Item 1 Identifying Information
A. Full Legal Name of the Firm
(1) Firm Name:
PFM FINANCIAL ADVISORS LLC�
Organization CRD No.,if any:
(2) Sole Proprietor: If the applicant is a sole proprietor, check here, and provide full last name, first name, middle name, and suffix, if any:
Yes No
(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.
Yes No
�
(specify)
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.
Yes No
(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.
Yes No
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(3) Additional Names:�
(a) Is municipal advisor-related business conducted under any additional names?�
Yes No
(b) List any additional names on Section 1-B of Schedule D.
C. (1) IRS Employer Identification Number:
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 checked, 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.:
Investment Adviser
SEC -Registered
SEC File No.:
Exempt Reporting Adviser
SEC File No.:
Registered in US State or Other US Jurisdiction
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, enter the organization CRD Number above. In the table below, select each US state or jurisdiction in which the predecessor municipal advisory firm is so registered.
Check All That Apply:
US State or Jurisdiction
(Code)
US State or Jurisdiction
(Code)
District of Columbia
(DC)
Government Securities Broker-Dealer�
SEC File No.:
Other SEC Registration
(Specify):
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Another federal or state regulator(Specify):
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Registration No. (if any):
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(3) Additional Registrations:
(a) Does the applicant have any additional registrations that are not listed in subsection (2)?
Yes No
(b) List any such additional registrations onSection 1-D of Schedule D.
E. Principal Office and Place of Business
(1) Address:�Do not use a P.O. Box.
Street Address 1:
1735 MARKET STREET�
Street Address 2:
42nd FLOOR�
State/Country:
PENNSYLVANIA �
Telephone Number at this location:
215-567-6100�
Fax Number (if any) at this location:
215-567-4180�
For non-US telephone and fax numbers, include country code with area code and local number.
Is this address a private residence? A private residential address will not be included in publicly available versions of this registration form.
Yes No
(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.
(3) Mailing Address: Is the mailing address different from principal office and place of business address in Item 1-E(1)?
Yes No
If "Yes," complete this item.
Is this address a private residence? A private residential address will not be included in publicly available versions of this registration form.
Yes No
F. Website
(1) Provide the address of the applicant's principal website (if any):�
(2) Does the applicant have any additional websites?�
Yes No
(3) Total number of additional websites
(specify)
(4) 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 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.
Street Address 1:
1735 MARKET STREET�
Street Address 2:
42nd FLOOR�
State/Country:
PENNSYLVANIA �
For non-US telephone and fax numbers, include country code with area code and local number.
Telephone Number:
215-567-6100�
Fax Number:
215-567-4180�
E-mail Address of Chief Compliance Officer:
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., 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.
Street Address 1:
1735 MARKET STREET�
Street Address 2:
42ND FLOOR�
State/Country:
PENNSYLVANIA �
For non-US telephone and fax numbers, include country code with area code and local number.
Telephone Number:
215-567-6100�
Fax Number:
215-567-4180�
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
(1) 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
(2) 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 entities?
Yes No
(2) If "Yes," provide the names of all such affiliates and any applicable registrations in Section 1-K of Schedule D .
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)
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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 U.S. 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
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 Form MA included in the General Instructions.
Yes No
If "Yes" enter the Date of Succession:
B. If "Yes," in Item 3.A., complete Section 3 of Schedule D.
If "Yes," in Item 3.A., complete Section 3 of Schedule D.
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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? (If none, enter a zero. Count a firm only once; do not count each of the firm's employees that solicits on the applicant's behalf.)
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
(2) 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) Municipal Entities
(2) Non-profit organizations (e.g., 501(c)(3) organizations) who are obligated persons
(3) Corporations or other businesses not listed above who are obligated persons
(4) Other: (specify)
(5) 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)
Municipal Entities:
If none, enter a zero.
(2)
Obligated Persons:
If none, enter a zero
(3) Total:
H. Types of Persons Solicited
The applicant solicits the following types of persons:
Check all that apply.
(1) Public pension funds
(2) 529 Plans
(3) Local government investment pools
(4) State government investment pools
(5) Hospitals
(6) Colleges
(7) Other: (specify)
(8) Not applicable - applicant only serves clients; does not engage in solicitation in the context of its municipal advisory activities
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) Hourly charges
(2) Fixed fees (not contingent on the issuance of municipal securities)
(3) Contingent fees
(4) Subscription fees (for a newsletter or other publications)
(5) Other: (specify)
(6) 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) Hourly charges
(2) Fixed fees (not contingent on the success of solicitations)
(3) Contingent fees
(4) Subscription fees (for a newsletter or other publications)
(5) Other: (specify)
(6) 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?
