New York Codes, Rules and Regulations › Title 13 - DEPARTMENT OF LAW › Appendices › Appendix 3

Current through Register Vol. 46, No. 28, July 10, 2024
FORM ADV (Paper Version)
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
PART 1A
WARNING:
Complete this form truthfully. False
				statements or omissions may result in denial of your application, revocation of
				your registration, or criminal prosecution. You must keep this form updated by
				filing periodic amendments. See Form ADV General Instruction 3.
Check the box that indicates what you would like to do (check
				all that apply):
[] Submit an initial application to register as an investment
				adviser with the SEC.
[] Submit an initial application to register as an investment
				adviser with one or more states.
[] Submit an
annual updating amendment
to your
				registration for your fiscal year ended _ ._____________________
[] Submit an other-than-annual amendment to your
				registration.
Item 1 Identifying Information
Responses to this Item tell us who you are, where you are doing
				business, and how we can contact you.
A. Your full legal name (if you are a sole proprietor, your
				last, first, and middle names): ______________________
B. Name under which you primarily conduct your advisory
				business, if different from Item 1.A. ______________________
List on Section 1.B. of Schedule D any additional names
				under which you conduct your advisory business.
C. If this filing is reporting a change in your legal name
				(Item 1.A.) or primary business name (Item 1.B.), enter the new name and
				specify whether the name change is of [] your legal name or [] your primary
				business name: ______________________
D. If you are registered with the SEC as an investment adviser,
				your SEC file number: 801- _____________________
E. If you have a number (
"CRD
Number")
				assigned by the
NASD's CRD
system or by the IARD system, your
CRD
number: ____
If your firm does not have a CRD number, skip this Item 1.E. Do
				not provide the CRD number of one of your officers, employees, or
				affiliates.
FORM ADV
.....................................................................................Your
						  Name _______.. CRD Number _______
Part 1A
..........................................................................................Date
						  _______.. SEC 801-Number ______
Page 2 of 16
F.
Principal Office and Place of
				Business
(1) Address (do not use a P.O. Box):
(number and street)
(city) (state/country) (zip+4/postal code)
If this address is a private residence, check this box:
				[]
List on Section 1.F. of Schedule D any office, other than your
				principal office and place of business, at which you conduct investment
				advisory business. If you are applying for registration, or are registered,
				with one or more state securities authorities, you must list all of your
				offices in the state or states to which you are applying for registration or
				with whom you are registered. If you are applying for registration, or are
				registered only, with the SEC, list the largest five offices in terms of
				numbers of employees.
(2) Days of week that you normally conduct business at your
principal office and place of business:
[] Monday - Friday [] Other:
				___________________________________________________________________
Normal business hours at this location:
				__________________________________________________________
(3) Telephone number at this location: (area code) (telephone
				number)
(4) Facsimile number at this location: (area code) (telephone
				number)
G. Mailing address, if different from your
principal
				office and place of business
address:
(number and street)
(city) (state/country) (zip+4/postal code)
If this address is a private residence, check this box:
				[]
H. If you are a sole proprietor, state your full residence
				address, if different from your
principal office and place of
				business
address in Item 1.F.:
(number and street)
(city) (state/country) (zip+4/postal code)
FORM ADV
.......................................................................................
						  Your Name _______.. CRD Number _______
Part 1A
.............................................................................................
						  Date _______.. SEC 801-Number ______
Page 3 of 16
I. Do you have World Wide Web site addresses? Yes [] No
				[]
If "yes," list these addresses on section 1.I. of Schedule D.
				If a web address serves as a portal through which to access other information
				you have published on the World Wide Web, you may list the portal without
				listing addresses for all of the other information. Some advisers may need to
				list more than one portal address. Do not provide individual electronic mail
				addresses in response to this Item.
J. Contact Employee:
(name)
(title)
(area code) (telephone number) .. (area code) (facsimile
				number)
				.............................................................................................
(number and street)
(city) (state/country) (zip+4/postal code)
(electronic mail (e-mail) address, if contact employee has
				one)
The contact employee should be an employee whom you have
				authorized to receive information and respond to questions about this Form
				ADV.
K. Do you maintain some or all of the books and records you are
				required to keep under Section 204 of the Advisers Act, or similar state law,
				somewhere other than your
principal office and place of
				business
?
Yes [] No []
If "yes," complete Section 1.K. of Schedule D.
