Form SEC 2898 SEC 2898 Form MA

FORM MA
APPLICATION FOR MUNICIPAL ADVISOR REGISTRATION
ANNUAL UPDATE OF MUNICIPAL ADVISOR REGISTRATION
AMENDMENT OF A PRIOR APPLICATION FOR REGISTRATION

OMB APPROVAL
OMB Number:
3235-0681
Expires:
February 28, 2017
Estimated average burden hours
per initial response. . . . . . . . . . 3.5
per annual amendment. . . . . . . 1.5
per other amendment. . . . . . . . 0.5

Please read the General Instructions for this form and other forms in the MA series, as well as its subsection, “Specific
Instructions for Certain Items in Form MA,” before completing this form. All italicized terms herein are defined or described
in the Glossary of Terms appended to the General Instructions.

PART I
This form must be completed by municipal advisors that are organized entities, including sole proprietors (referred
to herein as “municipal advisory firms” or “firms,” unless the context indicates otherwise).
WARNING:

Complete this form truthfully. False statements or omissions may result in denial of
application, revocation of registration, administrative or civil action, or criminal
prosecution. Form MA must be amended promptly upon the occurrence of certain
material events, and updated at least annually, within 90 days of the end of the
municipal advisor’s fiscal year, or, if a sole proprietor, the municipal advisor’s calendar
year. See General Instruction 8.

Type of Filing: This is an (check the appropriate box):
Initial application to register as a municipal advisor with the SEC.
Execution Page: After completing this form, you must complete the Execution Page.
Supporting Documentation: If you are required to make reportable disclosures in the Disclosure Reporting
Pages, you must attach the supporting documentation.
Non-Resident Applicants: If you are a non-resident of the United States, certain additional requirements must
be met at the time of filing your application, or processing of your application may be delayed. See General
Instruction 2.c. and subsection “General Instructions to Form MA-NR” of the General Instructions.
Annual update of municipal advisor’s Form MA, for fiscal year ended ______, or, if a sole proprietor, for
calendar year ended December 31, _____.
Execution Page: After completing this form, you must complete the Execution Page.
Changes: Are there changes in this annual update to information provided in the municipal advisor’s most
recent Form MA, other than the updated Execution Page?
Yes
No
Amendment (other than annual update) to any part of the municipal advisor’s most recent Form MA.
Execution Page: After completing this form, you must complete the Execution Page.

SEC 2898 (4/14)

Item 1 Identifying Information
A. Full Legal Name of the Firm:
(1) Firm Name: ______________________________________________________
Organization CRD No., if any: _____________
(2) Sole Proprietor: If the applicant is a sole proprietor, check the box below, and provide full last name,
first name, middle name, and suffix, if any:
Enter all the letters of each name and not initials or other abbreviations. If no middle name, enter
NMN on that line.
__________________ _______________ _____________ ________
Last Name
First Name
Middle Name
Suffix
Individual CRD No., if any: _____________
(3) Name Change: If full legal name has changed since the municipal advisor’s most recent Form MA,
check here and provide the previous full legal name.
______________________________________________

B. Doing-Business-As (DBA) Name:
(1) If the name under which municipal advisor-related business is primarily conducted is different from
Item 1-A., check here and provide the DBA name.
________________________________________________________________________

(2) Previous DBA Name:
If name under which municipal advisor-related business is primarily conducted has changed since the
municipal advisor’s most recent Form MA, check here and provide the previous name under which the
municipal advisor-related business was primarily conducted.
_________________________________________
(3) Additional Names:
(a) Is municipal advisor-related business conducted under any additional names?
(b) If “Yes,” list any additional names on Section 1-B of Schedule D.

Yes

No

C. (1) IRS Employer Identification Number: ______________________________
(2) If the applicant (such as a sole proprietor) has no employer identification number, provide the
applicant’s Social Security Number:
________________________________
The Social Security Number will not be included in publicly available versions of this registration form.

2

D. Registrations
(1) Form MA-T Registration: Was the applicant previously registered on Form MA-T as a municipal
advisor?
Yes
No

If “Yes,” enter the SEC File No. MA-T: ______________

(2) Other Registrations: Is the applicant registered as or with any of the following?
Check all that apply. For each registration box you check, provide the requested file number(s). An
applicant firm should NOT provide the organization CRD number, or other specified number, of any of its
organizational affiliates, or the individual CRD number of its officers, employees, or natural person
affiliates.
Municipal Advisor
SEC File No.: _________
Municipal Securities Dealer SEC File No.: _________
Broker-Dealer
SEC File No.: _________
Organization CRD No.: ___________
Investment Adviser
SEC-Registered
SEC File No.: ________ Organization CRD No.: ___________
Exempt Reporting Adviser SEC File No.: ________ Organization CRD No.: ___________
Investment Adviser Registration in a US State or Other US Jurisdiction: If applicant is registered
in a US state or other jurisdiction as an investment adviser, check the Registered in US State or
Other US Jurisdiction box below and enter the organization CRD Number. In the table below,
check the box for each US state or jurisdiction in which the applicant is so registered.
Registered in US State or Other US Jurisdiction
Check
All
That
Apply

US
State or
Jurisdiction
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana

Check
All
That
Apply

Code
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN

3

Organization CRD No. ___________

US
State or
Jurisdiction

Code

Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina

MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
RI
SC

Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri

IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO

South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin

SD
TN
TX
UT
VT
VI
VA
WA
WV
WI

Government Securities Broker-Dealer
SEC File No.: _______________ Bank Identifier: _______________
Other SEC Registration (Specify): __________________________________
SEC File No. (if any): ___________ EDGAR CIK (if any): __________
Another federal or state regulator (Specify): ___________________________
Registration No. (if any): ___________
(3) Additional Registrations
(a) Does the applicant have any additional registrations that are not listed in subsection (2)?
Yes
(b) If “Yes,” list such additional registrations on Section 1-D of Schedule D.

No

E. Principal Office and Place of Business
(1) Address: (Do not use a P.O. Box.)
______________________________________________________________________
(number and street)
______________________
_________ ___________ _____________________
(city)
(state)
(country)
(postal code)
______________________________________ ________________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

(2) Additional Offices:
(a) Is municipal advisor-related business conducted at any office(s) other than applicant’s principal
office and place of business listed above?
Yes
No
(b) If “Yes,” list the five largest such additional offices on Section 1-E of Schedule D.

4

(3) Mailing Address:
Complete this item only if mailing address is different from principal office and place of business address in Item
1-E.(1):

______________________________________________________________________
(number and street)
_______________________ _________ ___________ _____________________
(city)
(state)
(country)
(postal code)
If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

F. Website
(1) Provide the address of the applicant’s principal website (if any):
(specify) _______________________________________________
(2) Does the applicant have additional websites?

Yes

No

(3) If “Yes,” how many?
(specify) ____
If “Yes,” list all additional website addresses on Section 1-F of Schedule D.

G. If the applicant has a Chief Compliance Officer, provide his or her name and contact
information:
Please note that the applicant must provide name and contact information for either a Chief Compliance
Officer in this Question 1-G., or another contact person in Question 1-H below. Both may be provided.
Enter all the letters of each name and not initials or other abbreviations. If no middle name, enter
NMN on that line.
_______________
_______________
_______________
Last Name
First Name
Middle Name
______________________________________________________________________
(other title(s), if any)
______________________________________________________________________
(number and street)
_______________________ _________
___________ ____________________
(city)
(state)
(country)
(postal code)
______________________________________ ______________________________
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

_________________@_________________
(E-mail address of Chief Compliance Officer)

5

H. Contact Person: If a person other than the Chief Compliance Officer is authorized to receive
information and respond to questions about this form, provide the name and contact information for that
person:
Please note that the applicant must provide name and contact information for either a Chief Compliance
Officer in Question 1-G. above, or another contact person in this Question 1-H. Both may be provided.
Enter all the letters of each name and not initials or other abbreviations. If no middle name, enter
NMN on that line.
_______________
_______________
_______________
Last Name
First Name
Middle Name
______________________________________________________________________
(other title(s), if any)
______________________________________________________________________
(number and street)
_______________________ _________ ___________ ____________________
(city)
(state)
(country)
(postal code)
______________________________________ ______________________________
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

_________________@________________
(E-mail address of Contact Person)
I. Location of Books and Records
(1) Does the applicant maintain, or intend to maintain, some or all of the books and records required to be
kept under MSRB rules and SEC rules at a location other than the principal office and place of business
address listed in Item 1-E?
Yes
No
(2) If “Yes,” list all such locations in Section 1-I of Schedule D.
J. Foreign Financial Regulatory Authorities
(3) Is the applicant registered with a foreign financial regulatory authority? Answer “no” even if affiliated
with a business that is registered with a foreign financial regulatory authority.
Yes
No
(4) If “Yes,” list all such registrations in Section 1-J of Schedule D.
K. Business Affiliates of the Applicant
(1) Is the applicant affiliated with any other domestic or foreign business entity?

Yes

No

(2) If “Yes,” provide the names of all such affiliates and any applicable registrations in Section 1-K of
Schedule D.

6

Item 2 Form of Organization
A.

Applicant’s Form of Organization
If this is not an initial application, and the applicant’s form of organization has changed since the
applicant’s most recent Form MA, see Instruction 8 of the General Instructions.
Corporation
Sole Proprietorship
Limited Liability Partnership (LLP)
Partnership
Limited Liability Company (LLC)
Limited Partnership (LP)
Other (specify):_______________________________________________________________

B. Month of Applicant’s Annual Fiscal Year End ___________________
(Sole proprietors are not required to complete this subpart B.)

C. State, Other US Jurisdiction, or Foreign Jurisdiction Under Which Applicant is Organized
If the applicant is a corporation or limited liability company, indicate the state or jurisdiction where the
applicant is incorporated. If the applicant is a partnership, indicate the name of the state or jurisdiction
under the laws of which the partnership was formed. If applicant is a sole proprietor, indicate the state or
jurisdiction in which applicant resides.
If this is not an initial application for registration, and the applicant’s information has changed since the
applicant’s most recent Form MA, see General Instruction 8.
Enter the full name of the state or other US jurisdiction, or the full name, in English, of the foreign
jurisdiction: _________________________________________

D. Date of Organization: ___________________
E. Public Reporting Company
(1) Is the applicant a public reporting company under Sections 12 or 15(d) of the Securities
Exchange Act of 1934?
Yes

No

(2) If “Yes,” provide applicant’s EDGAR CIK number: _____________

Item 3 Successions
A. Is the applicant, at the time of this filing, succeeding to the business of a registered
municipal advisor?
If this succession was previously reported on Form MA, do not report the succession again. Instead, check “No.”
See Instruction 1 of the Specific Instructions for Certain Items in Form MA included in the General Instructions.

7

Yes

If “Yes,” enter the Date of Succession: ______________
(mm/dd/yyyy)

No

B. If “Yes” in Item 3-A., complete Section 3 of Schedule D.
Item 4 Information About Applicant’s Business
Note: Instruction 2 of the Specific Instructions for Certain Items in Form MA included in the General
Instructions provides guidance for newly formed municipal advisors completing this Item 4.

Employees
If the applicant is organized as a sole proprietorship, include the sole proprietor as an employee.
A.Number of Employees: Approximate number of employees of applicant. Include full- and part-time
employees, but do not include clerical, administrative, or support workers (or workers performing similar
functions): _____________ (If none, enter a zero.)
B. Municipal Advisory Activities: Approximately how many of these employees engage in municipal
advisory activities? (Include such employees even if they perform other functions in addition to engaging
in municipal advisory activities.) _____________ (If none, enter a zero.)