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) 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)
(2) 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)
(3) Advice concerning municipal escrow investments (including, without limitation, advice concerning their structure, timing, terms and other similar matters)
(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)
FINANCIAL PLANNING�
Item 5 Other Business Activities
A. Applicant is actively engaged in business in or as a:
�
Is Applicant Actively Engaged?
Check all that apply.
Is this Applicant's Primary Business(es)?
Check all that apply.
1. Broker-dealer, municipal securities dealer or government securities broker or dealer
2. Registered representative of a broker-dealer
3. Commodity pool operator (whether registered or exempt from registration)
4. Commodity trading advisor (whether registered or exempt from registration)
5. Futures commission merchant
6. Major swap participant
7. Major security-based swap participant
8. Swap dealer
9. Security-based swap dealer
10. Trust company
11. Real estate broker, dealer, or agent
12. Insurance company, broker, or agent
13. Banking or thrift institution (including a separately identifiable department or division of a bank)
14. Investment adviser (including financial planners)
15. Attorney or law firm (Jurisdiction(s) where licensed)
Jurisdiction(s) where licensed (specify)
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16. Accountant or accounting firm (Jurisdiction(s) where licensed)
Jurisdiction(s) where licensed (specify)
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17. Engineer or engineering firm
Jurisdiction(s) where licensed
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18. Other financial product advisor
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 adviser, check both boxes (4) and (5) below.
(1) Broker-dealer, municipal securities dealer, or government securities broker or dealer
(2) Investment company (including mutual funds)
(3) Investment adviser (including financial planners)
(4) Swap dealer
(5) Security-based swap dealer
(6) Major swap participant
(7) Major security-based swap participant
(8) Commodity pool operator (whether registered or exempt from registration)
(9) Commodity trading advisor (whether registered or exempt from registration)
(10) Futures commission merchant
(11) Banking or thrift institution
(12) Trust company
(13) Accountant or accounting firm
(14) Attorney or law firm
(15) Insurance company or agency
(16) Pension consultant
(17) Real estate broker or dealer
(18) Sponsor or syndicator of limited partnerships
(19) Engineer or engineering firm
(20) Other municipal advisor
Total Associated Persons:
Provide the total number of 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 (zero).
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
(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 No
(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
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 No
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.
(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 ifthe 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 No
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:
(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 advisor-related 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
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:
(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 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 advisor-related 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 advisor-related 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 advisor-related or investment-related activity?
Yes No
(5) denied, suspended, or revoked the registration or license of the applicant or that of any associated 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
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
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.
DANIEL HARTMAN�
Signature:
Date:
DANIEL HARTMAN�
Printed Name:
Advisor CRD Number (if any):
CHIEF EXECUTIVE OFFICER, MANAGING DIRECTOR�
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 as an exhibit 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.�
Advisor CRD Number (if any):
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.
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.
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: AddDelete Amend
Street Address 1:
Street Address 2:
City:
State/Country:
PENNSYLVANIA �
Is this address a private residence?
A private residential address will not be included in publicly available versions of this registration form.
Telephone number at this location:
Fax number (if any) a this location:
Select only one: AddDelete Amend
Street Address 1:
Street Address 2:
City:
State/Country:
MICHIGAN �
Is this address a private residence?
A private residential address will not be included in publicly available versions of this registration form.
Telephone number at this location:
Fax number (if any) a this location:
Select only one: AddDelete Amend
Street Address 1:
Street Address 2:
City:
State/Country:
MINNESOTA �
Is this address a private residence?
A private residential address will not be included in publicly available versions of this registration form.
Telephone number at this location:
Fax number (if any) a this location:
Select only one: AddDelete Amend
Street Address 1:
Street Address 2:
City:
State/Country:
VIRGINIA �
Is this address a private residence?
A private residential address will not be included in publicly available versions of this registration form.
Telephone number at this location:
Fax number (if any) a this location:
Select only one: AddDelete Amend
Street Address 1:
Street Address 2:
City:
State/Country:
FLORIDA �
Is this address a private residence?
A private residential address will not be included in publicly available versions of this registration form.
Telephone number at this location:
Fax number (if any) a this location:
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.
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: AddDelete Amend
Name of entity where books and records are kept:
PFM FINANCIAL ADVISORS LLC
Street Address 1:
Street Address 2:
City:
State/Country:
PENNSYLVANIA �
Is this address a private residence?
Telephone number at this location:
Fax number (if any) at this location:
For non-US telephone and fax numbers, include country code with area code and local number.
This is (Select only one):
one of applicant's branch offices or affiliates.
a third-party unaffiliated record keeper.