L. Are you registered with a
foreign financial
				regulatory authority
? Yes [] No []
Answer "no" if you are not registered with a foreign financial
				regulatory authority, even if you have an affiliate that is registered with a
				foreign financial regulatory authority. If "yes," complete Section 1.L. of
				Schedule D.
FORM ADV
.......................................................................................
						  Your Name _______ .. CRD Number _______
Part 1A
.............................................................................................
						  Date _______.. SEC 801-Number ______
Page 4 of 16
Item 2 SEC Registration
Responses to this Item help us (and you) determine whether you
				are eligible to register with the SEC. Complete this Item 2 only if you are
				applying for SEC registration or submitting an
annual updating
				amendment
to your SEC registration.
A. To register (or remain registered) with the SEC, you must
				check at least one of the Items 2.A(1) through 2.A(10), below. If you are
				submitting an
annual updating amendment
to your SEC
				registration and you are no longer eligible to register with the SEC, check
				Item 2.A(11). You:
[] (1) have
assets under management
of $25
				million (in U.S. dollars) or more;
See Part 1A Instruction 2.a. to determine whether you should
				check this box.
[] (2) have your
principal office and place of
				business
in the U.S. Virgin Islands or Wyoming;
[] (3) have your
principal office and place of
				business
outside the United States;
[] (4) are an investment adviser (or sub-adviser) to an
				investment company registered under the Investment Company Act of 1940;
See Part 1A Instruction 2.b. to determine whether you should
				check this box.
[] (5) have been designated as a nationally recognized
				statistical rating organization;
See Part 1A Instruction 2.c. to determine whether you should
				check this box.
[] (6) are a pension consultant that qualifies for the
				exemption in rule 203A-2(b);
See Part 1A Instruction 2.d. to determine whether you should
				check this box.
[] (7) are relying on rule 203A-2(c) because you are an
				investment adviser that
controls,
is
controlled
by, or is under common
control
with, an investment adviser that is registered with the SEC, and your
principal office and place of business
is the same as the
				registered adviser;
See Part 1A Instruction 2.e. to determine whether you should
				check this box. If you check this box, complete section 2.A(7) of Schedule
				D.
[] (8) are a newly formed adviser relying on rule 203A-2(d)
				because you expect to be eligible for SEC registration within 120 days;
See Part 1A Instruction 2.f. to determine whether you should
				check this box. If you check this box, complete section 2.A(8) of Schedule
				D.
FORM ADV
................................................................................
						  Your Name _______.. CRD Number _______
Part 1A
......................................................................................
						  Date _______.. SEC 801-Number ______
Page 5 of 16
[] (9) are a multi-state adviser relying on rule
				203A-2(e);
See Part 1A Instruction 2.g. to determine whether you should
				check this box. If you check this box, complete Section 2.A(9) of Schedule
				D.
[] (10) have received an SEC
order
exempting
				you from the prohibition against registration with the SEC;
If you check this box, complete Section 2.A(10) of Schedule
				D.
[] (11) are no longer eligible to remain registered with the
				SEC.
See Part 1A Instruction 2.h. to determine whether you should
				check this box.
B. Under state laws, SEC-registered advisers may be required to
				provide to state securities authorities a copy of the Form ADV and any
				amendments they file with the SEC. These are called
notice
				filings.
If this is an initial application, check the box(es) next to
				the state(s) that you would like to receive notice of this and all subsequent
				filings you submit to the SEC. If this is an amendment to direct your
notice filings
to additional state(s), check and circle the
				box(es) next to the state(s) that you would like to receive notice of this and
				all subsequent filings you submit to the SEC. If this is an amendment to your
				registration to stop your
notice filings
from going to
				state(s) that currently receive them, circle the unchecked box(es) next to
				those state(s).
[] AL [] CT [] HI [] KY [] MN [] NH [] OH [] SC [] VA
[] AK [] DE [] ID [] LA [] MS [] NJ [] OK [] SD [] WA
[] AZ [] DC [] IL [] ME [] MO [] NM [] OR [] TN [] WV
[] AR [] FL [] IN [] MD [] MT [] NY [] PA [] TX [] WI
[] CA [] GA [] IA [] MA [] NE [] NC [] PR [] UT
[] CO [] GU [] KS [] MI [] NV [] ND [] RI [] VT
If you are amending your registration to stop your notice
				filings from going to a state that currently receives them and you do not want
				to pay that state's notice filing fee for the coming year, your amendment must
				be filed before the end of the year (December 31).