C. Registered Representatives
(1) Approximately how many of the employees who are included in the response to part B are registered
representatives of a broker-dealer? _______________ (If none, enter a zero.)
(2) Approximately how many are investment adviser representatives? ______________ (If none, enter a
zero.)

D. Firms and Other Persons that Solicit on Behalf of the Applicant
Approximately how many firms and other persons who are not employed by the applicant and who are not
otherwise associated persons of the applicant solicit clients on the applicant’s behalf? (Count a firm only
once; do not count each of the firm’s employees that solicits on the applicant’s behalf.)
___________ (If none, enter a zero.)
Please list the names of these firms and other persons on Section 4-D of Schedule D.

E. Employees Also Acting as Affiliates of the Applicant
(1) Does the applicant have any employees that also do business independently on the applicant’s behalf as
affiliates of the applicant?
Yes
No

8

(2) If “Yes,” provide the total number of such employees: _______
(3) List the names of these employees on Section 4-E of Schedule D.

Clients
F. Types of Clients: Approximately how many clients did the applicant serve in the context of its
municipal advisory activities during its most-recently completed fiscal year? ___________ (If none, enter
a zero and check box 5 below.)
The applicant has the following types of clients:
Check all that apply.
(1)
(2)
(3)
(4)
(5)

Municipal entities
Non-profit organizations (e.g., 501(c)(3) organizations) who are obligated persons
Corporations or other businesses not listed above who are obligated persons
Other: ___________________________
Not applicable - applicant engages only in solicitation; does not serve clients in the context of
its municipal advisory activities.

G. Solicitations of Municipal Entities and Obligated Persons
Approximately how many municipal entities and obligated persons were solicited by the applicant on
behalf of a third-party during its most-recently completed fiscal year? (If the applicant solicits its clients in
addition to serving these clients in the context of its municipal advisory activities, the clients should be counted in the
response to this Part G even if counted in Part F.)

(1)
(2)
(3)

Municipal Entities: ____________ (If none, enter a zero.)
Obligated Persons: ____________ (If none, enter a zero.)
Total: _______________

H. Types of Persons Solicited
The applicant solicits the following types of persons:
Check all that apply.
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)

Public pension funds
529 Plans
Local government investment pools
State government investment pools
Hospitals
Colleges
Other: ___________________________
Not applicable – applicant only serves clients; does not engage in solicitation in the context of
its municipal advisory activities.

9

Compensation Arrangements
I. Applicant is compensated for its advice to or on behalf of municipal entities or obligated

persons with respect to municipal financial products or the issuance of municipal securities
by:
Check all that apply.
(1)
(2)
(3)
(4)
(5)
(6)

Hourly charges
Fixed fees (not contingent on the issuance of municipal securities)
Contingent fees
Subscription fees (for a newsletter or other publications)
Other (specify): __________________________________________________
Not applicable – applicant engages only in solicitation; does not serve clients in the context of
its municipal advisory activities.

J. Applicant is compensated for its solicitation activities by:
Check all that apply.
(1)
(2)
(3)
(4)
(5)
(6)

Hourly charges
Fixed fees (not contingent on the success of solicitations)
Contingent fees
Subscription fees (for a newsletter or other publications)
Other (specify): __________________________________________________
Not applicable; applicant only serves clients; does not engage in solicitation as part of its
municipal advisory activities.

K. Does the applicant receive compensation, in the context of its municipal advisory activities,

from anyone other than clients?
Yes

No

If “Yes,” please explain:
______________________________________________________________________________________
______________________________________________________________________________________
______________________________________________________________________________________

Applicant’s Business Relating to Municipal Securities
L. Applicant is engaged in the following types of activities:
Check all that apply.
(1)

(2)

(3)

Advice concerning the issuance of municipal securities (including, without limitation, advice
concerning the structure, timing, terms and other similar matters, such as the preparation of
feasibility studies, tax rate studies, appraisals and similar documents, related to an offering of
municipal securities)
Advice concerning the investment of the proceeds of municipal securities (including, without
limitation, advice concerning the structure, timing, terms and other similar matters concerning
such investments)
Advice concerning municipal escrow investments (including, without limitation, advice
concerning their structure, timing, terms and other similar matters)

10

(4)

Advice concerning the investment of other funds of a municipal entity (including, without
limitation, advice concerning the structure, timing, terms and other similar matters concerning
such investments)
(5) Advice concerning guaranteed investment contracts (including, without limitation, advice
concerning their structure, timing, terms and other similar matters)
(6) Advice concerning the use of municipal derivatives (including, without limitation, advice
concerning their structure, timing, terms and other similar matters)
(7) Solicitation of investment advisory business from a municipal entity or obligated person
(including, without limitation, municipal pension plans) on behalf of an unaffiliated broker,
dealer, municipal advisor or investment adviser (e.g., third party marketers, placement agents,
solicitors, and finders)
(8) Solicitation of business other than investment advisory business from a municipal entity or
obligated person on behalf of an unaffiliated person or firm (e.g., third party marketers,
placement agents, solicitors, and finders)
(9) Advice or recommendations concerning the selection of other municipal advisors or
underwriters with respect to municipal financial products or the issuance of municipal securities
(10) Brokerage of municipal escrow investments
(11) Other (specify):____________________________

Item 5 Other Business Activities
A. Applicant is actively engaged in business in or as a:
Other Business

(i) Is
Applicant
Actively
Engaged?

(ii) Is this
Applicant’s
Primary
Business(es)?

Check all that
apply.

Check all that
apply.
(iii) Jurisdiction(s) where licensed:

1.

2.
3.
4.

Broker-dealer, municipal securities
dealer or government securities broker
or dealer
Registered representative of a brokerdealer
Commodity pool operator (whether
registered or exempt from registration)
Commodity trading advisor (whether
registered or exempt from registration)

5.
6.
7.
8.
9.

Futures commission merchant
Major swap participant
Major security-based swap participant
Swap dealer
Security-based swap dealer

10.
11.
12.
13.

Trust company
Real estate broker, dealer, or agent
Insurance company, broker, or agent
Banking or thrift institution (including
a separately identifiable department or
division of a bank)

11

14.

Investment adviser (including
financial planners)

15.

Attorney or law firm

________________________________
________________________________
________________________________

16.

Accountant or accounting firm

________________________________
________________________________
________________________________

17.
18.

Engineer or engineering firm
Other financial product advisor
(specify):
_________________________
_________________________
_________________________

B. Other Business:
(1) Is applicant actively engaged in any other business not listed in Part A of this Item
(other than engaging in municipal advisory activities)?

Yes

No

(2) If “Yes” to Part B-1., is this other business applicant’s primary business?

Yes

No

(3) If “Yes” to Part B-2., describe the other business on Section 5-B of Schedule D.

Item 6 Financial Industry and Other Activities of Associated Persons
A. Applicant has one or more associated persons that is a:
Check all that apply.
“Associated Person” herein refers to a person who is an associated person of a municipal advisor. Note that
“associated person” includes employees and persons with control over the municipal advisor that do not themselves
engage in municipal advisory activities, but does not include employees that are performing solely clerical,
administrative, support or other similar functions. Note also that more than one box may be applicable to any such
associated person. For example, if an associated person is both a swap dealer and security-based swap dealer, check
both boxes (4) and (5) below.
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)

Broker-dealer, municipal securities dealer, or government securities broker or dealer
Investment company (including mutual funds)
Investment adviser (including financial planners)
Swap dealer
Security-based swap dealer
Major swap participant
Major security-based swap participant
Commodity pool operator (whether registered or exempt from registration)
Commodity trading advisor (whether registered or exempt from registration)

12

(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)

Futures commission merchant
Banking or thrift institution
Trust company
Accountant or accounting firm
Attorney or law firm
Insurance company or agency
Pension consultant
Real estate broker or dealer
Sponsor or syndicator of limited partnerships
Engineer or engineering firm
Other municipal advisor

Total Associated Persons: Provide the total number of all such associated persons: ______
Provide the total number of such associated persons, not the number of boxes checked. For example, if the applicant’s
associated persons are 2 broker-dealers, 1 investment company, and 2 pension consultants, then 3 boxes would be
checked in Item 6-A.1 to 20, while the total number of such associated persons entered in Item 6-A, Total Associated
Persons, would be 5. If there are no associated persons, enter 0.

B. Applicant must list all such associated persons, including foreign associated persons, on
Section 6 of Schedule D.
If Item 6-A, Total Associated Persons, is 2 or more, the applicant must complete a separate Section 6 of Schedule D
for each associated person.

Item 7

Participation or Interest of Applicant, or of Associated Persons of Applicant, in
Municipal Advisory Client or Solicitee Transactions

Proprietary Interest in Municipal Advisory Client or Solicitee Transactions
A. Does applicant or any associated person:
(1) buy securities or other investment or derivative products for itself from clients or solicitees in the
context of its municipal advisory activities, or sell securities it owns to such clients or solicitees?
Yes
No
(2) buy or sell for itself securities (other than shares of mutual funds) or other investment or derivative
products that the applicant also recommends to such clients or solicitees?
Yes
No
(3) enter into derivatives contracts with such clients or solicitees?

Yes

No

(4) recommend securities or other investment or derivative products to such clients or solicitees in which
applicant or any associated person has some other proprietary (ownership) interest (other than those
mentioned in Items 7-A(1), (2) or (3) above)?
Yes
No

Sales Interest in Client or Solicitee Transactions
B. Does applicant or any associated person:
(1) recommend purchases of securities or derivatives to clients or solicitees that are served by the applicant
or associated person, for which the applicant or any associated person serves as underwriter, general or
managing partner, or purchaser representative?
Yes
No

13

(2) recommend purchases or sales of securities or derivatives to such clients or solicitees in which
applicant or any associated person has any other sales interest (other than the receipt of sales
commissions as a broker or registered representative of a broker-dealer)?
Yes

No

Investment or Brokerage Discretion
C. Does applicant or any associated person have discretionary authority to determine the:
(1) securities or other investment or derivative products to be bought or sold for the account of a client or
solicitee?
Yes
No
(2) amount of securities or other investment or derivative products to be bought or sold for the account of
such a client or solicitee?
Yes
No
(3) (a) broker or dealer to be used for a purchase or sale of securities or other investment or derivative
products for the account of such a client or solicitee?
Yes
No
(b) If “Yes,” are any of the brokers or dealers associated persons?

Yes

(4) commission rates or other fees to be paid to a broker or dealer for such a client’s or solicitee’s
securities transactions or transactions in other investment or derivative products?
Yes

No

No

D. (1) Does applicant or any associated person recommend brokers, dealers or investment advisers to
clients or solicitees in the context of its municipal advisory activities?
Yes
No
(2) If “Yes,” is any such broker, dealer, or investment adviser an associated person?

Yes

No

In responding to Items 7-E and 7-F below, consider all cash and non-cash compensation that the applicant or an
associated person gave or received from any person in exchange for referrals of such clients or solicitees, including any
bonus that is based, at least in part, on the number or amount of such referrals.

E. Does the applicant or any associated person, directly or indirectly, compensate any person

for referrals of clients or solicitees in connection with municipal advisory activities?
Yes

No

F. Does the applicant or any associated person, directly or indirectly, receive compensation

from any person for referrals of clients or solicitees in connection with municipal advisory
activities?
Yes

Item 8 Owners, Officers, and Other Control Persons
A.