Other
Briefly describe the books and records kept at the location(s) you checked. If you checked "other," describe additionally all such location(s).
In accordance with MSRB Rules G-8 and G-9, books are records are inclusive of, but not limited to customer account information, written communications, client contracts, and information concerning customer complaints.�
Select only one: AddDelete Amend
Name of entity where books and records are kept:
PFM FINANCIAL ADVISORS LLC
Street Address 1:
Street Address 2:
City:
State/Country:
MICHIGAN �
Is this address a private residence?
Telephone number at this location:
Fax number (if any) at this location:
For non-US telephone and fax numbers, include country code with area code and local number.
This is (Select only one):
one of applicant's branch offices or affiliates.
a third-party unaffiliated record keeper.
Other
Briefly describe the books and records kept at the location(s) you checked. If you checked "other," describe additionally all such location(s).
In accordance with MSRB Rules G-8 and G-9, books are records are inclusive of, but not limited to customer account information, written communications, client contracts, and information concerning customer complaints.�
Select only one: AddDelete Amend
Name of entity where books and records are kept:
PFM FINANCIAL ADVISORS LLC
Street Address 1:
Street Address 2:
City:
State/Country:
MINNESOTA �
Is this address a private residence?
Telephone number at this location:
Fax number (if any) at this location:
For non-US telephone and fax numbers, include country code with area code and local number.
This is (Select only one):
one of applicant's branch offices or affiliates.
a third-party unaffiliated record keeper.
Other
Briefly describe the books and records kept at the location(s) you checked. If you checked "other," describe additionally all such location(s).
In accordance with MSRB Rules G-8 and G-9, books are records are inclusive of, but not limited to customer account information, written communications, client contracts, and information concerning customer complaints.�
Select only one: AddDelete Amend
Name of entity where books and records are kept:
PFM FINANCIAL ADVISORS LLC
Street Address 1:
Street Address 2:
City:
State/Country:
VIRGINIA �
Is this address a private residence?
Telephone number at this location:
Fax number (if any) at this location:
For non-US telephone and fax numbers, include country code with area code and local number.
This is (Select only one):
one of applicant's branch offices or affiliates.
a third-party unaffiliated record keeper.
Other
Briefly describe the books and records kept at the location(s) you checked. If you checked "other," describe additionally all such location(s).
In accordance with MSRB Rules G-8 and G-9, books are records are inclusive of, but not limited to customer account information, written communications, client contracts, and information concerning customer complaints.�
Select only one: AddDelete Amend
Name of entity where books and records are kept:
PFM FINANCIAL ADVISORS LLC
Street Address 1:
Street Address 2:
City:
State/Country:
FLORIDA �
Is this address a private residence?
Telephone number at this location:
Fax number (if any) at this location:
For non-US telephone and fax numbers, include country code with area code and local number.
This is (Select only one):
one of applicant's branch offices or affiliates.
a third-party unaffiliated record keeper.
Other
Briefly describe the books and records kept at the location(s) you checked. If you checked "other," describe additionally all such location(s).
In accordance with MSRB Rules G-8 and G-9, books are records are inclusive of, but not limited to customer account information, written communications, client contracts, and information concerning customer complaints.�
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.
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:
PFM SWAP ADVISORS LLC
1. Does the affiliate have an applicable federal, state, or foreign registration?
Yes No
2. Provide the following details:
(a) Name of Agency Issuing Registration (in English):
COMMODITIES FUTURES TRADING COMMISSION/NATIONAL FUTURES ASSOCIATION (NFA); MUNICIPAL SECURITIES RULEMAKING BOARD/SECURITY EXCHANGE COMMISSION (SEC)
(b) Registration No., if any:
CTFC/NFA - 0474395; MSRB/SEC - 867-001139
(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:
(specify):
�
Foreign Country Name (in English):
(specify):
�
Name of Affiliate:
PFM SOLUTIONS LLC
1. Does the affiliate have an applicable federal, state, or foreign registration?
Yes No
2. Provide the following details:
(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:
(specify):
�
Foreign Country Name (in English):
(specify):
�
Name of Affiliate:
PFM GROUP CONSULTING LLC
1. Does the affiliate have an applicable federal, state, or foreign registration?
Yes No
2. Provide the following details:
(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:
(specify):
�
Foreign Country Name (in English):
(specify):
�
Name of Affiliate:
MUNITE LLC
1. Does the affiliate have an applicable federal, state, or foreign registration?
Yes No
2. Provide the following details:
(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:
(specify):
�
Foreign Country Name (in English):
(specify):
�
Name of Affiliate:
PFM CALIFORNIA ADVISORS LLC
1. Does the affiliate have an applicable federal, state, or foreign registration?
Yes No
2. Provide the following details:
(a) Name of Agency Issuing Registration (in English):
MUNICIPAL SECURITIES RULEMAKING BOARD/SECURITIES EXCHANGE COMMISSION
(b) Registration No., if any:
MSRB: K1277 / SEC: 867-02535
(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:
(specify):
�
Foreign Country Name (in English):
(specify):
�
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.