Item 3 Form of Organization
A. How are you organized?
[] Corporation [] Sole Proprietorship [] Limited Liability
				Partnership (LLP)
[] Partnership [] Limited Liability Company (LLC)
[] Other (specify):
				___________________________________________________________________________
If you are changing your response to this Item, see Part 1A
				Instruction 4.
B. In what month does your fiscal year end each year?
				_______________________________________________
FORM ADV
...................................................................................
						  Your Name _______.. CRD Number _______
Part 1A
.........................................................................................
						  Date _______.. SEC 801-Number ______
Page 6 of 16
C. Under the laws of what state or country are you organized?
				_______
If you are a partnership, provide the name of the state or
				country under whose laws your partnership was formed. If you are a sole
				proprietor, provide the name of the state or country where you reside.
If you are changing your response to this Item, see Part 1A
				Instruction 4.
Item 4 Successions
A. Are you, at the time of this filing, succeeding to the
				business of a registered investment adviser?
[] Yes .. [] No
				...........................................................................................................................................................................
If "yes," complete Item 4.B. and Section 4 of Schedule
				D.
B. Date of Succession: (mm/dd/yyyy)
If you have already reported this succession on a previous Form
				ADV filing, do not report the succession again. Instead, check "No." See Part
				1A Instruction 4.
Item 5 Information About Your Advisory Business
Responses to this Item help us understand your business, assist
				us in preparing for on-site examinations, and provide us with data we use when
				making regulatory policy. Part 1A Instruction 5.a. provides additional guidance
				to newly-formed advisers for completing this Item 5.
Employees
A. Approximately how many
employees
do you
				have? Include full and part-time
employees
but do not include
				any clerical workers.
[] 1-5 [] 6-10 [] 11-50 [] 51-250 [] 251-500 []
				501-1,000
[] More than 1,000 If more than 1,000, how many? __ (round to
				the nearest 1,000)
B.
(1) Approximately how many of these
employees
perform investment advisory functions (including research)?
[] 0 [] 1-5 [] 6-10 [] 11-50 [] 51-250 [] 251-500 []
				501-1,000
[] More than 1,000 If more than 1,000, how many? __ (round to
				the nearest 1,000)
(2) Approximately how many of these
employees
are registered representatives of a broker- dealer?
[] 0 [] 1-5 [] 6-10 [] 11-50 [] 51-250 [] 251-500 []
				501-1,000
[] More than 1,000 If more than 1,000, how many? __ (round to
				the nearest 1,000)
If you are organized as a sole proprietorship, include yourself
				as an employee in your responses to Items 5.A(1) and 5.B(2). If an employee
				performs more than one function, you should count that employee in each of your
				responses to Item 5.B(1) and 5.B(2).
FORM ADV
................................................................... Your Name
						  _______.. CRD Number _______
Part 1A
.......................................................................... Date
						  _______.. SEC 801-Number ______
Page 7 of 16
(3) Approximately how many firms or other
persons
solicit advisory
clients
on your
				behalf?
[] 0 [] 1-5 [] 6-10 [] 11-50 [] 51-250 [] 251-500 []
				501-1,000
[] More than 1,000 If more than 1,000, how many? __ (round to
				the nearest 1,000)
In your response to Item 5.B(3), do not count any of your
				employees and count a firm only once-do not count each of the firm's employees
				that solicit on your behalf.
Clients
C. To approximately how many
clients
did you
				provide investment advisory services during your most-recently completed fiscal
				year?
[] 0 [] 1-10 [] 11-25 [] 26-100 [] 101-250 [] 251-500
[] More than 500 If more than 500, how many? __ (round to the
				nearest 500)
D. What types of
clients
do you have? Indicate
				the approximate percentage that each type of
client
comprises
				of your total number of
clients.
None
Up to
10%
11-25%
26-50%
51-75%
More Than
75%
(1)
Individuals (other than
high net worth
							 individuals
)
[]
[]
[]
[]
[]
[]
(2)
High net worth
							 individuals
[]
[]
[]
[]
[]
[]
(3)
Banking or thrift institutions
[]
[]
[]
[]
[]
[]
(4)
Investment companies (including mutual
							 funds)
[]
[]
[]
[]
[]
[]
(5)
Pension and profit sharing plans (other than plan
							 participants)
[]
[]
[]
[]
[]
[]
(6)
Other pooled investment vehicles (e.g., hedge
							 funds)
[]
[]
[]
[]
[]
[]
(7)
Charitable organizations
[]
[]
[]
[]
[]
[]
(8)
Corporations or other businesses not listed
							 above
[]
[]
[]
[]
[]
[]
(9)
State or municipal
government
							 entities
[]
[]
[]
[]
[]
[]
(10)
Other: _____
[]
[]
[]
[]
[]
[]
The category "individuals" includes trusts, estates, 401(k)
				plans and IRAs of individuals and their family members, but does not include
				businesses organized as sole proprietorships.