Identifying Owners, Officers, and Other Control Persons
(1) In this Item, identify every person that, directly or indirectly, controls the applicant, or that the
applicant directly or indirectly controls.
(a) If this is an initial application, the applicant must complete Schedule A and Schedule B.
Schedule A asks for information about direct owners and executive officers.
Schedule B asks for information about indirect owners.

14

No

(b) If this is an amendment updating information reported on either the Schedule A or Schedule B
(or both) filed with the applicant’s initial application, the applicant must also complete Schedule
C.
(2) Does any person not named in Item 1-A or Schedules A, B, or C, directly or indirectly, control the
applicant’s management or policies?
Yes
No
(3) If “Yes” to Item 8-A.2. above, complete Section 8-A of Schedule D.
B. Public Reporting Companies
(1) Is any person in Schedules A, B, or C, or in Section 8-A of Schedule D a public reporting company
under
Sections 12 or 15(d) of the Securities Exchange Act of 1934?
Yes
No
(2) If “Yes” to Item 8-B.1. above, complete Section 8-B of Schedule D.

Item 9 Disclosure Information
In this Item, provide information about the criminal, regulatory, and judicial history, if any, of the applicant
and each associated person of the applicant.
This information is used to determine whether to approve an application for registration, to decide whether to
revoke registration, or to place limitations on the applicant’s activities as a municipal advisor, and to identify
potential problem areas on which to focus during on-site examinations. One event may result in the
requirement to answer “Yes” to more than one question below.
Refer to the Glossary of Terms for explanations of italicized terms, such as associated person.

Criminal Action Disclosure
If the answer is “Yes” to any question below in Part A or B below, complete a Criminal Action DRP.
Disclosure of any event listed in this Criminal Action Disclosure section is not required if the date of the event
was more than ten years ago. For purposes of calculating this ten-year period, the date of an event is the date
that the final order, judgment, or decree was entered, or the date that any rights of appeal from preliminary
orders, judgments, or decrees lapsed.
Check all that apply:

A.

In the past ten years, has the applicant or any associated person:
(1) been convicted of any felony, or pled guilty or nolo contendere (“no contest”) to any charge of a felony,
in a domestic, foreign, or military court?
Yes
No
(2) been charged with any felony?

Yes

The response to Item 9-A(2) may be limited to charges that are currently pending.
B. In the past ten years, has the applicant or any associated person:

15

No

(1) been convicted of any misdemeanor, or pled guilty or nolo contendere (“no contest”), in a domestic,
foreign, or military court to any charge of a misdemeanor in a case involving: municipal advisorrelated business, 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?
Yes
No
(2) been charged with a misdemeanor of the kind listed in Item 9-B(1)?

Yes

No

(1) found the applicant or any associated person to have made a false statement or omission?
Yes

No

The response to Item 9-B(2) may be limited to charges that are currently pending.

Regulatory Action Disclosure
If the answer is “Yes” to any question in Parts C-G below, complete a Regulatory Action DRP.
Check all that apply:
C. Has the SEC or the CFTC ever:

(2) found the applicant or any associated person to have been involved in a violation of any SEC or CFTC
regulation or statute?
Yes
No
(3) found the applicant or any associated person to have been a cause of the denial, suspension, revocation,
or restriction of the authorization of a municipal advisor-related or an investment-related business to
operate?
Yes
No
(4) entered an order against the applicant or any associated person in connection with municipal advisorrelated or investment-related activity?
Yes
No
(5) imposed a civil money penalty on the applicant or any associated person, or ordered the applicant or
any associated person to cease and desist from any activity?
Yes
No
D. Has any other federal regulatory agency, any state regulatory agency, or any foreign
financial regulatory authority ever:
(1) found the applicant or any associated person to have made a false statement or omission, or been
dishonest, unfair, or unethical?
Yes
No
(2) found the applicant or any associated person to have been involved in a violation of municipal advisorrelated or investment-related regulations or statutes?
Yes
No
(3) found the applicant or any associated person to have been the cause of a denial, suspension, revocation,
or restriction of the authorization of a municipal advisor-related or an investment-related business to
operate?
Yes
No
(4) entered an order against the applicant or any associated person in connection with a municipal advisorrelated or investment-related activity?
Yes
No
(5) denied, suspended, or revoked the registration or license of the applicant or that of any associated

16

person, or otherwise prevented the applicant or any associated person, by order, from associating with
a municipal advisor-related or investment-related business or restricted the activities of the applicant or
any associated person?
Yes
No
E. Has any self-regulatory organization or commodities exchange ever:
(1) found the applicant or any associated person to have made a false statement or omission?
Yes

No

(2) found the applicant or any associated person 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)? Yes
No
(3) found the applicant or any associated person to have been the cause of a denial, suspension, revocation
or restriction of the authorization of a municipal advisor-related or an investment-related business to
operate?
Yes
No
(4) disciplined the applicant or any associated person by expelling or suspending the applicant or the
associated person from membership, barring or suspending the applicant or the associated person from
association with other members, or by otherwise restricting the activities of the applicant or the
associated person?
Yes
No
F. Revocation or Suspension: Has the applicant or any associated person ever had an authorization to act
as an attorney, accountant, or federal contractor revoked or suspended?
Yes
No
G. Regulatory Proceedings: Is the applicant or any associated person currently the subject of any
regulatory proceeding that could result in a “Yes” answer to any part of Item 9-C, 9-D, or 9-E?
Yes

No

Civil Judicial Disclosure
If the answer is “Yes” to a question below, complete a Civil Judicial Action DRP.
Check all that apply:
H. (1) Has any domestic or foreign court ever:
(a) enjoined the applicant or any associated person in connection with any municipal advisor-related
or investment-related activity?
Yes
No
(b) found that the applicant or any associated person was involved in a violation of any municipal
advisor-related or investment-related statute(s) or regulation(s)?
Yes
No
(c) dismissed, pursuant to a settlement agreement, a municipal advisor-related or investment-related
civil action brought against the applicant or any associated person by a state or other US
jurisdiction or a foreign financial regulatory authority?
Yes
No
(2) Current Proceedings: Is the applicant or any associated person the subject of any currently pending
civil proceeding that could result in a “Yes” answer to any part of Item 9-H(1)?
Yes
No

17

Item 10 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, the SEC needs to determine whether you meet the Small Business Administration’s definition of
“small business” for purposes of entities that provide investment and related activities. Accordingly, answer “Yes”
or “No,” as appropriate, to the questions below:
A. Did the applicant have annual receipts of less than $7 million during its most recent fiscal year (or during
the time the applicant has been in business, if it has not completed its first fiscal year in business)?
Yes
No
B. Is the applicant affiliated with any business or organization that had annual receipts of $7 million or more
during its most recent fiscal year (or during the time it has been in business, if it has not completed its first
fiscal year in business)?
Yes
No

18

FORM MA
SCHEDULE A
DIRECT OWNERS AND EXECUTIVE OFFICERS OF THE APPLICANT
1. Complete Schedule A only if submitting an initial application. Schedule A asks for information about the
applicant’s direct owners and executive officers. Use Schedule C to amend this information. To determine
direct ownership and executive officer status, see instruction 2 below.
Separate subparts of Schedule A must be completed for: (1) direct owners that are business entities, and (2)
direct owners and executive officers who are natural persons, as follows:
•

Complete Schedule A-1: “Direct Owners of Applicant – Business Entities,” for owners that are
organized as a business or other legal entity, such as a corporation, partnership, trust, or limited
liability company.

•

Complete Schedule A-2: “Direct Owners and Executive Officers of Applicant – Natural
Persons,” for owners who are individuals, including sole proprietors, and for executive officers.

2. List in either Schedule A-1 or Schedule A-2 below, or both, as applicable, the full names of:
(a) If applicant is organized as a corporation, each shareholder that is a direct owner of 5% or more of a
class of the applicant’s voting securities, unless applicant is a public reporting company (a company subject
to Sections 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 the
applicant’s 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-inlaw, 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) If the applicant is organized as a partnership, all general partners and each limited and special partner
that has the right to receive upon dissolution, or has contributed, 5% or more of the applicant’s capital;
(c) In the case of a trust, a person that directly owns 5% or more of a class of the applicant’s voting
securities, or that has the right to receive upon dissolution, or has contributed, 5% or more of the
applicant’s capital, the trust and each trustee;
(d) If the applicant is organized as a limited liability company (“LLC”), (i) each member that has the right
to receive upon dissolution, or has contributed, 5% or more of the applicant’s capital, and (ii) if managed
by elected managers, all elected managers; and
(e) Each Chief Executive Officer, Chief Financial Officer, Chief Operations Officer, Chief Legal Officer,
Chief Compliance Officer, director and any other individuals with similar status or functions (applies in
Schedule A-2 only).
3. In the DE/FE column of Schedule A-1 below, enter “DE” if the owner is a domestic entity, or “FE” if the
owner is an entity organized, incorporated or domiciled in a foreign country.
4. Complete the Title or Status column by entering board/management titles; status as partner, trustee, sole
proprietor, elected manager, shareholder, or member. For shareholders or members, indicate the class of
securities owned (if more than one is issued). In the next column, indicate the date that the title or status was
acquired.

5. Ownership codes are:
NA - less than 5%
A - 5% but less than 10%
B - 10% but less than 25%
C - 25% but less than 50%
D - 50% but less than 75%
E - 75% or more
6. (a) In the Control Person column, enter “Yes” in the first sub-column if the person has control as defined in
the Glossary of Terms to Form MA, 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 sub-column (Schedule A-1 only) enter “PR” if the owner is a public reporting company under
Sections 12 or 15(d) of the Exchange Act.
7. (a) For Schedule A-1, enter the organization CRD number. If not registered with the CRD, then enter the IRS
Tax Number, Employer Identification Number (“EIN”), or Foreign Business Number.
(b) For Schedule A-2, enter the individual CRD number. If not registered with the CRD, then enter the Social
Security Number (“SSN”) or Foreign Identity Number; and enter the Date of Birth (“DOB”). Social
security numbers, foreign identity numbers, and dates of birth will not be publicly disseminated.
8. Does applicant have any indirect owners to be reported on Schedule B?

Yes

No

Schedule A-1: Direct Owners of Applicant – Business Entities
BUSINESS ENTITY
FULL LEGAL NAME

DE/FE

Title
or
Status

Date Title or
Status
Acquired
MM

Ownership
Code

YYYY

Control
Person
Yes/
No

PR

Organization CRD No.
(If None: IRS Tax No., EIN, or
Foreign Business No.)
CRD
No.

IRS
Tax
No.

EIN

Foreign
Bus.
No.

Schedule A-2: Direct Owners and Executive Officers of Applicant – Natural Persons
NATURAL PERSON
FULL LEGAL NAME

Title
or
Status

Date Title or
Status
Acquired

Ownership
Code

Control
Person

Individual CRD No.
(If None: SSN and DOB, or
Foreign ID No. and DOB)

Yes/No

CRD
No.

Enter all the letters of each name
and not initials or other
abbreviations. If no middle
name, enter NMN on that line.

Last
Name

First
Name

Middle
Name

MM

YYYY

20

SSN

DOB

Foreign
ID No.

FORM MA
SCHEDULE B
INDIRECT OWNERS OF THE APPLICANT
1. Complete Schedule B only if applicant is submitting an initial application. Schedule B asks for
information about the applicant’s indirect owners. The applicant must first complete Schedule A, which asks
for information about direct owners. For purposes of Schedule B, an “indirect owner” includes any owner of
25% or more of any direct owner listed in Schedule A, and any owner of 25% or more of each such indirect
owner going up the chain of ownership. Use Schedule C to amend the information in this schedule. To
determine indirect ownership, see instructions 2 and 3 below.
Separate subparts of Schedule B must be completed for: (1) indirect owners that are business entities, and (2)
indirect owners who are natural persons, as follows:
•

Complete Schedule B-1: “Indirect Owners of Applicant – Business Entities,” for owners who are
organized as business or other legal entities, such as a corporation, partnership, trust, or limited
liability company.

