate or management person is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, N
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) or management person(s) is no longer associated with the adviser.
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:
NOTE: The completion of this form does not relieve the advisory affiliate or management person of its obligation to update its IARD or CRD records.
PART II
1. Judgment/Lien Amount:
$ 97,125.00
2. Judgment/Lien Holder:
JOYHN GEOFFREY
3. Judgment/Lien Type:
Civil
4. Date Filed (MM/DD/YYYY):
07/12/2025 Exact Explanation
If not exact, provide explanation:
5. Is Judgment/Lien outstanding?
Yes No
If No, provide status date (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
If No, how was matter resolved?
6. Court (Name of Federal, State or Foreign Court), Location of Court (City or County and State or Country) and Docket/Case Number:
STATE OF OHIO, CUYAHOGA COUNTY COURT OF COMMON PLEAS, CV 25-120723
7. Provide a brief summary of events leading to the action and any payment schedule details including current status (if applicable) (your response must fit
within the space provided):
ON JULY 12, 2025, PLAINTIFFS JOHN GEOFFREY BRADNER, JR., AND HOLLY ROVELLI-BRADNER FILED A COMPLAINT A BREACH OF CONTRACT ACTION WAS FILED
AGAINST GREAT LAKES RENTAL MORTGAGE, LLC, GREAT LAKES LOAN SERVICING, LLC, GREAT LAKES INVESTMENT PARTNERS FUND B, LLC AND SEKU SHABAZZ
IN THE CUYAHOGA COUNTY COMMON PLEAS COURT, STATE OF OHIO. ON FEBRUARY 19TH, 2026, A JUDGMENT WAS RENDERED BY THE COURT IN FAVOR OF
PLAINTIFFS AGAINST GREAT LAKES LOAN SERVICING, LLC AND SEKU SHABAZZ FOR THE SUM OF $97,425.00 AND INTEREST AT 0% AND $0 COSTS OF SUIT. THE
JUDGMENT LIEN REMAINS PENDING.
This Disclosure Reporting Page (DRP ADV) is an response used to report details for affirmative responses to Item 2.D. of Part 1B of
INITIAL OR AMENDED
Form ADV.
Judgment/Lien
Check Part 1B item(s) being responded to:
2D
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 or
advisory affiliates management persons
One or more of your or
advisory affiliates management persons
If this DRP is being filed for an advisory affiliate or a management person, give the full name of the advisory affiliate or management person below (for
individuals, Last name, First name, Middle name).
If the advisory affiliate or management person has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate checkbox.
ADV DRP - ADVISORY AFFILIATE or MANAGEMENT PERSON
CRD 5988727
This advisory affiliate or management person is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, N
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) or management person(s) is no longer associated with the adviser.
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:
NOTE: The completion of this form does not relieve the advisory affiliate or management person of its obligation to update its IARD or CRD records.
PART II
1. Judgment/Lien Amount:
$ 132,433.13
2. Judgment/Lien Holder:
SAVANNA ROBERTS
3. Judgment/Lien Type:
Civil
4. Date Filed (MM/DD/YYYY):
10/23/2025 Exact Explanation
If not exact, provide explanation:
5. Is Judgment/Lien outstanding?
Yes No
If No, provide status date (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
If No, how was matter resolved?