Unless you provide advisory services pursuant to an investment
				advisory contract to an investment company registered under the Investment
				Company Act of 1940, check "None" in response to Item 5.D(4).
FORM ADV
..............................................................................
						  Your Name _______.. CRD Number _______
Part 1A
....................................................................................
						  Date _______.. SEC 801-Number ______
Page 8 of 16
Compensation Arrangements
E. You are compensated for your investment advisory services by
				(check all that apply):
[] (1) A percentage of assets under your management
[] (2) Hourly charges
[] (3) Subscription fees (for a newsletter or
				periodical)
[] (4) Fixed fees (other than subscription fees)
[] (5) Commissions
[] (6)
Performance-based fees
[] (7) Other (specify):
				________________________________________________________________________
Assets Under Management
F. (1) Do you provide continuous and regular supervisory or
				management services to securities portfolios? [] Yes [] No
(2) If yes, what is the amount of your assets under management
				and total number of accounts?
U.S. Dollar
							 Amount
Total Number of
							 Accounts
Discretionary:
(a) $ ________.00
(d) ________
Non-Discretionary:
(b) $ ________.00
(e) ________
Total:
(c) $ ________.00
(f) ________
Part 1A Instruction 5.b. explains how to calculate your assets
				under management. You must follow these instructions carefully when completing
				this Item.
Advisory Activities
G. What type(s) of advisory services do you provide? Check all
				that apply.
[] (1) Financial planning services
[] (2) Portfolio management for individuals and/or small
				businesses
[] (3) Portfolio management for investment companies
[] (4) Portfolio management for businesses or institutional
clients
(other than investment companies)
[] (5) Pension consulting services
[] (6) Selection of other advisers
[] (7) Publication of periodicals or newsletters
[] (8) Security ratings or pricing services
[] (9) Market timing services
[] (10) Other (specify):
				_________________________________________________________________
Do not check item 5.G(3) unless you provide advisory services
				pursuant to an investment advisory contract to an investment company registered
				under the Investment Company Act of 1940.
FORM ADV
.......................................................................... Your
						  Name _______.. CRD Number _______
Part 1A
................................................................................
						  Date _______.. SEC 801-Number ______
Page 9 of 16
H. If you provide financial planning services, to how many
clients
did you provide these services during your last fiscal
				year?
[] 0 [] 1-10 [] 11-25 [] 26-50 [] 51-100 [] 101-250 []
				251-500
[] More than 500 If more than 500, how many? __ (round to the
				nearest 500)
I. If you participate in a
wrap fee program,
do you (check all that apply):
[] (1)
sponsor
the
wrap fee
				program?
[] (2) act as a portfolio manager for the
wrap fee
				program?
If you are a portfolio manager for a wrap fee program, list the
				names of the programs and their sponsors in Section 5.I(2) of Schedule
				D.
If your involvement in a wrap fee program is limited to
				recommending wrap fee programs to your clients, or you advise a mutual fund
				that is offered through a wrap fee program, do not check either Item 5.I(1) or
				5.I(2).
Item 6 Other Business Activities
In this Item, we request information about your other business
				activities.
A. You are actively engaged in business as a (check all that
				apply):
[] (1) Broker-dealer
[] (2) Registered representative of a broker-dealer
[] (3) Futures commission merchant, commodity pool operator, or
				commodity trading advisor
[] (4) Real estate broker, dealer, or agent
[] (5) Insurance broker or agent
[] (6) Bank (including a separately identifiable department or
				division of a bank)
[] (7) Other financial product salesperson (specify):
				_________________________________________________
B. (1) Are you actively engaged in any other business not
				listed in Item 6.A. (other than giving investment advice)? [] Yes [] No
(2) If yes, is this other business your primary business? []
				Yes [] No
If "yes," describe this other business on Section 6.B. of
				Schedule D.
(3) Do you sell products or provide services other than
				investment advice to your advisory
clients?
[] Yes [] No
FORM ADV
..................................................................... Your Name
						  _______.. CRD Number _______
Part 1A
...........................................................................