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.
SECTION 4-E Employees That Also Do Business Independently on the Applicant's Behalf as Affiliates of the Applicant
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 6-A. A separate Schedule D must be completed for each such associated person.
Select only one: AddDelete Amend
Legal Name of Associated Person:
PFM SWAP ADVISORS LLC
Primary Business Name of Associated Person:
PFM SWAP ADVISORS LLC
A. Associated person is a: Check all that apply.
(1) Broker-dealer, municipal securities dealer, or government securities broker or dealer
(2) Investment company (including mutual funds)
(3) Investment adviser (including financial planners)
(4) Swap dealer
(5) Security-based swap dealer
(6) Major swap participant
(7) Major security-based swap participant
(8) Commodity pool operator (whether registered or exempt from registration)
(9) Commodity trading advisor (whether registered or exempt from registration)
(10) Futures commission merchant
(11) Banking or thrift institution
(12) Trust company
(13) Accountant or accounting firm
(14) Attorney or law firm
(15) Insurance company or agency
(16) Pension consultant
(17) Real estate broker or dealer
(18) Sponsor or syndicator of limited partnerships
(19) Engineer or engineering firm
(20) Other municipal advisor
B. Control Relationships and Foreign Relations
(1) Control Relationships
(a) Does the applicant control or is it controlled by the associated person? Yes No
(b) Are the applicant and the associated person under common control? Yes No
(2) Foreign Financial Regulatory Authority Registration
(a) Is the associated person registered with a foreign financial regulatory authority? Yes No
(b) List the name, 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.
Select only one: AddDelete Amend
Legal Name of Associated Person:
PFM CALIFORNIA ADVISORS LLC
Primary Business Name of Associated Person:
PFM CALIFORNIA ADVISORS LLC
A. Associated person is a: Check all that apply.
(1) Broker-dealer, municipal securities dealer, or government securities broker or dealer
(2) Investment company (including mutual funds)
(3) Investment adviser (including financial planners)
(4) Swap dealer
(5) Security-based swap dealer
(6) Major swap participant
(7) Major security-based swap participant
(8) Commodity pool operator (whether registered or exempt from registration)
(9) Commodity trading advisor (whether registered or exempt from registration)
(10) Futures commission merchant
(11) Banking or thrift institution
(12) Trust company
(13) Accountant or accounting firm
(14) Attorney or law firm
(15) Insurance company or agency
(16) Pension consultant
(17) Real estate broker or dealer
(18) Sponsor or syndicator of limited partnerships
(19) Engineer or engineering firm
(20) Other municipal advisor
B. Control Relationships and Foreign Relations
(1) Control Relationships
(a) Does the applicant control or is it controlled by the associated person? Yes No
(b) Are the applicant and the associated person under common control? Yes No
(2) Foreign Financial Regulatory Authority Registration
(a) Is the associated person registered with a foreign financial regulatory authority? Yes No
(b) List the name, 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.
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.
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 Sections 12 or 15(d) of the Securities Exchange Act of 1934, provide the information below. A separate Schedule D must be completed for each public reporting company.
Schedule D: MISCELLANEOUS
The space below may be used to explain a response to an Item or to provide any other information.
PFM I - No individual holds more than 10% ownership.�
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP MA) is an INITIALOR AMENDEDresponse 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-C(2) ���
�9-C(3)��
�9-C(4)
�9-C(5)
9-D(1)
9-D(2)
9-D(3)�
�9-D(4)��
�9-D(5)
��9-E(1)�
�9-E(2)�
�9-E(3)��
�9-E(4)
�
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.
REGULATORY ACTION DRP PART 1
Check all that apply, except where noted
A.��� The person(s) or entity(ies) for whom this DRP is being filed is (are) the: ��
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) 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 firm and/or natural person in the space below:
Applicant
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 No
REGULATORY ACTION DRP PART 2
1.�Regulatory Action was initiated by:
A. Select the Appropriate Item. (Select only one. A separate Regulatory Action DRP is required for each such regulator or other authority.)
