- Inaccurate ADV I and II
In accordance with Commission Rule 830-X-3-.03, if the Form ADV becomes inaccurate for any reason, the
investment adviser shall file an amended Form ADV within 30 days.
- No Audited Balance Sheet
In accordance with Commission Rule 830-X-3-.05(3)(a), annually an audited balance sheet is to be submitted
to the Commission staff within 60 days after the close of the Firm’s fiscal year.
- Inadequate Written Procedures
In accordance with Commission Rule 830-X-3-.13(3)(b), as a part of its responsibility under this rule, every
dealer, issuer or investment adviser shall establish, maintain and enforce written procedures, a copy of which shall
be kept in each business office, which shall set forth the procedures adopted by the dealer, issuer or investment
adviser to comply with the following duties imposed by this rule, and shall state at which business office or offices
the dealer, issuer or investment adviser keeps and maintains the records required by Rules 830-X-3-.16.
- Improper Advertising
In accordance with Commission Rule 830-X-3-.22(1)(e) it is a fraudulent, deceptive or manipulative act, practice
or course of business, within the meaning of the state securities act, for an investment adviser, directly or indirectly,
to publish, circulate or distribute any advertisement which: Contains any untrue statement of a material fact, or omits
to state a material fact necessary in order to make the statements made, in light of the circumstances under which
they are made, not misleading, or which is otherwise false or misleading.
- Failure to Supervise
In accordance with Commission Rule 830-X-3-.13(1), every dealer, issuer or investment adviser, and officers, directors
and partners thereof, shall exercise diligent supervision over all the securities activities of its associated persons.