						  Date _______.. SEC 801-Number ______
Page 10 of 16
Item 7 Financial Industry Affiliations
In this Item, we request information about your financial
				industry affiliations and activities. This information identifies areas in
				which conflicts of interests may occur between you and your
clients.
Item 7 requires you to provide information about you and your
related persons.
Your
related persons
are all
				of your advisory affiliates and any
person
that is under
				common
control
with you.
A. You have a
related person
that 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) other investment adviser (including financial
				planners)
[] (4) futures commission merchant, commodity pool operator, or
				commodity trading advisor
[] (5) banking or thrift institution
[] (6) accountant or accounting firm
[] (7) lawyer or law firm
[] (8) insurance company or agency
[] (9) pension consultant
[] (10) real estate broker or dealer
[] (11) sponsor or syndicator of limited partnerships
If you checked Item 7.A(3), list on Section 7.A. of Schedule D
				all your related persons that are investment advisers.
B. Are you or any
related person
a general
				partner in an
investment-related
limited partnership or
				manager of an
investment-related
limited liability company? []
				Yes [] No
If "yes," for each limited partnership or limited liability
				company, complete Section 7.B. of Schedule D.
Item 8 Participation or Interest in
Client
Transactions
In this Item, we request information about your participation
				and interest in your
clients'
transactions. Like Item 7, this
				information identifies areas in which conflicts of interest may occur between
				you and your
clients.
Like Item 7, Item 8 requires you to provide information about
				you and your
related persons.
FORM ADV
............................................................................
						  Your Name _______.. CRD Number _______
Part 1A
..................................................................................
						  Date _______.. SEC 801-Number ______
Page 11 of 16
Proprietary Interest in Client
				Transactions
A. Do you or any
related person:
..
Yes No
...................................................................................
(1) buy securities for yourself from advisory
clients,
or sell securities you own to advisory
clients
(principal transactions)?.. [] []
				.................................................
(2) buy or sell for yourself securities (other than shares of
				mutual funds) that you also recommend to advisory
clients?
..
				[] []
				.........................................................................
(3) recommend securities (or other investment products) to
				advisory
clients
in which you or any
related
				person
has some other proprietary (ownership) interest (other than
				those mentioned in Items 8.A(1) or (2))?.. [] []
				.............................................................
Sales Interest in
Client
Transactions
B. Do you or any
related person:.. Yes No
...........................................................................
(1) as a broker-dealer or registered representative of a
				broker-dealer, execute securities trades for brokerage customers in which
				advisory
client
securities are sold to or bought from the
				brokerage customer (agency cross transactions)?.. [] []
				..............................................................................................................................................................................................................
(2) recommend purchase of securities to advisory
clients
for which you or any
related person
serves as underwriter, general or managing partner, or purchaser
				representative?.. [] []
				.......................................................................................................................
(3) recommend purchase or sale of securities to advisory
clients
for which you or any
related person
has any other sales interest (other than the receipt of sales commissions as a
				broker or registered representative of a broker-dealer)?.. [] []
				...................................
Investment or Brokerage Discretion
C. Do you or any
related person
have
discretionary authority
to determine the:..
Yes
				No
.......
(1) securities to be bought or sold for a
client's
account?.. [] []
				.......................................................................................
(2) amount of securities to be bought or sold for a
client's
account?.. [] []
				......................................................................
(3) broker or dealer to be used for a purchase or sale of
				securities for a
client's
account?.. [] []
				.................................
(4) commission rates to be paid to a broker or dealer for a
client's
securities transactions?.. [] []
				...............................
FORM ADV
.......................................................................... Your
						  Name _______.. CRD Number _______
Part 1A
................................................................................
						  Date _______.. SEC 801-Number ______
Page 12 of 16
..
Yes No
......................................................................................................................................................................
D. Do you or any
related person
recommend
				brokers or dealers to
clients?
.. [] []
				..............................
E. Do you or any
related person
receive
				research or other products or services other than execution from a
				broker-dealer or a third party in connection with
client
securities transactions?.. [] []
				......................................................
F. Do you or any
related person,
directly or
				indirectly, compensate any
person
for
client
referrals?.. [] []
				................................................................................................................................................
In responding to this Item 8.F., consider in your response all
				cash and non-cash compensation that you or a related person gave any person in
				exchange for client referrals, including any bonus that is based, at least in
				part, on the number or amount of client referrals.