6. Court (Name of Federal, State or Foreign Court), Location of Court (City or County and State or Country) and Docket/Case Number:
OHIO STATE COURT, CUYAHOGA COUNTY COURT OF COMMON PLEAS, CASE NUMBER CV-25-118597
7. Provide a brief summary of events leading to the action and any payment schedule details including current status (if applicable) (your response must fit
within the space provided):
ON JUNE 2, 2025, PLAINTIFF SAVANNA ROBERTS FILED A COMPLAINT AGAINST GREAT LAKES RENTAL MORTGAGE, LLC, GREAT LAKES INVESTMENT PARTNERS,
LLC, GREAT LAKES SERVICING, LLC, GREAT LAKES INVESTMENT PARTNERS FUND E, LLC, AND SEKU SHABAZZ FOR BREACH OF CONTRACT IN CUYAHOGA
COUNTY COMMON PLEAS, STATE OF OHIO. ON SEPTEMBER 30, 2025, A JUDGMENT WAS RENDERED BY THE COURT AGAINST GREAT LAKES RENTAL MORTGAGE,
LLC, GREAT LAKES INVESTMENT PARTNERS, LLC, GREAT LAKES INVESTMENT PARTNERS FUND E, LLC, AND SEKU SHABAZZ FOR THE SUME OF $132,433.13 AND
INTEREST AT 0% FROM THE 30TH OF SEPTEMBER 2025 AND $275 COSTS OF SUIT, PLUS ATTORNEY'S FEES IN THE AMOUNT OF $26,024.20. THE JUDGMENT
LIEN REMAINS PENDING.
This Disclosure Reporting Page (DRP ADV) is an response used to report details for affirmative responses to Item 2.D. of Part 1B of
INITIAL OR AMENDED
Form ADV.
Judgment/Lien
Check Part 1B item(s) being responded to:
2D
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 or
advisory affiliates management persons
One or more of your or
advisory affiliates management persons
If this DRP is being filed for an advisory affiliate or a management person, give the full name of the advisory affiliate or management person below (for
individuals, Last name, First name, Middle name).
If the advisory affiliate or management person has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate checkbox.
ADV DRP - ADVISORY AFFILIATE or MANAGEMENT PERSON
CRD 5988727
This advisory affiliate or management person is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, N
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) or management person(s) is no longer associated with the adviser.
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:
NOTE: The completion of this form does not relieve the advisory affiliate or management person of its obligation to update its IARD or CRD records.
PART II
1. Judgment/Lien Amount:
$ 388,750.00
2. Judgment/Lien Holder:
ZINOFF CAPITAL,
3. Judgment/Lien Type:
Civil
4. Date Filed (MM/DD/YYYY):
06/02/2025 Exact Explanation
If not exact, provide explanation:
5. Is Judgment/Lien outstanding?
Yes No
If No, provide status date (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
If No, how was matter resolved?
6. Court (Name of Federal, State or Foreign Court), Location of Court (City or County and State or Country) and Docket/Case Number:
OHIO STATE COURT, CUYAHOGA COUNTY COURT OF COMMON PLEAS, CASE NUMBER CV-25-118600
7. Provide a brief summary of events leading to the action and any payment schedule details including current status (if applicable) (your response must fit
within the space provided):
ON JUNE 2, 2025, PLAINTIFF ZINOFF CAPITAL FILED A COMPLAINT AGAINST GREAT LAKES RENTAL MORTGAGE, LLC, GREAT LAKES INVESTMENT PARTNERS, LLC,
GREAT LAKES SERVICING, LLC, GREAT LAKES INVESTMENT PARTNERS FUND E, LLC, AND SEKU SHABAZZ FOR BREACH OF CONTRACT IN CUYAHOGA COUNTY
COMMON PLEAS, STATE OF OHIO. ON OCTOBER 15, 2025, A JUDGMENT WAS RENDERED BY THE COURT AGAINST GREAT LAKES RENTAL MORTGAGE, LLC, GREAT
LAKES INVESTMENT PARTNERS, LLC, GREAT LAKES LOAN SERVICING, LLC, GREAT LAKES INVESTMENT PARTNERS FUND E, LLC, AND SEKU SHABAZZ, FOR
$355,086.70 PLUS INTEREST OF 15% FROM OCTOBER 15, 2025, PLUS COSTS OF $275. THE JUDGMENT LIEN REMAINS PENDING.
This Disclosure Reporting Page (DRP ADV) is an response used to report details for affirmative responses to Item 2.D. of Part 1B of
INITIAL OR AMENDED
Form ADV.
Judgment/Lien
Check Part 1B item(s) being responded to:
2D
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 or
advisory affiliates management persons
One or more of your or
advisory affiliates management persons
If this DRP is being filed for an advisory affiliate or a management person, give the full name of the advisory affiliate or management person below (for
individuals, Last name, First name, Middle name).