•

Complete Schedule B-2: “Indirect Owners of Applicant – Natural Persons,” for individuals and
sole proprietors.

2. With respect to each direct owner listed on Schedule A-1 (business entities), list in either Schedule B-1 or
Schedule B-2 below, as applicable:
(a) in the case of a direct owner listed on Schedule A-1 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 a direct owner listed on Schedule A-1 that is a partnership, all general partners and each
limited and special partner that has the right to receive upon dissolution, or has contributed, 25% or more of
the partnership’s capital;
(c) in the case of a direct owner listed on Schedule A-1 that is a trust, the trust and each trustee; and
(d) in the case of a direct owner listed on Schedule A-1 that is a limited liability company (“LLC”), (i)
each member that has the right to receive upon dissolution, or has contributed, 25% or more of the LLC’s
capital, and (ii) if managed by elected managers, each elected manager.
3. Continue up the chain of indirect ownership listing all 25% shareholders 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 column in Schedule B-1 below, enter “DE” if the indirect owner is a domestic entity, or “FE” if
the owner is an entity organized, incorporated or domiciled in a foreign country. Complete the next column by
indicating the entity in the chain of ownership in which this indirect owner has an interest.

21

5. Complete the Status column by entering the indirect owner’s status as partner, trustee, elected manager,
shareholder, or member. For shareholders or members, indicate the class of securities owned (if more than one
is issued).
6. Ownership codes are:
C - 25% but less than 50%
D - 50% but less than 75%
E - 75% or more
F - Other (general partner, trustee, or elected manager)
7. (a) In the Control Person column, enter “Yes” in the first sub-column if the person has control as defined in
the Glossary of Terms to Form MA, 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 sub-column, for Schedule B-1 only, enter “PR” if the indirect owner is a public reporting
company under Sections 12 or 15(d) of the Exchange Act.
8. (a) For Schedule B-1, enter the organization CRD number. If not registered with the CRD, then enter the IRS
Tax Number, Employer Identification Number (“EIN”), or Foreign Business Number.
(b) For Schedule B-2, enter the individual CRD number. If not registered with the CRD, then enter the Social
Security Number (“SSN”) or Foreign Identity Number; and enter the Date of Birth (“DOB”). Social
security numbers, foreign identity numbers, and dates of birth will not be publicly disseminated.

Schedule B-1: Indirect Owners of Applicant – Business Entities
BUSINESS ENTITY
FULL LEGAL NAME

DE/FE

Entity
In
Which
Interest
Is
Owned

Title
or
Status

Date Title or
Status
Acquired
MM

Ownership
Code

YYYY

Control
Person
Yes/No

PR

Organization CRD No.
(If None: IRS Tax No., EIN,
or Foreign Business No.)
CRD
No.

IRS
Tax
No.

Foreign
Bus.
No.

EIN

Schedule B-2: Indirect Owners of Applicant – Natural Persons
NATURAL PERSON
FULL LEGAL NAME
Enter all the letters of each
name and not initials or other
abbreviations. If no middle
name, enter NMN on that line.

Last
Name

First
Name

Middle
Name

Entity
In
Which
Interest
Is
Owned

Status

Date Title or
Status
Acquired

MM

YYYY

Ownership
Code

Control
Person

Individual CRD No.
(If None: SSN and DOB, or
Foreign ID No. and DOB)

Yes/No CRD
No.

22

SSN

DOB

Foreign ID
No.

FORM MA
SCHEDULE C
Amendments to Schedules A and B
1. Use Schedule C only to amend information requested on either Schedule A or Schedule B. Refer to
instructions in Schedule A and Schedule B, which also apply for this Schedule C.
2. In the Type of Amendment column, indicate “A” (addition), “D” (deletion), or “C” (change in information
about the same person).
3. Ownership codes are:
NA - less than 5%
A - 5% but less than 10%
B - 10% but less than 25%
C - 25% but less than 50%
D - 50% but less than 75%
E - 75% or more
F - Other (general partner, trustee, or elected member)
4. List below all changes to Schedule A:
Schedule A-1: Direct Owners of Applicant – Business Entities
TYPE OF
AMENDMENT

BUSINESS ENTITY
FULL LEGAL NAME

DE/
FE

Title
or
Status

Date Title
or Status
Acquired
MM

Ownership
Code

YYYY

Control
Person
Yes/
No

PR

Organization CRD No.
(If None: IRS Tax No., EIN, or
Foreign Business No.)
CRD
EIN
Foreign
IRS
No.
Bus. No.
Tax
No.

Schedule A-2: Direct Owners and Executive Officers of Applicant – Natural Persons
TYPE OF
AMENDMENT

NATURAL PERSON
FULL LEGAL NAME
Enter all the letters of each
name and not initials or
other abbreviations. If no
middle name, enter NMN
on that line.
Last
Name

First
Name

Middle
Name

Title
or
Status

Date Title
or Status
Acquired

MM

YYYY

Ownership
Code

Control
Person

Individual CRD No.

Yes/No

CRD
No.

(If None: SSN and DOB or Foreign
ID No. and DOB)

SSN

DOB

Foreign
ID No.

5. List below all changes to Schedule B:
Schedule B-1: Indirect Owners of Applicant – Business Entities
TYPE
OF
AMEDMENT

BUSINESS
ENTITY
FULL LEGAL
NAME

DE
/FE

Entity In
Which
Interest
Is
Owned

Status

Date Title or
Status
Acquired
MM

Ownership
Code

YYYY

Control
Person
Yes/
No

Organization CRD No.
(If None: IRS Tax No., EIN, or
Foreign Business No.)

PR

Schedule B-2: Indirect Owners of Applicant – Natural Persons
TYPE OF
AMENDMENT

NATURAL PERSON
FULL LEGAL NAME
Enter all the letters of
each name and not
initials or other
abbreviations. If no
middle name, enter
NMN on that line.
Last
Name

First
Name

Middle
Name

Entity Status
In
Which
Interest
Is
Owned

Date Title or
Status
Acquired

MM

YYYY

24

Ownership Control
Code
Person

Individual CRD No.
(If None: SSN and DOB or
Foreign ID No. and DOB

Yes/No CRD SSN
No.

DOB

Foreign ID
No.

FORM MA
SCHEDULE D
Certain items in Part I of Form MA require additional information on Schedule D. Use this Schedule D to report
details for items listed below. Report only new information or changes/updates to previously submitted
information. Do not repeat previously submitted information.
This is an:

INITIAL or

AMENDED Schedule D or

ANNUAL UPDATE

SECTION 1-B Other Names under which Municipal Advisor-Related Business is Conducted
List the applicant’s other business names and the jurisdictions in which they are used. A separate Schedule D must
be completed for each business name and the jurisdictions where that name is used.
Select only one:
Add
Delete
Amend
Name __________________________________________ Jurisdictions: ______________________________
(List all jurisdictions.)
SECTION 1-D Additional Registrations of the Applicant
Indicate any additional registrations with federal or state regulators, and the relevant registration number. A
separate Schedule D must be completed for each such registration.
Name ____________________________________________ Registration No. ___________________________
SECTION 1-E Additional Offices at which the Applicant’s Municipal Advisor-Related Business is Conducted
Provide the location of the largest five additional offices (in terms of numbers of employees) at which the
applicant’s municipal advisor-related business is conducted other than applicant’s principal office and place of
business. A separate Schedule D must be completed for each such office.
Select only one:
Add
Delete
Amend
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

SECTION 1-F Additional Website Addresses
List any additional website addresses of the applicant. A separate Schedule D must be completed for each such
website address.
Select only one:
Add
Delete
Amend
Website Address: ________________________________________________

25

SECTION 1-I Location of Books and Records
Complete the following information for each location at which the applicant keeps books and records, other than its
principal office and place of business. A separate Schedule D must be completed for each location.
Select only one:

Add

Delete

Amend

Name of entity where books and records are kept: _______________________________
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

This is (select only one):

one of applicant’s branch offices or affiliates
a third-party unaffiliated recordkeeper
other

Briefly describe the books and records kept at the location(s) you checked. If you checked “other,” describe
additionally all such location(s).
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
__________________________________________________________________________________________
SECTION 1-J Registration with Foreign Financial Regulatory Authorities
List the full name, in English, of each foreign financial regulatory authority, provide the foreign registration
number (if any), and list the full name, in English, of the country with which the applicant is registered. A separate
Schedule D must be completed for each foreign financial regulatory authority with whom the applicant is
registered.
Select only one:

Add

Delete

Amend

______________________________________________
English Name of Foreign Financial Regulatory Authority

26

_________________ ____________________
Foreign Registration English Name of Country
No. (if any)

SECTION 1-K Business Affiliates of the Applicant
Provide the name of any domestic or foreign business affiliate of the applicant, and any federal, state, or foreign
registration of such affiliate and the registration number. A separate Schedule D must be completed for each such
affiliate.
Name of Affiliate: _______________________________________________
1. Does the affiliate have an applicable federal, state, or foreign registration?

Yes

No

2. If “Yes” to Section 1-K (1) above, provide the:
(a) Name of Agency Issuing Registration (in English): ___________________________________
(b) Registration No., if any: ________________________
(c) Provide the jurisdiction (check the appropriate box, and if a US state or other jurisdiction, or a foreign
country, provide the name of the jurisdiction):
US Federal
US State or Other US Jurisdiction: _________________
Foreign Country Name (in English): __________________________________
SECTION 3 Successions
Complete the following information if succeeding to the business of a currently-registered municipal advisor. If the
applicant succeeded more than one municipal advisory firm in the succession being reported on this Form MA, a
separate Schedule D must be completed for each predecessor firm. See Instruction 1 of the Specific Instructions for
Certain Items in Form MA included in the General Instructions.
Name of Predecessor Municipal Advisory Firm: __________________________________________________
Municipal Advisor
SEC File No.: _____________
Municipal Securities Dealer
SEC File No.: _____________
Broker-Dealer
SEC File No.: _____________ Organization CRD No.: __________
Investment Adviser
SEC-Registered
SEC File No.: _________ _ Organization CRD No.: __________
Exempt Reporting Adviser SEC File No.: __________ Organization CRD No.: __________
Investment Adviser Registration in a US State or Other US Jurisdiction: If predecessor municipal advisory firm
is registered in a US state or other jurisdiction as an investment adviser, check the Registered in US State or
Other US Jurisdiction box below and enter the organization CRD Number. In the table below, check the box for
each US jurisdiction in which the applicant is so registered.