Item 9
Custody
In this Item, we ask you whether you or a
related
				person
has
custody
of
client
assets.
A. Do you have
custody
of any advisory
clients':
..
Yes No
.........................................
(1) cash or bank accounts?.. [] []
				..........................................................................................................................................
(2) securities?.. [] []
				...............................................................................................................................................................
B. Do any of your
related persons
have
custody
of any of your advisory
clients':
(1) cash or bank accounts?.. [] []
				.........................................................................................................................................
(2) securities?.. [] []
				...............................................................................................................................................................
C. If you answered "yes" to either Item 9.B(1) or 9.B(2), is
				that
related person
a broker-dealer registered under Section
				15 of the Securities Exchange Act of 1934?.. [] []
				.....................................................................................................................
Item 10
Control Persons
In this Item, we ask you to identify every
person
that, directly or indirectly,
controls
you.
If you are submitting an initial application, you must complete
				Schedule A and Schedule B. Schedule A asks for information about your direct
				owners and executive officers. Schedule B asks for information about your
				indirect owners. If this is an amendment and you are updating information you
				reported on either Schedule A or Schedule B (or both) that you filed with your
				initial application, you must complete Schedule C.
Does any
person
not named in Item 1.A. or
				Schedules A, B, or C, directly or indirectly,
control
your
				management or policies? [] Yes [] No
If yes, complete Section 10 of Schedule D.
FORM ADV
..............................................................................
						  Your Name _______.. CRD Number _______
Part 1A
....................................................................................
						  Date _______.. SEC 801-Number ______
Page 13 of 16
Item 11 Disclosure Information
In this Item, we ask for information about your disciplinary
				history and the disciplinary history of all your
advisory
				affiliates.
We use this information to determine whether to grant your
				application for registration, to decide whether to revoke your registration or
				to place limitations on your activities as an investment adviser, and to
				identify potential problem areas to focus on during our on-site examinations.
				One event may result in "yes" answers to more than one of the questions
				below.
Your
advisory affiliates
are: (1) all of your
				current
employees
(other than
employees
performing only clerical, administrative, support or similar functions); (2)
				all of your officers, partners, or directors (or any
person
performing similar functions); and (3) all
persons
directly or
				indirectly
controlling
you or
controlled
by
				you. If you are a "separately identifiable department or division" (SID) of a
				bank, see the Glossary of Terms to determine who your
advisory
				affiliates
are.
If you are registered or registering with the SEC, you may
				limit your disclosure of any event listed in Item 11 to ten years following the
				date of the event. If you are registered or registering with a state, you must
				respond to the questions as posed; you may, therefore, limit your disclosure to
				ten years following the date of an event only in responding to Items 11.A(1),
				11.A(2), 11.B(1), 11.B(2), 11.D(4), and 11.H(1)(a). For purposes of calculating
				this ten-year period, the date of an event is the date the final order,
				judgment, or decree was entered, or the date any rights of appeal from
				preliminary orders, judgments, or decrees lapsed.
You must complete the appropriate Disclosure Reporting Page
				("DRP") for "yes" answers to the questions in this Item 11.
For "yes" answers to the following questions, complete
				a Criminal Action DRP.
..
Yes
No
................................................................................................................................
A. In the past ten years, have you or any
advisory
				affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no
				contest") in a domestic, foreign, or military court to any
felony?
.. [] []
				........................................................................
(2) been
charged
with any
felony?
.. [] []
				..............................................................................
If you are registered or registering with the SEC, you may
				limit your response to Item 11.A(2) to charges that are currently
				pending.
B. In the past ten years, have you or any
advisory
				affiliate:
(1) been convicted of or pled guilty or nolo contendere ("no
				contest") in a domestic, foreign, or military court to a
misdemeanor
involving: investments or an
investment-related
business, or any fraud, false statements,
				or omissions, wrongful taking of property, bribery, perjury, forgery,
				counterfeiting, extortion, or a conspiracy to commit any of these offenses?..
				[] []
				...........................................................................................................................................................................
(2) been
charged
with a
misdemeanor
listed in Item 11.B(1)?.. [] []
				.....................................
If you are registered or registering with the SEC, you may
				limit your response to Item 11.B(2) to charges that are currently
				pending.
FORM ADV
................................................................... Your Name
						  _______.. CRD Number _______
Part 1A
......................................................................... Date
						  _______.. SEC 801-Number ______
Page 14 of 16
For "yes" answers to the following questions, complete
				a Regulatory Action DRP.
