Client Disclosures

Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising.

Core Concepts

Form ADV Part 1

Filed electronically via IARD (Investment Adviser Registration Depository). Contains:

• Registration information (SEC, states)
• Form of organization, control persons, and ownership
• Disciplinary history (criminal, regulatory, civil)
• Other business activities and financial industry affiliations
• Custody of client assets
• Participation in client transactions
• AUM and number of clients

Part 1 is publicly available through the SEC's Investment Adviser Public Disclosure (IAPD) website. It is not delivered to clients but is a regulatory filing that must be kept current (annual updating amendment within 90 days of fiscal year end, interim amendments for material changes).