Registered in US State or Other US Jurisdiction
Check
All
That
Apply

US
State or
Jurisdiction
Alabama
Alaska
Arizona

Check
All
That
Apply

Code

Organization CRD No. ___________

US
State or
Jurisdiction
Montana
Nebraska
Nevada

AL
AK
AZ

27

Code
MT
NE
NV

Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri

AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL
IN
IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO

New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin

NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
RI
SC
SD
TN
TX
UT
VT
VI
VA
WA
WV
WI

Government Securities Broker-Dealer
SEC File No.: _______________ Bank Identifier: _______________
Other SEC Registration (Specify): __________________________________
SEC File No. (if any): ___________ EDGAR CIK (if any): __________
Another federal or state regulator (Specify): ___________________________
Registration No. (if any): ___________
SECTION 4-D Firms and Other Persons that Solicit Municipal Advisor Clients on the Applicant’s Behalf
Provide the name, address, and phone number of any firm or other person that is not otherwise an associated
person of the applicant that solicits municipal advisor clients on the applicant’s behalf. A separate Schedule D
must be completed for each such firm or natural person.
Name: ___________________________________________________________
_____________________
________________________
EDGAR CIK No. (if any)
Individual CRD No. (if any)
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

28

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

SECTION 4-E Employees That Also Do Business Independently on the Applicant’s Behalf as Affiliates of the
Applicant
Name of Employee:
Enter all the letters of each name and initials or other abbreviations. If no middle name, enter NMN on that line.
_______________
_______________
_______________
Last Name
First Name
Middle Name
_____________________
_______________________
EDGAR CIK No. (if any)
Individual CRD No. (if any)
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

SECTION 5-B Description of Primary Business (for businesses not listed in Part A of Item 5)
If you checked Item 5-B.2., describe the applicant’s primary business (not the applicant’s municipal advisor-related
business):
____________________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
____________________________________________________________________________________________
SECTION 6 Financial Industry and Other Activities of Associated Persons
The following information must be completed for each associated person in every category you checked in Item 6A. This section must be completed separately for each such associated person.
Select only one:

Add

Delete

Amend

Legal Name of Associated Person: ________________________________________________________________
Primary Business Name of Associated Person:
_______________________________________________________
A. Associated person is a:
Check all that apply.
(1)
(2)
(3)

Broker-dealer, municipal securities dealer, or government securities broker or dealer
Investment company (including mutual funds)
Investment adviser (including financial planners)

29

(4)
(5)
(6)
(7)
(8)
(9)
(10)
(11)
(12)
(13)
(14)
(15)
(16)
(17)
(18)
(19)
(20)

Swap dealer
Security-based swap dealer
Major swap participant
Major security-based swap participant
Commodity pool operator (whether registered or exempt from registration)
Commodity trading advisor (whether registered or exempt from registration)
Futures commission merchant
Banking or thrift institution
Trust company
Accountant or accounting firm
Attorney or law firm
Insurance company or agency
Pension consultant
Real estate broker or dealer
Sponsor or syndicator of limited partnerships
Engineer or engineering firm
Other municipal advisor

B. Control Relationships and Foreign Registrations
(1) Control Relationships
(a) Does the applicant control or is it controlled by the associated person?

(b) Are the applicant and the associated person under common control?

Yes
Yes

No
No

(2) Foreign Financial Regulatory Authority Registration
(a) Is the associated person registered with a foreign financial regulatory authority?
Yes
No
(b) If the answer to (2)(a) is “Yes,” list in English the name of each foreign financial regulatory authority,
the associated person’s registration number with that authority (if any), and the country in which the
authority has jurisdiction.
______________________________________________
_____________ _______________________
English Name of Foreign Financial Regulatory Authority Registration
English Name of Country
Number (if any)
______________________________________________
_____________ _______________________
English Name of Foreign Financial Regulatory Authority Registration
English Name of Country
Number (if any)
SECTION 8 Control Persons (on a basis other than 25% ownership or executive officer status)
Section 8-A. A separate Schedule D must be completed for each control person not named in Item 1-A or
Schedules A, B, or C that directly or indirectly controls the applicant’s management or policies.
Select only one:
Add
Delete
The control person is a (select only one):

Amend
Firm or organization. You must complete Section 8-A (1).
Natural person. You must complete Section 8-A (2).

(1) If the control person is a firm or organization:
Name_________________________________________________________________
Municipal Advisor
Form MA-T Registration
SEC File No.: _______________
Effective Date: ______________ Termination Date: _____________

30

mm/dd/yyyy

mm/dd/yyyy

Form MA Registration
SEC File No.: _______________
Effective Date: ______________ Termination Date: _____________
mm/dd/yyyy
mm/dd/yyyy
Municipal Securities Dealer
SEC File No.: ______________
Effective Date: _________________ Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Broker-Dealer
SEC File No.: ___________
Organization CRD No.: _____________
Effective Date: _________________ Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Investment Adviser
SEC-Registered
SEC File No.: ________
Organization CRD No.: ________
Effective Date: ____________
Termination Date: ____________
mm/dd/yyyy
mm/dd/yyyy
Exempt Reporting Adviser
SEC File No.: ________ Organization CRD No.: _______
Effective Date: __________
Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Investment Adviser Registration in a US State or Other US Jurisdiction: If control person is registered
in a US state or other jurisdiction as an investment adviser, check the Registered in US State or Other
US Jurisdiction box below, and enter the organization CRD Number and other information requested.
In the table below, check the box for each US state or jurisdiction in which the control person is so
registered.
Registered in US State or Other US Jurisdiction
Organization CRD No. ___________
Effective Date: _____________
Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Check
All
That
Apply

US
State or
Jurisdiction
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida
Georgia
Guam
Hawaii
Idaho
Illinois

Check
All
That
Apply

Code
AL
AK
AZ
AR
CA
CO
CT
DE
DC
FL
GA
GU
HI
ID
IL

31

US
State or
Jurisdiction

Code

Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island

MT
NE
NV
NH
NJ
NM
NY
NC
ND
OH
OK
OR
PA
PR
RI

Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri

IN
IA
KS
KY
LA
ME
MD
MA
MI
MN
MS
MO

South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virgin Islands
Virginia
Washington
West Virginia
Wisconsin

SC
SD
TN
TX
UT
VT
VI
VA
WA
WV
WI

Government Securities Broker-Dealer SEC File No.: ___________ Bank Identifier: ___________
Effective Date: _________________
Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Other SEC Registration (Specify) ____________________________
SEC File No. (if any): _______________
EDGAR CIK (if any): ______________
Effective Date: _________________
Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Another Federal or State Regulator (Specify) _________________________________
Registration No. (if any): _________________
Effective Date: _________________
Termination Date: _________________
mm/dd/yyyy
mm/dd/yyyy
Business Address
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

Briefly describe the nature of the control:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
(2) If control person is a natural person:
Enter all the letters of each name and not initials or other abbreviations. If no middle name, enter NMN on that
line.
_______________
_______________
_______________
Last Name
First Name
Middle Name

32

_____________________
EDGAR CIK No. (if any)
_______________________
_______________________
_______________________
Individual CRD No. (if any)
Effective Date
Termination Date
_______________________________________________________________________
(number and street)
_______________________
_________
___________ ___________________
(city)
(state)
(country)
(postal code)
_________________________________
_____________________________
Telephone number at this location
Fax number (if any) at this location
(area code) (telephone number)
(area code) (fax number)
For non-US telephone and fax numbers, include country code with area code and local number.

If this address is a private residence, check this box:
A private residential address will not be included in publicly available versions of this registration form.

Briefly describe the nature of the control:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
Section 8-B. If any person named in Schedules A, B, or C or in Section 8-A of this Schedule D is a public
reporting company under Section 12 or 15(d) of the Securities Exchange Act of 1934, provide the
information below. A separate Section 8-B of Schedule D must be completed for each public reporting
company.
1. Full legal name of the public reporting company: _________________________________________
2. The public reporting company’s EDGAR CIK number: ________________
3. The Schedules where the public reporting company was reported:
Check all that apply.
Schedule A
Schedule B
Schedule C, Section 4
Schedule C, Section 5
Schedule D, Section 8-A

Schedule D: MISCELLANEOUS
The space below may be used to explain a response to an Item or to provide any other information.
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________
_____________________________________________________________________________________________

33

FORM MA
PART II:
DISCLOSURE REPORTING PAGES (DRPs)
CRIMINAL ACTION DISCLOSURE REPORTING PAGE (MA)
CRIMINAL ACTION DRP – PART 1
This Disclosure Reporting Page (DRP MA) is an
INITIAL OR
details for affirmative response(s) to Items 9-A or 9-B of Form MA.

AMENDED response used to report

Check item(s) in Form MA for which this DRP is providing details:
9-A(1)
9-A(2)

9-B(1)

9-B(2)

How to Report an Event or Proceeding on a Criminal Action DRP: 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.
One event may result in more than one affirmative answer to Items 9-A(1), 9-A(2), 9-B(1), and/or 9-B(2). Use
this DRP to report all charges, including multiple counts of the same charge, arising out of the same event and filed
in one criminal action. Separate criminal actions arising out of the same event, and unrelated criminal actions, must
be reported on separate DRPs.
Requirement to Provide Court Documents: Applicable court documents (i.e., criminal complaint, information or
indictment as well as judgment of conviction or sentencing documents) must be attached to, and filed electronically
with, this DRP (if not previously submitted).
Check all that apply, except where noted:
A. The person(s) or entity(ies) concerning whom this DRP is being filed is (are) the:
Select only one.
Applicant (the municipal advisory firm)
Applicant and one or more of the applicant’s associated person(s)
One or more of applicant’s associated person(s)
1. Applicant
(a) Is this DRP an amendment that seeks to remove a previously filed DRP concerning the applicant from
the record?
Yes
No
(b) If “Yes,” the reason the DRP should be removed is:
The applicant is registered or has submitted an application for registration that is currently pending
and the event or proceeding previously reported was resolved in the applicant’s favor.
The event or proceeding occurred more than ten years ago.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________

2. Associated Person(s)
(a) Does this DRP concern one or more associated persons?

Yes

No

(i) If “Yes,” indicate the total number of such associated person(s): ___
(b) Identify each such associated person by checking below either the box for firm or for natural person, as
appropriate, and provide the requested information:
Firm
Full legal name of the associated person:
______________________________________________________
The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC
CRD No., if any: ____________________
Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The event or proceeding occurred more than ten years ago.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
Provide the information for each additional firm below:
_____________________________________________
_____________________________________________

Natural Person
Full name of the associated person:
Enter all the letters of each name and not initials or other abbreviations.
If no middle name, enter NMN on that line.
_______________ _______________
Last Name
First Name

_______________
Middle Name

_________
Suffix

The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC

35

CRD No., if any: ____________________

Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The event or proceeding occurred more than ten years ago.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
Provide the information for each additional natural person below:
_______________________________________________________
_______________________________________________________

B. DRP filed elsewhere for this event: Is an accurate and up-to-date DRP containing the information regarding
the applicant or associated person required by this DRP already on file (a) in the IARD or CRD system (with a
Form ADV, BD, or U4), or (b) in the SEC’s EDGAR system (with a Form MA or Form MA-I)?
Yes
If the answer is “Yes,” provide the applicable information indicated below that identifies where the DRP
may be found.
1. Form ADV, BD, or U4 Filing: For a DRP filed on the IARD or CRD system with one of these
forms, provide the following information:
Name on Registration: _________________________________________________
CRD No.: __________________ Disclosure Occurrence No.: ___________________
2. Form MA Filing: For a DRP filed on EDGAR with a Form MA, provide the following
information:
Name on Registration: _________________________________________________
MA Registration Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
3. Form MA-I Filing: For a DRP filed on EDGAR with a Form MA-I, provide the following
information:
Name of Individual: _________________________________________________
MA-I File Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
No

36

If the answer is “Yes,” no other information on this DRP (other than set forth above) must be provided.
If the answer is “No,” complete Part 2 below.
NOTE: The completion of all or any part of this form does not relieve the municipal advisor or
associated person of its obligation to update its IARD or CRD records.