If the advisory affiliate or management person has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate checkbox.
ADV DRP - ADVISORY AFFILIATE or MANAGEMENT PERSON
CRD 5988727
This advisory affiliate or management person is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, N
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) or management person(s) is no longer associated with the adviser.
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:
NOTE: The completion of this form does not relieve the advisory affiliate or management person of its obligation to update its IARD or CRD records.
PART II
1. Judgment/Lien Amount:
$ 994,000.00
2. Judgment/Lien Holder:
SEQUENCE FINANC
3. Judgment/Lien Type:
Civil
4. Date Filed (MM/DD/YYYY):
10/03/2022 Exact Explanation
If not exact, provide explanation:
ORIGINAL CASE FILED IN SC ON 10/03/2022 REFILED IN OH ON 05/14/2025
5. Is Judgment/Lien outstanding?
Yes No
If No, provide status date (MM/DD/YYYY):
Exact Explanation
If not exact, provide explanation:
If No, how was matter resolved?
6. Court (Name of Federal, State or Foreign Court), Location of Court (City or County and State or Country) and Docket/Case Number:
INITIAL CASE FILED IN SOUTH CAROLINA STATE COURT, CHARLESTON COUNTY COURT OF COMMON PLEAS, CASE NUMBER SC 2022-CP OHIO STATE COURT,
CUYAHOGA COUNTY COURT OF COMMON PLEAS, CASE NUMBER CV-25-114612
7. Provide a brief summary of events leading to the action and any payment schedule details including current status (if applicable) (your response must fit
within the space provided):
ON OCTOBER 3, 2022, PLAINTIFF SEQUENCE FINANCIAL SPECIALISTS, LLC FILED A COMPLAINT AGAINST SEKU SHABAZZ, INDIVIDUALLY, IN A SUIT ON
GUARANTY, IN THE CHARLESTON COUNTY COURT OF COMMON PLEAS, STATE OF SOUTH CAROLINA. IN JULY 30, 2023, A JUDGMENT BY SAID COURT WAS
RENDERED IN FAVOR OF SEQUENCE FINANCIAL SPECIALISTS, LLC, AND ON MAY 14, 2025, A JUDGMENT LIEN ACTION WAS FILED IN CUYAHOGA COUNTY
COMMON PLEAS COURT, STATE OF OHIO, AGAINST MR. SHABAZZ FOR THE JUDGMENT AMOUNT OF $994,000 PLUS INTEREST OF 11.5% AND COURT COSTS OF
$125. THE JUDGMENT LIEN REMAINS PENDING.
This Disclosure Reporting Page (DRP ADV) is an response used to report details for affirmative responses to Item 2.D. of Part 1B of
INITIAL OR AMENDED
Form ADV.
Judgment/Lien
Check Part 1B item(s) being responded to:
2D
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 or
advisory affiliates management persons
One or more of your or
advisory affiliates management persons
If this DRP is being filed for an advisory affiliate or a management person, give the full name of the advisory affiliate or management person below (for
individuals, Last name, First name, Middle name).
If the advisory affiliate or management person has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate checkbox.
ADV DRP - ADVISORY AFFILIATE or MANAGEMENT PERSON
CRD 5988727
This advisory affiliate or management person is a Firm an Individual
Number:
Registered:
Yes No
Name: SHABAZZ, SEKU, NKRUMAH
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) or management person(s) is no longer associated with the adviser.
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:
THIS ITEM WAS MISFILED AS AN ITEM AGAINST THE FIRM. IN FACT IT WAS AGAINST A MANAGEMENT PERSON (EX-SPOUSE) WHICH HAS SINCE BEEN SATISFIED
CONSISTENT WITH THE DIVORCE DECREE AND IS NOW LISTED AS A LEGACY DRP.
NOTE: The completion of this form does not relieve the advisory affiliate or management person of its obligation to update its IARD or CRD records.