..
Yes No
...........................................................................................................................................
C. Has the SEC or the Commodity Futures Trading Commission
				(CFTC) ever:
(1)
found
you or any
advisory
				affiliate
to have made a false statement or omission?.. [] []
				.......
(2)
found
you or any
advisory
				affiliate
to have been
involved
in a violation of SEC
				or CFTC regulations or statutes?.. [] []
				...............................................
(3)
found
you or any
advisory
				affiliate
to have been a cause of an
investment-
				related
business having its authorization to do business denied,
				suspended, revoked, or restricted?.. [] []
				...........................................................
(4) entered an
order
against you or any
advisory affiliate
in connection with
investment-related
activity?.. [] []
				...........................................................................
(5) imposed a civil money penalty on you or any
advisory affiliate,
or
ordered
you or any
advisory affiliate
to cease and desist from any activity?.. []
				[] ....................................................
D. Has any other federal regulatory agency, any state
				regulatory agency, or any
foreign financial regulatory
				authority:
(1) ever
found
you or any
advisory
				affiliate
to have made a false statement or omission, or been
				dishonest, unfair, or unethical?.. [] []
				.................................................................
(2) ever
found
you or any
advisory
				affiliate
to have been
involved
in a violation of
investment-related
regulations or statutes?.. [] []
				..........
(3) ever
found
you or any
advisory
				affiliate
to have been a cause of an
investment-related
business having its authorization to do
				business denied, suspended, revoked, or restricted?.. [] [] .......
(4) in the past ten years, entered an
order
against you or any
advisory affiliate
in connection with an
investment-related
activity?.. [] []
				...................................
(5) ever denied, suspended, or revoked your or any
advisory affiliate's
registration or license, or otherwise
				prevented you or any
advisory affiliate,
by
order,
from associating with an
investment-related
business or restricted your or any
advisory affiliate's
activity?.. [] [] .......
E. Has any
self-regulatory organization
or
				commodities exchange ever:
(1)
found
you or any
advisory
				affiliate
to have made a false statement or omission?.. [] []
				.......
(2)
found
you or any
advisory
				affiliate
to have been
involved
in a violation of its
				rules (other than a violation designated as a
"minor rule
				violation"
under a plan approved by the SEC)?.. [] []
				.................................
FORM ADV
..............................................................................
						  Your Name _______.. CRD Number _______
Part 1A
....................................................................................
						  Date _______.. SEC 801-Number ______
Page 15 of 16
..
Yes No
.....................................................................................................................................................
(3)
found
you or any
advisory
				affiliate
to have been the cause of an
investment-related
business having its authorization to do
				business denied, suspended, revoked, or restricted?.. [] []
				................................................
(4) disciplined you or any
advisory affiliate
by expelling or suspending you or the
advisory affiliate
from
				membership, barring or suspending you or the
advisory
				affiliate
from association with other members, or otherwise
				restricting your or the
advisory affiliate's
activities?.. []
				[]
				...................................................................................................
F. Has an authorization to act as an attorney, accountant, or
				federal contractor granted to you or to any
advisory affiliate
ever been revoked or suspended?.. [] []
				.........................................
G. Are you or any
advisory affiliate
now the
				subject of any regulatory
proceeding
that could result in a
				"yes" answer to any part of Item 11.C, 11.D, or 11.E?.. [] []
				......................
For "yes" answers to the following questions, complete
				a Civil Judicial Action DRP.
..
Yes No
.....................................................................................................................................................
H. (1) Has any domestic or foreign court:
(a) in the past ten years,
enjoined
you or any
advisory affiliate
in connection with any
investment-related
activity?.. [] []
				.....................
(b) ever
found
that you or any
advisory affiliate
were
involved
in a
				violation of
investment-related
statutes or regulations?.. []
				[] ..............
(c) ever dismissed, pursuant to a settlement agreement, an
investment-related
civil action brought against you or any
advisory affiliate
by a state or
foreign financial
				regulatory authority?
[] []
(2) Are you or any
advisory affiliate
now the
				subject of any civil
proceeding
that could result in a "yes"
				answer to any part of Item 11.H(1)?.. [] []
				................................................
Item 12 Small Businesses
The SEC is required by the Regulatory Flexibility Act to
				consider the effect of its regulations on small entities. In order to do this,
				we need to determine whether you meet the definition of "small business" or
				"small organization" under rule 0-7.