37

CRIMINAL ACTION DRP – PART 2
1. Firm or Organization
A. Were charge(s) brought against a firm or organization over which the applicant or an associated
person exercise(s)(d) control?
Yes
No
B. If “Yes,” provide the following information:
(1) Enter the firm or organization name: __________________________________________
(2) Was the firm or organization engaged in a municipal advisor-related or investment-related business?
Yes
No
(3) What was the relationship of the applicant or the associated person with the firm or organization?
(Include any position or title with the firm or organization.)
_______________________________________________________________________________
2. Court Where Formal Charge(s) Were Brought: (File a separate Criminal Action DRP for charges brought
in separate courts and/or separate cases in the same court. If brought in a foreign jurisdiction, provide all
the information below in English.)
Federal Court
Military Court
State Court
Foreign Country Court
International Court
Other : ___________________________
A. Name of the Court: ___________________________________________________________________
B. Location of the Court
Street Address: ______________________________________________________________
City or County: ______________________ State/Country: ________________________
Postal Code: __________________
C. Docket/Case Number and Case Name:______________________________
3. Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): ___________________

Exact

Explanation

If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
B. Details of Event: Report all charges separately. For each charge, provide all of the following information.
(1) First Charge
(a) List the charge/charge description:
________________________________________________________________________________

38

(b) Number of counts: ___
(c) Check the applicable box:

Felony

Misdemeanor

(d) Plea for this charge:
_____________________________________________________________________________
(e) (i) Is the charge municipal advisor-related?
Yes
No
(ii) If “Yes,” what is the product type?
_________________________________________________________________________
(f) (i) Is the charge investment-related?
Yes
No
(ii) If “Yes,” what is the product type?
_________________________________________________________________________
(g) (i) Amended Charge: Indicate if the original charge was amended or reduced:
Yes
No
(ii) If “Yes,” provide the date the charge was amended or reduced (MM/DD/YYYY):
___________________
Report the information for each additional charge below:
___________________________________________________
___________________________________________________

C. Felony Charge(s): Did any of the charge(s) within the event involve a felony?
4. Current Status of the Event:

Pending

On Appeal

Yes

No

Final

5. Event Status Date (Complete unless status is pending) (MM/DD/YYYY): ___________________
Exact
Explanation
If not exact, provide explanation:
_______________________________________________________________________________________
_______________________________________________________________________________________
6. On Appeal – Judicial Review: If Item 4 On Appeal is checked, to whom was the criminal action
appealed? (If brought in a foreign jurisdiction, provide all the information below in English.)
Federal Court
Military Court
State Court
Foreign Country Court
International Court
Other (specify): ___________________________
Provide the name and location of the court, docket/case number, and case name:
______________________________________________________________________________________
Date appeal filed (MM/DD/YYYY): ___________________

39

For Item 7: If Item 4 Final or On Appeal is checked, complete Item 7.
For Pending Actions, skip to Item 8.
7. Disposition Disclosure Detail (For each charge provide the following information):
(a) First Charge
(1) Disposition of the Charge
(Check all that apply to this charge.)
Acquitted
Amended
Convicted
Deferred Adjudication
Dismissed

Found not guilty
Pled guilty
Pled nolo contendere
Pled not guilty

Pretrial diversion/intervention
Reduced
Other (specify) ____________

Appealed
Affirmed
Vacated & Returned For Further Action
Vacated / Final
Other (specify) ______________________
Explanation: If more than one disposition is checked, and/or Other is checked, or the above otherwise
does not adequately summarize the disposition of the charge, provide an explanation.
_______________________________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________
(2) Date (MM/DD/YYYY): _____________
(3) Sentence/Penalty: Is a sentence or other penalty ordered?

Yes

No

If “Yes,” list each type (e.g., prison, jail, probation, community service, counseling, education, other specify):
______________________________________________________________________________
_______________________________________________________________________________
_______________________________________________________________________________
(4) Is there an incarceration in connection with this sentence?

Yes

No

If “Yes,” provide the following details:
(i) Duration (length of the sentence):

Days ___

Months ___

Years ___

(ii) Start Date of Penalty (MM/DD/YYYY): _________________

Not determined.

(iii) End Date of Penalty (MM/DD/YYYY): _________________

Not determined.

(iv) Is the sentence to be served concurrently with any other sentence?

40

Yes

No

If yes, indicate the end date of the concurrent sentence (MM/DD/YYYY):
_______________________
(v) Explanation (Optional):
__________________________________________________________________________
__________________________________________________________________________
(5) Monetary Penalty/Fine:
(i) Was a monetary penalty/fine imposed?
Yes
No
If “Yes,” provide the following details in (ii) and (iii) below:
(ii) Total Penalty/Fine Amount:

$___________

(iii) Was any portion suspended/reduced?
Yes If “Yes,” how much?
No

$___________

(iv) Final Amount:

$___________

(v) Was the final amount paid in full?
Yes If “Yes,” date paid in full (MM/DD/YYYY):____________
No
If “No,” indicate the amount unpaid:
$___________
And explain the circumstances:
_____________________________________________________________________________
_____________________________________________________________________________
Report the disposition(s) of each additional charge below:

____________________________________________________
_________________________________________________________

8. Summary of Circumstances: Use this space to provide a brief summary of the circumstances leading to the
action, allegation(s), finding(s) and disposition(s), if any. Include any relevant information on the current
action status, and on any terms, conditions, and dates not already provided above, and any other relevant
information. The information must fit within the space provided.
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

41

REGULATORY ACTION DISCLOSURE REPORTING PAGE (MA)
REGULATORY ACTION DRP – PART 1
This Disclosure Reporting Page (DRP MA) is an
INITIAL OR
AMENDED response used to report
details for affirmative responses to Items 9-C, 9-D, 9-E, 9-F or 9-G of Form MA.
Check item(s) being responded to:
9-C(1)
9-D(1)
9-E(1)
9-F

9-C(2)
9-D(2)
9-E(2)
9-G

9-C(3)
9-D(3)
9-E(3)

9-C(4)
9-D(4)
9-E(4)

9-C(5)
9-D(5)

How to Report an Event or Proceeding on a Regulatory Action DRP: 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.
One event may result in more than one affirmative answer to Items 9-C, 9-D, 9-E, 9-F, and/or 9-G. If an event
gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
Check all that apply, except where noted:
A. The person(s) or entity(ies) for whom this DRP is being filed is (are) the:
Select only one.
Applicant (the municipal advisory firm)
Applicant and one or more of the applicant’s associated person(s)
One or more of applicant’s associated person(s)
1. Applicant
(a) Is this DRP an amendment filed for the applicant that seeks to remove a previously filed DRP
concerning the applicant from the record?
Yes
No
(b) If “Yes,” the reason the DRP should be removed is:
The applicant is registered or applying for registration and the event or proceeding was resolved in
the applicant’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
2. Associated Person(s)
(a) Is this DRP being filed for one or more associated persons?

Yes

No

(i) If “Yes,” indicate the total number of such associated person(s): ___
(b) Identify each such associated firm and/or natural person in the space below:
Firm
Full name of the associated person:
______________________________________________________

42

The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC
CRD No., if any: ____________________
Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
Provide the information for each additional firm below:

___________________________________________
_______________________________________________

Natural Person
Full name of the associated person:
Enter all the letters of each name and not initials or other abbreviations.
If no middle name, enter NMN on that line.
_______________ _______________
Last Name
First Name

_______________
Middle Name

_________
Suffix

The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC
CRD No., if any: ____________________
Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________

43

Provide
ral
person below:
Provide the information
forthe
each
additional
natural person below:
_________________________________________________________
_________________________________________________________

B. DRP filed elsewhere for this event: Is an accurate and up-to-date DRP containing the information regarding
the applicant or associated person required by this DRP already on file (a) in the IARD or CRD system (with a
Form ADV, BD, or U4), or (b) in the SEC’s EDGAR system (with a Form MA or Form MA-I)?
Yes
If the answer is “Yes,” provide the applicable information indicated below that identifies where the DRP
may be found.
1. Form ADV, BD, or U4 Filing: For a DRP filed on the IARD or CRD system with one of these
forms, provide the following information:
Name on Registration: _________________________________________________
CRD No.: __________________ Disclosure Occurrence No.: ___________________
2. Form MA Filing: For a DRP filed on EDGAR with a Form MA, provide the following
information:
Name on Registration: _________________________________________________
MA Registration Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
3. Form MA-I Filing: For a DRP filed on EDGAR with a Form MA-I, provide the following
information:
Name of Individual: _________________________________________________
MA-I File Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
No
If the answer is “Yes,” no other information on this DRP (other than set forth above) must be provided.
If the answer is “No,” complete Part 2 below.
NOTE: The completion of all or any part of this form does not relieve the municipal advisor or
associated person of its obligation to update its IARD or CRD records.

44

REGULATORY ACTION DRP – PART 2
1. Regulatory Action was initiated by:
A.Select the Appropriate Item.
Select only one box below. A separate Regulatory Action DRP is required for each such regulator or other
authority.
SEC
CFTC
Federal Banking Agency
National Credit Union Administration
Other Federal Authority

State
SRO

Foreign Financial Regulatory Authority
Other: _________________________

B. Full name of the individual regulator (if not fully identified in Item 1-A) or other authority that
initiated the action. For a foreign financial regulatory authority, please provide the full name in English.
___________________________________________________________________________________
2. Sanction(s) Sought:
Check all that apply.
Bar (Permanent)
Bar (Temporary / Time Limited)
Cease and Desist
Censure
Civil and Administrative Penalty(ies)/Fine(s)
Denial

Disgorgement
Expulsion
Injunction
Prohibition
Reprimand
Rescission

Restitution
Requalification
Revocation
Suspension
Undertaking

Other Sanction(s) Sought (list each such additional sanction):
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
3. Date Initiated (MM/DD/YYYY): ____________________

Exact

Explanation

If not exact, provide explanation:
_______________________________________________________________________________________
_______________________________________________________________________________________
4. Regulatory Action was brought in (if brought in a foreign jurisdiction, provide all the information below in
English):
A. Name of the Administrative Proceeding, Commission/Agency Hearing, or other regulatory proceeding
or forum: ________________________________________________________
B. Location of the Proceeding / Hearing:
Street Address: ______________________________________________________________
City or County: ______________________ State/Country: _______________________
Postal Code: __________________

45

C. Docket/Case Number: __________________
5. A. Principal Product Type (check appropriate item):
No Product
Annuity – Charitable
Annuity – Fixed
Annuity – Variable
Banking Product
(other than CD)
CD
Commodity Option
Debt – Asset Backed
Debt – Corporate
Debt – Government
Debt – Municipal
Derivative

Direct Investment – DPP & LP Interest
Equipment Leasing
Equity Listed (Common & Preferred Stock)
Equity OTC
Futures – Commodity
Futures – Financial
Index Option
Insurance
Investment Contract
Money Market Fund
Mutual Fund

Oil & Gas
Options
Penny Stock
Prime Bank Instrument
Promissory Note
Real Estate Security
Security Futures
Security-based Swap
Swap
Unit Investment Trust
Viatical Settlement

Other Principal Product Type (specify):
___________________________________________________________________________________

B. Other Product Types?
Yes
No If “Yes,” describe each additional product type:
___________________________________________________________________________________
___________________________________________________________________________________
6. Allegations: Describe the allegations related to this regulatory action. (The response must fit within the space
provided.)
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
7. Current Status:

Pending

On Appeal

Final

8. Pending: If you checked Item 7 Pending, provide the following information.
A. Date Served: The date that notice or other process was served (MM/DD/YYYY): _______________
Exact
Explanation
If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
B. Limitation or Restrictions: Are there any limitations or restrictions currently in effect?
Yes
No
If the answer is “Yes,” provide details:
___________________________________________________________________________________