PART II
1. Judgment/Lien Amount:
$ 4,014.03
2. Judgment/Lien Holder:
VELOCITY DEBT
3. Judgment/Lien Type:
Civil
4. Date Filed (MM/DD/YYYY):
04/07/2017 Exact Explanation
If not exact, provide explanation:
5. Is Judgment/Lien outstanding?
Yes No
If No, provide status date (MM/DD/YYYY):
12/16/2019 Exact Explanation
If not exact, provide explanation:
If No, how was matter resolved?
Satisfied
6. Court (Name of Federal, State or Foreign Court), Location of Court (City or County and State or Country) and Docket/Case Number:
CUYAHOGA COUNTY COURT OF COMMON PLEAS OHIO USA DOCKET # CV-17-878584
7. Provide a brief summary of events leading to the action and any payment schedule details including current status (if applicable) (your response must fit
within the space provided):
VELOCITY INVESTMENTS DEBT LLC HAS FILED A LAWSUIT FOR A JUDGEMENT LIEN FOR SEKU N. SHABAZZ FOR AN UNSECURED LOAN THAT WAS MADE TO
MICHELE L. JOHNSON IN 2014 THAT WAS CO-SIGNED BY SEKU N. SHABAZZ. IN 2014 SEKU N. SHABAZZ AND MICHELE L. JOHNSON WERE MARRIED. IN 2016
THEY DIVORCED. THE DIVORCE DECREE STATES THAT MICHELE L. JOHNSON IS RESPONSIBLE FOR THIS PARTICULAR DEBT (DOCKET # DR-16-360404). THE
JUDGEMENT WAS SATISFIED ON 01/28/2020 BY EX-SPOSE.
Part 1B Item 1 - State Registration
You must complete this Part 1B only if you are applying for registration, or are registered, as an investment adviser with any of the state securities
authorities.
Complete this Item 1 if you are submitting an initial application for state registration or requesting additional state registration(s). Check the boxes next to the
states to which you are submitting this application. If you are already registered with at least one state and are applying for registration with an additional state or
states, check the boxes next to the states in which you are applying for registration. Do not check the boxes next to the states in which you are currently
registered or where you have an application for registration pending.
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
Part 1B Item 2 - Additional Information
Complete this Item 2A. only if the person responsible for supervision and compliance does not appear in Item 1J. or 1K. of Form ADV Part 1A:
A. Person responsible for supervision and compliance:
Name: Title:
Telephone: Fax:
Number and Street 1: Number and Street 2:
City: State: Country: ZIP+4/Postal Code:
Email address, if available:
If this address is a private residence, check this box:
B. Bond/Capital Information, if required by your home state
(1) Name of Issuing Insurance Company:
(2) Amount of Bond:
$ .00
(3) Bond Policy Number:
Yes No
(4) If required by your home state, are you in compliance with your home state's minimum capital requirements?
Part 1B - Disclosure Questions
BOND DISCLOSURE
For "yes" answers to the following question, complete a Bond DRP. Yes No
C. Has a bonding company ever denied, paid out on, or revoked a bond for you, any advisory affiliate, or any management person?
JUDGMENT/LIEN DISCLOSURE
For "yes" answers to the following question, complete a Judgment/Lien DRP. Yes No
D. Are there any unsatisfied judgments or liens against you, any advisory affiliate, or any management person?
ARBITRATION DISCLOSURE
For "yes" answers to the following questions, complete an Arbitration DRP.
E. Are you, any advisory affiliate, or any management person currently the subject of, or have you, any advisory affiliate, or any management person
been the subject of, an arbitration claim alleging damages in excess of $2,500, involving any of the following: Yes No
(1) any investment or an investment-related business or activity?
(2) fraud, false statement, or omission?
(3) theft, embezzlement, or other wrongful taking of property?
(4) bribery, forgery, counterfeiting, or extortion?
(5) dishonest, unfair, or unethical practices?
CIVIL JUDICIAL DISCLOSURE
For "yes" answers to the following questions, complete a Civil Judicial Action DRP.