SEC
State
Foreign Financial Regulatory Authority
CFTC
SRO
Other: (specify)
Federal Banking Agency
National Credit Union Administration
Other Federal Authority
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)
Disgorgement
Restitution
Bar (Temporary / Time Limited)
Expulsion
Requalification
Cease and Desist
Injunction
Revocation
Censure
Prohibition
Suspension
Civil and Administrative Penalty(ies)/Fine(s)
Reprimand
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:
In the Matter of PFM Financial Advisors LLC�
��
B. Location of the Proceeding / Hearing:
Street Address 1
Street Address 2
City or County
DISTRICT OF COLUMBIA �
State/Country
Postal Code
C. Docket/Case Number:
Administrative Proceeding File No. 3-22121 / Securities Exchange Act of 1934 Release No. 101041�
5. A.�Principal Product Type (check appropriate item):
No Product
Annuity - Charitable
Direct Investment - DPP & LP Interest
Oil & Gas
Annuity - Fixed
Equipment Leasing
Options
Annuity - Variable
Equity Listed (Common & Preferred Stock)
Penny Stock
Banking Product
(other than CD)
Equity OTC
Prime Bank Instrument
CD
Futures - Commodity
Promissory Note
Commodity Option
Futures - Financial
Real Estate Security
Debt - Asset Backed
Index Option
Security Futures
Debt - Corporate
Insurance
Security-based Swap
Debt - Government
Investment Contract
Swap
Debt - Municipal
Money Market Fund
Unit Investment Trust
Derivative
Mutual Fund
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.)
Violations of recordkeeping and supervision requirements in connection with unauthorized use of text messaging by certain employees to conduct municipal advisory activities.�
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:�
�
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 1: ��Street Address 2:
City or County:
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 the action was 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)
Dismissed
Stipulation and Consent
Consent
Judgment Rendered
Withdrawn
Decision
Order
Other: (requires explanation)
Decision & Order of Offer of Settlement
Settled
�
Appealed
�������������� Affirmed
�������������� Vacated Nunc Pro Tunc / ab initio
�������������� Vacated & Returned For Further Action
�������������� Vacated / Final
�������������� Other: (requires explanation)
B. Explanation: � (If more than one box in Item 10-A. 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. Sanctions: Were any Sanctions Ordered?� Yes �No
B.��� If "Yes," check each individual sanction below that was ordered:���
Bar (Permanent)
Disgorgement*
Restitution*
Bar (Temporary / Time Limited)
Expulsion
Requalification
Cease and Desist
Injunction
Revocation
Censure
Prohibition
Suspension
Civil and Administrative Penalty(ies)/Monetary Fine(s)*
Reprimand
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 (list each such additional sanction):
C.��� Sanction Detail (Provide the details of the following specific sanctions, if checked above in Item 12-B.)
� (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 �
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 each in a separate entry.
������� ������(i) Duration (length of time):
������� ��������� Permanent (not limited by length of time).
������� ��������� Temporary / Time Limited. Specify the: Days Months
������� ���������������� ���������������� ���������������� ���������������� �������������� Years
������� ������(ii) Start Date (MM/DD/YYYY): � Exact ����� � 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":
�
(b)� Enjoined
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 each in a separate entry.
������� ������(i) Duration (length of time):
������� ��������� Permanent (not limited by length of time)
������� ��������� Temporary / Time Limited. Specify the: Days Months
������� ���������������� ���������������� ���������������� ���������������� �������������� Years
������� ������(ii) Start Date (MM/DD/YYYY): � Exact ����� � 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":
�
(c)� Suspended
If the applicant or an associated person received in the above one or more suspensions from registration capacities, associations, and/or other activities, and the terms specify different time periods, report each in a separate entry.
������� ������(i) Duration (length of time):
������� ��������� Permanent (not limited by length of time)
������� ��������� Temporary / Time Limited. Specify the: Days Months
������� ���������������� ���������������� ���������������� ���������������� �������������� Years
������� ������(ii) Start Date (MM/DD/YYYY): � Exact ����� � 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":
�
(2)�� Requalification:
�� Was requalification by examination, retraining, or other process a condition of a sanction? ������� ���� ������� ���� ������� ���� � YES � NO
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 each in a separate entry.
If "Yes," provide the following details:
� (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:�
�
(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?����� �
��(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.
According to the SEC Order, from at least July 2020 to January 2024, a number of PFMFA employees sent and received off-channel communications in the form of text messages relating to municipal advisory activities. Text messages were not authorized by firm policy. Thus the SEC found that PFMFA violated certain recordkeeping requirements. To settle this civil administrative matter, PFMFA agreed, among other things, to pay a fine of $250,000 and to certain undertakings involving written procedures and employee training.