46

9. On Appeal – Administrative or Judicial Review of the Regulatory Action: If you appealed, provide the
following information.
A. Name of Regulator or Court Action Appealed To: Provide the name of the US regulator (i.e., the SEC,
an SRO, other), federal court, state court or state regulator, or a foreign or international court or regulator
to whom you appealed. If brought in a foreign jurisdiction, provide all the information below in English.
___________________________________________________________________________
B. Location of the Regulator or Judicial Court to Whom You Appealed:
Street Address: ______________________________________________________________
City or County: ______________________ State/Country: _______________________
Postal Code: __________________
C. Docket/Case Name: __________________________________________________________
D. Docket/Case Number:______________________________
E. Date Appeal filed (MM/DD/YYYY): ______________
Exact
Explanation
If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
F. Appeal Details (including status):
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
G. Limitation or Restrictions: Are there any limitations or restrictions currently in effect while on appeal?
Yes
No
If the answer is “Yes,” provide details:
___________________________________________________________________________________
___________________________________________________________________________________
If you checked Item 7 Final or On Appeal, complete Items 10 through 13.
For Pending Actions, skip to Item 13.
10. A. Resolution: How was the action resolved? (Check all the applicable boxes that reflect the most recent
resolution of the action by a regulator or a court, whether or not any part of the resolution is on appeal. If
any part of the resolution is on appeal, identify in Item 10-B which part is currently on appeal.)
Acceptance, Waiver & Consent (AWC)
Consent
Decision
Decision & Order of Offer of Settlement
Appealed
Affirmed
Vacated Nunc Pro Tunc / ab initio

Dismissed
Judgment Rendered
Order
Settled

47

Stipulation and Consent
Withdrawn
Other (requires explanation)

Vacated & Returned For Further Action
Vacated / Final
Other (requires explanation)
B. Explanation: If more than one box in Item 10-A is checked, or Other is checked, or Item 10-A otherwise
does not adequately summarize the type of resolution, provide an explanation. For example, if you
appealed all or part of a resolution by the regulator or court, indicate what is being appealed.
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
C. Order: If Order is checked above in Item 10-A, does the order constitute a final order based on
violations of any laws or regulations that prohibit fraudulent, or deceptive conduct?
Yes

No

11. Resolution Date (MM/DD/YYYY):____________________
Exact
Explanation
(For a resolution that is being appealed in part, the date to be provided should be the date on which the
regulator (reviewing a decision by an SRO or an Administrative Law Judge) or a court provided its resolution.)
If not exact, provide explanation:
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
_________________________________________________________________________________________
12. Resolution Detail
A. Sanction(s): Were any Sanctions Ordered?

Yes
No, none were ordered.

B. If “Yes,” check each individual sanction below that was ordered:
Bar (Permanent)
Bar (Temporary / Time Limited)
Cease and Desist
Censure
Civil and Administrative Penalty(ies)/Fine(s)*
Denial

Disgorgement*
Expulsion
Injunction
Prohibition
Reprimand
Rescission

Restitution*
Requalification
Revocation
Suspension
Undertaking

* Monetary Sanction(s): Were one or more sanctions ordered that require a monetary payment?
Yes
No
If “Yes,” enter the total amount ordered: $_____________
Other Sanction(s) Ordered (list each such additional sanction):
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

48

C. Sanction Detail (Provide the details of the following specific sanctions, if checked above in Item 12B.)
(1) Barred, Enjoined, or Suspended: If you checked one or more of these sanctions in Item 12-B. above,
check the applicable box(es) below and provide the corresponding information.
(a) Barred
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________
(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more bars
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:
________________________________________________________________________
________________________________________________________________________

(b) Enjoined
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________

49

(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more injunctions
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:
_________________________________________________________________
_________________________________________________________________

(c) Suspended
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________
(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_______________________________________________________________________________
_______________________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

50

If the applicant or an associated person received in the above action one or more suspensions
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:
_________________________________________________________________________
_________________________________________________________________________

(2) Requalification: Was requalification by examination, retraining, or other process a condition of a
sanction?
Yes
No
If “Yes,” provide:
(a) Length of time given to requalify, retrain, or complete other process:
No time period is specified.
Time period is specified:
Days ___

Months ___

Years ___

(b) Type of examination, retraining, or other process required:
_____________________________________________________________________________
_____________________________________________________________________________
(c) Was the condition satisfied?

Yes

No

(1) If “Yes,” provide the date (MM/DD/YYYY): ______________
(2) If “No,” explain the circumstances:
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more
requalifications in connection with registration capacities, associations, and/or other
activities; and the terms specify different time periods; report the additional details below:
_____________________________________________________________________
_____________________________________________________________________

(3) Monetary Sanction(s): If you indicated in Item 12-B above that one or more monetary sanctions were
ordered, provide the following information.
(a) Total Amount Ordered:

$___________

(b) Portion levied against:
Applicant
(i) Amount Ordered:

$___________

(ii) Was any portion waived?
Yes
No
If “Yes,” how much? $___________

51

(iii) Final Amount:

$___________

(iv) Was final amount paid in full?
Yes
No
If “Yes,” date paid in full (MM/DD/YYYY):____________
If “No,” explain the circumstances:
______________________________________________________________________
______________________________________________________________________
Associated Person
(i) Amount Ordered:

$___________

(ii) Was any portion waived?
Yes ________
No
If “Yes,” how much?
(iii) Final Amount:

$___________
$___________

(iv) Was final amount paid in full?
Yes
No
If “Yes,” date paid in full (MM/DD/YYYY):____________
If “No,” explain the circumstances:
______________________________________________________________________
______________________________________________________________________
Provide the information for each additional associated person below:
___________________________________________________
___________________________________________________

13. Summary of Circumstances: Use this space to provide a brief summary of the circumstances leading to the
action, allegation(s), finding(s) and disposition(s), if any. Include any relevant information on the current
action status, and on any terms, conditions, and dates not already provided above, and any other relevant
information. The information must fit within the space provided.
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

52

CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (MA)
CIVIL JUDICIAL ACTION DRP – PART 1
This Disclosure Reporting Page (DRP MA) is an
INITIAL OR
details for affirmative responses to Item 9-H. of Form MA.
Check item(s) being responded to:

9-H(1)(a)

9-H(1)(b)

AMENDED response used to report

9-H(1)(c)

9-H(2)

How to Report an Event or Proceeding on a Civil Judicial Action DRP: 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.
One event may result in more than one affirmative answer to Item 9-H. Separate cases arising out of the same
event, and unrelated civil judicial actions, must be reported on separate DRPs; if they are later consolidated into a
single civil judicial action, the consolidated action can be reported on one DRP.
Check all that apply, except where noted:
A. The person(s) or entity(ies) for whom this DRP is being filed is (are) the:
Select only one.
Applicant (the municipal advisory firm)
Applicant and one or more of the applicant’s associated person(s)
One or more of applicant’s associated person(s)
1. Applicant
(a) Is this DRP an amendment filed for the applicant that seeks to remove a previously filed DRP
concerning the applicant from the record?
Yes
No
(b) If “Yes,” the reason the DRP should be removed is:
The applicant is registered or applying for registration and the event or proceeding was resolved in
the applicant’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
2. Associated Person(s)
(a) Is this DRP being filed for one or more associated persons?

Yes

No

(i) If “Yes,” indicate the total number of such associated person(s): ___
(b) Identify each such associated firm and/or natural person in the space below:
Firm
Full name of the associated person:
______________________________________________________

The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC
CRD No., if any: ____________________
Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________
Provide the information for each additional firm below:
_______________________________________________
_______________________________________________

Natural Person
Full name of the associated person:
Enter all the letters of each name and not initials or other abbreviations.
If no middle name, enter NMN on that line.
_______________ _______________
Last Name
First Name

_______________
Middle Name

_________
Suffix

The associated person is:
registered with the SEC
SEC Registration No. ____________
not registered with the SEC
CRD No., if any: ____________________
Is this DRP an amendment that seeks to remove a previously filed DRP concerning this associated
person?
Yes
No
If “Yes,” the reason the DRP should be removed is:
The associated person(s) is no longer associated with the advisor.
The event or proceeding was resolved in the associated person’s favor.
The DRP was filed in error. Explain the circumstances:
_______________________________________________________________________
_______________________________________________________________________

54

Provide the information for each additional natural person below:
________________________________________________________

_______________________________________________

B. DRP filed elsewhere for this event: Is an accurate and up-to-date DRP containing the information regarding
the applicant or associated person required by this DRP already on file (a) in the IARD or CRD system (with a
Form ADV, BD, or U4), or (b) in the SEC’s EDGAR system (with a Form MA or Form MA-I)?
Yes
If the answer is “Yes,” provide the applicable information indicated below that identifies where the DRP
may be found.
1. Form ADV, BD, or U4 Filing: For a DRP filed on the IARD or CRD system with one of these
forms, provide the following information:
Name on Registration: _________________________________________________
CRD No.: __________________ Disclosure Occurrence No.: ___________________
2. Form MA Filing: For a DRP filed on EDGAR with a Form MA, provide the following
information:
Name on Registration: _________________________________________________
MA Registration Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
3. Form MA-I Filing: For a DRP filed on EDGAR with a Form MA-I, provide the following
information:
Name of Individual: _________________________________________________
MA-I File Number: __________________
Date of filing that contains the DRP (MM/DD/YYYY): _________________
Accession number of the filing: ________________________
No
If the answer is “Yes,” no other information on this DRP (other than set forth above) must be provided.
If the answer is “No,” complete Part 2 below.
NOTE: The completion of all or any part of this form does not relieve the municipal advisor or
associated person of its obligation to update its IARD or CRD records.

55

CIVIL JUDICIAL ACTION DRP – PART 2
1. Court Action was initiated by:
A. Select the Appropriate Item(s).
Check all that apply.
SEC
CFTC
Other Federal Authority

State
SRO
Commodities Exchange

Foreign Financial Regulatory Authority
Municipal Advisory Firm
Private Plaintiff

Other: _______________________________
B. Plaintiff(s): Enter the full name(s) of the plaintiff(s), unless only SEC and/or CFTC is/are checked
above. For a foreign financial regulatory authority, please provide the full name in English.
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
Were all plaintiffs fully identified in the space provided?