F. Are you, any advisory affiliate, or any management person currently subject to, or have you, any advisory affiliate, or any management person been
found liable in, a civil, self-regulatory organization, or administrative proceeding involving any of the following: Yes No
(1) an investment or investment-related business or activity?
(2) fraud, false statement, or omission?
(3) theft, embezzlement, or other wrongful taking of property?
(4) bribery, forgery, counterfeiting, or extortion?
(5) dishonest, unfair, or unethical practices?
Part 1B - Business Information
G. Other Business Activities
(1) Are you, any advisory affiliate, or any management person actively engaged in business as a(n) (check all that apply):
Tax Preparer
Issuer of securities
Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles
Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles
Real estate adviser
(2) If you, any advisory affiliate, or any management person are actively engaged in any business other than those listed in Item 6.A of Part 1A or Item 2.G(1)
of Part 1B, describe the business and the approximate amount of time spent on that business:
H. If you provide financial planning services, the investments made based on those services at the end of your last fiscal year totaled:
Securities Investments Non-Securities Investments
Under $100,000
$100,001 to $500,000
$500,001 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 to $5,000,000
More than $5,000,000
If securities investments are over $5,000,000, how much? 6650000 (round to the nearest $1,000,000)
If non-securities investments are over $5,000,000, how much? (round to the nearest $1,000,000)
I. Custody Yes No
(1) Advisory Fees
Do you withdraw advisory fees directly from your clients' accounts? If you answered "yes", respond to the following:
(a) Do you send a copy of your invoice to the custodian or trustee at the same time that you send a copy to the client?
(b) Does the custodian send quarterly statements to your clients showing all disbursements for the custodian account, including the amount of
the advisory fees?
(c) Do your clients provide written authorization permitting you to be paid directly for their accounts held by the custodian or trustee?
(2) Pooled Investment Vehicles and Trusts
(a) (i) Do you or a related person act as a general partner, managing member, or person serving in a similar capacity, for any pooled investment
vehicle for which you are the adviser to the pooled investment vehicle, or for which you are the adviser to one or more of the investors in
the pooled investment vehicle? If you answered "yes", respond to the following:
(a) (ii) As the general partner, managing member, or person serving in a similar capacity, have you or a related person engaged any of the
following to provide authority permitting each direct payment or any transfer of funds or securities from the account of the pooled
investment vehicle?
Attorney
Independent certified public accountant
Other independent party
Describe the independent party:
For purposes of this Item 2I.2(a), "Independent party" means a person that: (A) is engaged by the investment adviser to act as a gatekeeper for the
payment of fees, expenses and capital withdrawals from the pooled investment; (B) does not control and is not controlled by and is not under common
control with the investment adviser; (C) does not have, and has not had within the past two years, a material business relationship with the investment
adviser; and (D) shall not negotiate or agree to have material business relations or commonly controlled relations with an investment adviser for a period
of two years after serving as the person engaged in an independent party agreement.
(b) Do you or a related person act as investment adviser and a trustee for any trust, or act as a trustee for any trust in which your advisory
clients are beneficiaries of the trust?
(3) Do you require the prepayment of fees of more than $500 per client and for six months or more in advance?
J. If you are organized as a sole proprietorship, please answer the following: Yes No
(1) (a) Have you passed, on or after January 1, 2000, the Series 65 examination?
(b) Have you passed, on or after January 1, 2000, the Series 66 examination and also passed, at any time, the Series 7 examination?
(2) (a) Do you have any investment advisory professional designations?
If "no",you do not need to answer Item 2.J(2)(b).
(b) I have earned and I am in good standing with the organization that issued the following credential:
Certified Financial Planner ("CFP")
Chartered Financial Analyst ("CFA")
Chartered Financial Consultant ("ChFC")
Chartered Investment Counselor ("CIC")
Personal Financial Specialist ("PFS")
None of the above
(3) Your Social Security Number:
K. If you are organized other than as a sole proprietorship, please provide the following:
(1) Indicate the date you obtained your legal status. Date of formation: 08/30/2017
(2) Indicate your IRS Empl. Ident. No.:
Part 2
Amend, retire or file new brochures:
Brochure ID Brochure Name Brochure Type(s)
340596 PART 2B Other
340597 CLIENT BROCHURE Individuals, High net worth individuals,
Foundations/charities, Financial Planning Services,
Includes material about supervised persons that would
otherwise be in a supplement (state-registered
advisers only), The document is a Brochure Supplement
for one or more supervised persons (state-registered
advisers only)
432733 SHABAZZ PART 2B 20260706 The document is a Brochure Supplement for one or more
supervised persons (state-registered advisers only)
432734 WILDE PART 2B 20260706 The document is a Brochure Supplement for one or more
supervised persons (state-registered advisers only)
432735 PART 2A 20260706 Individuals, High net worth individuals, Financial
Planning Services
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
SEKU N SHABAZZ 07/10/2026
Printed Name: Title:
SEKU N SHABAZZ PRESIDENT/CCO
Adviser CRD Number:
290434
NON-RESIDENT INVESTMENT ADVISER EXECUTION PAGE
You must complete the following Execution Page to Form ADV. This execution page must be signed and attached to your initial submission of Form ADV to the SEC
and all amendments.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint each of the Secretary of the SEC, and the Secretary of State or other
legally designated officer, of any other state in which you are submitting a notice filing, as your agents to receive service, and agree that such persons may accept
service on your behalf, of any notice, subpoena, summons, order instituting proceedings, demand for arbitration, or other process or papers, and you further agree
that such service may be made by registered or certified mail, in any federal or state action, administrative proceeding or arbitration brought against you in any
place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with your investment
advisory business that is subject to the jurisdiction of the United States, and (b) is founded, directly or indirectly, upon the provisions of: (i) the Securities Act of
1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any
rule or regulation under any of these acts, or (ii) the laws of any state in which you are submitting a notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power of attorney and consent to service of process will continue in effect if any partner withdraws from or
is admitted to the partnership, provided that the admission or withdrawal does not create a new partnership. If the partnership dissolves, this irrevocable power
of attorney and consent shall be in effect for any action brought against you or any of your former partners.
3. Non-Resident Investment Adviser Undertaking Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your own expense, to the U.S. Securities and Exchange Commission at its principal office in Washington
D.C., at any Regional or District Office of the Commission, or at any one of its offices in the United States, as specified by the Commission, correct, current, and
complete copies of any or all records that you are required to maintain under Rule 204-2 under the Investment Advisers Act of 1940. This undertaking shall be
binding upon you, your heirs, successors and assigns, and any person subject to your written irrevocable consents or powers of attorney or any of your general
partners and managing agents.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with the authority of, the non-resident investment adviser. The investment adviser and I both certify,
under penalty of perjury under the laws of the United States of America, that the information and statements made in this ADV, including exhibits and any other
information submitted, are true and correct, and that I am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be preserved and available for inspection as required by law. Finally, I authorize any person having custody or
possession of these books and records to make them available to federal and state regulatory representatives.
Signature: Date: MM/DD/YYYY
Printed Name: Title:
Adviser CRD Number:
290434
STATE-REGISTERED 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 application for state registration
and all amendments to registration.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned adviser, irrevocably appoint the legally designated officers and their successors, of the state in
which you maintain your principal office and place of business and any other state in which you are applying for registration or amending your registration, 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 applying for registration or amending your registration.
2. State-Registered Investment Adviser Affidavit
If you are subject to state regulation, by signing this Form ADV, you represent that, you are in compliance with the registration requirements of the state in which
you maintain your principal place of business and are in compliance with the bonding, capital, and recordkeeping requirements of that state.
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.
Date: MM/DD/YYYY Printed Name:
07/10/2026 SEKU N SHABAZZ
Adviser CRD Number:
290434
Signature: Title:
SEKU N SHABAZZ PRESIDENT/CCO