Yes

No

2. Defendant(s):
A. Enter the full name(s) of the defendant(s). For foreign defendant(s), please provide the full name(s) in
English:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
B. Are you a named defendant?
Yes
No
If “No,” describe how this action involves you:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
3. Sanction(s) or Relief Sought (check appropriate items):
Bar (Permanent)
Bar (Temporary / Time Limited)
Cease and Desist
Censure
Civil /Administrative Penalty(ies)/Fine(s)
Denial
Disgorgement

Exemption
Expulsion
Injunction
Money Damage(s)
(Private/Civil Complaint)
Prohibition
Reprimand

56

Rescission
Restitution
Restraining Order
Requalification
Revocation
Suspension
Undertaking

Other Sanction(s) or Relief Sought:
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
4. A. Filing Date of Court Action (MM/DD/YYYY): ____________________
Exact

Explanation

If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
B. Date Notice/Process was served (MM/DD/YYYY): _________________
Exact

Explanation

If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
5. Formal Action was brought in (If brought in a foreign jurisdiction, provide all the information below in
English):
Check the applicable box:
Federal Court

Military Court

State Court

Foreign Court

International Court

Other : ___________________________
A. Name of the Court:______________________________________________________________
B. Location of the Court
Street Address: _______________________________________________________________
City or County: ______________________ State/Country: ________________________
Postal Code: __________________
C. Docket/Case Number and Case Name:______________________________
6. A. Principal Product Type (check appropriate item):
No Product
Annuity – Charitable
Annuity – Fixed
Annuity – Variable
Banking Product
(other than CD)

Direct Investment – DPP & LP Interest
Equipment Leasing
Equity Listed (Common & Preferred Stock)
Equity OTC
Futures – Commodity

57

Oil & Gas
Options
Penny Stock
Prime Bank Instrument
Promissory Note

CD
Commodity Option
Debt – Asset Backed
Debt – Corporate
Debt – Government
Debt – Municipal
Derivative

Futures – Financial
Index Option
Insurance
Investment Contract
Money Market Fund
Mutual Fund

Real Estate Security
Security Futures
Security-based Swap
Swap
Unit Investment Trust
Viatical Settlement

Other Principal Product Type (specify):
___________________________________________________________________________________
B. Other Product Types?
Yes
No
If “Yes,” describe each additional product type:
___________________________________________________________________________________
___________________________________________________________________________________
7. Allegations: Describe the allegations related to this civil action. (The response must fit within the space
provided.)
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
8. Current Status:

Pending

On Appeal

Final

9. Pending: If you checked Item 8 Pending, provide the following information.
A. Date Served: The date that notice or other process was served (MM/DD/YYYY): _______________
Exact
Explanation
If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
B. Limitation or Restrictions: Are there any limitations or restrictions currently in effect?
Yes
No
If the answer is “Yes,” provide details:
___________________________________________________________________________________
___________________________________________________________________________________
10. On Appeal – Judicial Review: If you appealed, provide the following information.
(If brought in a foreign jurisdiction, provide all the information below in English):
A. Action Appealed to: (Provide the name of the federal, state, foreign, or international court to whom you
appealed.) __________________________________________________________________________
B. Location of the Court:
Street Address: ____________________________________________________________
City or County: ______________________ State/Country: ______________________
Postal Code: __________________

58

C.Docket/Case Name: _______________
D.Docket/Case Number: _______________
E. Date Appeal filed (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
___________________________________________________________________________________
___________________________________________________________________________________
F. Appeal Details (including status):
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
G. Limitation or Restrictions: Are there any limitations or restrictions currently in effect while on appeal?
Yes

No

If the answer is “Yes,” provide details:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
If you checked Item 8 Final or On Appeal, complete Items 11 through 14.
For Pending Actions, skip to Item 14.
11. A. Resolution: How was the action resolved? Check all the applicable boxes that reflect the most recent
resolution of the action by a court, whether or not any part of the resolution is on appeal. If any part of
the resolution is on appeal, identify in Item 11-B which part is currently on appeal.
Consent
Decision
Decision & Order of Offer of Settlement
Dismissed

Judgment Rendered
Opinion
Order
Settled

Stipulation and Consent
Withdrawn

Other: _______________________
Appealed
Affirmed
Vacated Nunc Pro Tunc / ab initio
Vacated & Returned For Further Action
Vacated / Final
Other: _______________________
B. Explanation: If more than one box in Item 11-A is checked or Item 11-A otherwise does not adequately
summarize the type of resolution, provide an explanation. For example, if you appealed all or part of a
resolution by the regulator or court, indicate what is being appealed.
___________________________________________________________________________________
___________________________________________________________________________________

59

C. Order: If Order is checked above in Item 11-A, does the order constitute a final order based on violations
of any laws or regulations that prohibit fraudulent, or deceptive conduct?
Yes
No
12. Resolution Date (MM/DD/YYYY):____________________
Exact
Explanation
(For a resolution that is being appealed in part, the date to be provided should be the date on which the
regulator or court provided its resolution.)
If not exact, provide explanation:
____________________________________________________________________________________
____________________________________________________________________________________
13. Resolution Detail
A. Sanction(s): Were any Sanctions Ordered or Relief Granted?
Yes
No, none were ordered, or granted.
B. If “Yes,” check each individual sanction ordered and/or relief granted below:
Bar (Permanent)
Bar (Temporary / Time Limited)
Cease and Desist
Censure
Civil /Administrative Penalty(ies)/Fine(s)*
Denial
Disgorgement*

Exemption
Expulsion
Injunction
Money Damage(s)
(Private/Civil Complaint)*
Prohibition
Reprimand

Rescission
Restitution*
Restraining Order
Requalification
Revocation
Suspension
Undertaking

* Monetary Sanction(s): Were one or more sanctions ordered that require a monetary payment?
Yes
No
If “Yes,” enter the total amount ordered: $_____________
Other Sanctions Ordered or Relief Granted (list each such additional sanction or relief):
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
C. Sanction Detail (Provide the details of the following specific sanctions, if checked above in Item 13-B.)
(1) Barred, Enjoined, or Suspended: If you checked one or more of these sanctions in Item 13-B. above,
check the applicable box(es) below and provide the corresponding information.
(a) Barred
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

60

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
________________________________________________________________________
________________________________________________________________________
(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_____________________________________________________________________
_____________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more bars
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:

_____________________________________________________________________

________________________________________________________________
(b) Enjoined
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
_____________________________________________________________________
_____________________________________________________________________
(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_____________________________________________________________________
_____________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________

61

If the applicant or an associated person received in the above action one or more injunctions
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:
________________________________________________________________________
________________________________________________________________________

(c) Suspended
(i) Duration (length of time):
Permanent (not limited by length of time).
Temporary / Time Limited. Specify the:

Days ___

(ii) Start Date (MM/DD/YYYY): ______________

Months ___

Exact

Years ___

Explanation

If not exact, provide explanation:
_____________________________________________________________________
_____________________________________________________________________
(iii) End Date (MM/DD/YYYY): ______________

Exact

Explanation

If not exact, provide explanation:
_____________________________________________________________________
_____________________________________________________________________
(iv) Description: Provide remaining details and the registration capacities affected (General
Securities Principal, Financial Operations Principal, etc.). If none, enter “None”:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more suspensions
from registration capacities, associations, and/or other activities; and the terms specify
different time periods; report the additional details below:
_______________________________________________________________________________
_______________________________________________________________________________

(2) Requalification: Was requalification by examination, retraining, or other process a condition of a
sanction?
Yes
No
If “Yes,” provide:
(a) Length of time given to requalify, retrain, or complete other process:
No time period is specified.
Time period is specified:
Days ___

Months ___

Years ___

(b) Type of examination, retraining, or other process required:
_____________________________________________________________________________

62

(c) Was the condition satisfied?

Yes

No

(1) If “Yes,” provide the date (MM/DD/YYYY): ______________
(2) If “No,” explain the circumstances:
_________________________________________________________________________
_________________________________________________________________________
If the applicant or an associated person received in the above action one or more
requalifications in connection with registration capacities, associations, and/or other activities;
and the terms specify different time periods; report the additional details below:
_____________________________________________________________________
_____________________________________________________________________

(3) Monetary Sanction(s): If you indicated in Item 13-B above that one or more monetary sanctions were
ordered, provide the following information.
(a)

Total Amount Ordered: $___________

(b) Portion levied against:
Applicant
(i) Amount Ordered:

$___________

(ii) Was any portion waived?
Yes
No
If “Yes,” how much?
(iii) Final Amount:

$___________
$___________

(iv) Was final amount paid in full?
Yes ______
No
If “Yes,” date paid in full (MM/DD/YYYY):___________
If “No,” explain the circumstances:
______________________________________________________________________
______________________________________________________________________
Associated Person
(i) Amount Ordered:

$___________

(ii) Was any portion waived?
Yes
No
If “Yes,” how much?

$___________

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(iii) Final Amount:

$___________

(iv) Was final amount paid in full?
Yes
No
If “Yes,” date paid in full (MM/DD/YYYY):____________
If “No,” explain the circumstances:
______________________________________________________________________
______________________________________________________________________
Provide the information for each additional associated person below:
___________________________________________________________
___________________________________________________________

14. Summary of Circumstances: Use this space to provide a brief summary of the circumstances leading to the
action, allegation(s), finding(s) and disposition(s), if any. Include any relevant information on the current
action status, and on any terms, conditions, and dates not already provided above, and any other relevant
information. The information must fit within the space provided.
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________
_______________________________________________________________________________________

64

Form MA
APPLICATION FOR MUNICIPAL ADVISOR REGISTRATION
DOMESTIC MUNICIPAL ADVISOR EXECUTION
You must complete the following execution page to Form MA. This execution page must be signed and attached to
your initial application for SEC registration and all amendments to registration.

Appointment of Agent for Service of Process
By signing this Form MA, you, the undersigned advisor, 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, as your agents to
receive service, and agree that such persons may be served any process, pleadings, subpoenas, or other papers in (a) any
investigation or administrative proceeding conducted by the Commission that relates to the applicant or about which the
applicant may have information; and (b) any civil suit or action brought against the applicant or to which the applicant
has been joined as defendant or respondent, in any appropriate court in any place subject to the jurisdiction of any state
or of the United States of America or of any of its territories or possessions or of the District of Columbia, where the
investigation, proceeding or cause of action arises out of or relates to or concerns municipal advisory activities of the
municipal advisor. The applicant stipulates and agrees that any such civil suit or action or administrative proceeding
may be commenced by the service of process upon, and that service of an administrative subpoena shall be effected by
service upon the above-named Agent for Service of Process, and that service as aforesaid shall be taken and held in all
courts and administrative tribunals to be valid and binding as if personal service thereof had been made.

Signature
I, the undersigned, sign this Form MA on behalf of, and with the authority of, the municipal advisor. The municipal
advisor 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 Form MA, including exhibits and any other information submitted, are true and correct, and
that I am signing this Form MA as a free and voluntary act.
I certify that the advisor’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
regulatory representatives.

Signature: __________________

Date: ____________________

Printed Name: _______________

Advisor CRD Number (if any): _______________

Title: _________________

Form MA
APPLICATION FOR MUNICIPAL ADVISOR REGISTRATION
NON-RESIDENT MUNICIPAL ADVISOR EXECUTION
Instructions: If you are a non-resident, you must complete these steps:
1.

Execution Page: You must complete the following non-resident execution page to Form MA. This execution
page must be signed and attached to your initial application for SEC registration and all amendments to registration.

2.

Opinion of Counsel: You must also attach to Form MA an Opinion of Counsel. See General Instructions.

3.

Form MA-NR: You must also attach to Form MA one or more executed Form MA-NR(s) for the non-resident
municipal advisor applicant, and, if any, the non-resident general partner(s) and/or non-resident managing agents.
See General Instructions for Form MA-NR.

Non-Resident Municipal Advisor Undertaking Regarding Books and Records
By signing this Form MA, you 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 by law. 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 MA on behalf of, and with the authority of, the non-resident municipal advisor. The
municipal advisor 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 Form MA, including exhibits and any other information submitted, are true and
correct, and that I am signing this Form MA as a free and voluntary act.
I certify that the municipal advisor’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 regulatory representatives. Further, attached to this Form MA as an exhibit is an opinion of counsel that the
municipal advisor can, as a matter of law, provide the Commission with access to the books and records of such
municipal advisor, as required by law, and that the municipal advisor can, as a matter of law, submit to inspection and
examination by the Commission. Finally, attached to this Form MA is one or more executed Form MA-NR(s) for the
non-resident municipal advisor applicant, and, if any, the non-resident general partner(s) and/or non-resident managing
agents.

Signature: __________________

Date: ____________________

Printed Name: ________________

Advisor CRD Number (if any): _______________

Title: _________________

66