Answer this Item 12 only if you are registered or registering
				with the SEC
and
you indicated in response to Item 5.F(2)(c)
				that you have assets under management of less than $25 million. You are not
				required to answer this Item 12 if you are filing for initial registration as a
				state adviser, amending a current state registration, or switching from SEC to
				state registration.
FORM ADV
..............................................................................
						  Your Name _______.. CRD Number _______
Part 1A
....................................................................................
						  Date _______.. SEC 801-Number ______
Page 16 of 16
For purposes of this Item 12 only:
* Total Assets refers to the total assets of a firm, rather
				than the assets managed on behalf of
clients.
In determining
				your or another
person's
total assets, you may use the total
				assets shown on a current balance sheet (but use total assets reported on a
				consolidated balance sheet with subsidiaries included, if that amount is
				larger).
* Control means the power to direct or cause the direction of
				the management or policies of a
person,
whether through
				ownership of securities, by contract, or otherwise. Any
person
that directly or indirectly has the right to vote 25 percent or more of the
				voting securities, or is entitled to 25 percent or more of the profits, of
				another
person
is presumed to control the other
person.
..
Yes No
............................................................................................................................
A. Did you have total assets of $5 million or more on the last
				day of your most recent fiscal year?.. [] [] .......
If "yes," you do not need to answer Items 12.B and 12.C.
B. Do you:
(1) control another investment adviser that had assets under
				management of $25 million or more on the last day of the most recent fiscal
				year?.. [] []
				..............................................................................................................................................
(2) control another
person
(other than a
				natural person) that had total assets of $5 million or more on the last day of
				its most recent fiscal year?.. [] []
				.........................................................................................................................
C. Are you:
(1) controlled by or under common control with another
				investment adviser that had assets under management of $25 million or more on
				the last day of its most recent fiscal year?.. [] []
				..............................................................................
(2) controlled by or under common control with another
person
(other than a natural person) that had total assets of
				$5 million or more on the last day of its most recent fiscal year?.. [] []
				..............................................................
FORM ADV (Paper Version)
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
PART 1B
You must complete this Part 1B only if you are applying for
				registration, or are registered, as an investment adviser with any of the
state securities authorities.
Item 1 State Registration
Complete this Item 1 if you are submitting an initial
				application for state registration or requesting additional state
				registration(s). Check the boxes next to the states to which you are submitting
				this application. If you are already registered with at least one state and are
				applying for registration with an additional state or states, check the boxes
				next to the states in which you are applying for registration. Do not check the
				boxes next to the states in which you are currently registered or where you
				have an application for registration pending.
[] AL [] CT [] HI [] KY [] MN [] NH [] OH [] SC [] VA
[] AK [] DE [] ID [] LA [] MS [] NJ [] OK [] SD [] WA
[] AZ [] DC [] IL [] ME [] MO [] NM [] OR [] TN [] WV
[] AR [] FL [] IN [] MD [] MT [] NY [] PA [] TX [] WI
[] CA [] GA [] IA [] MA [] NE [] NC [] PR [] UT
[] CO [] GU [] KS [] MI [] NV [] ND [] RI [] VT
Item 2 Additional Information
A. Person responsible for supervision and compliance:
(name)
(title)
(area code) (telephone number).. (area code) (facsimile number)
				...................................................................
(number and street)
(city) (state/country) (zip+4/postal code)
(electronic mail (e-mail) address, if the person has
				one)
If this address is a private residence, check this box:
				[]
B. Bond/Capital Information, if required by your
home
				state.
(1) Name of Issuing Insurance Company:
____________________________________________________________________________________
(2) Amount of Bond: $ __.00
(2) Bond Policy Number: ______
FORM ADV
....................................................................... Your
						  Name _______.. CRD Number _______
Part 1B
............................................................................
						  Date _______.. SEC 801-Number ______
Page 2 of 4
..
Yes No
........................................................................................................................................
(4) If required by your home state, are you in compliance with
				your home state's minimum capital requirements?.. [] [] .......
For "yes" answers to the following question, complete a
				Bond DRP:
C. Has a bonding company ever denied, paid out on, or revoked a
				bond for you?.. [] [] ..................................
For "yes" answers to the following question, complete a
				Judgment/Lien DRP:
D. Do you have any unsatisfied judgments or liens against
				you?.. [] []
				.............................................................
For "yes" answers to the following questions, complete
				an Arbitration DRP:
E. Are you, any
advisory affiliate,
or any
management person
currently the subject of, or have you, any
advisory affiliate,
or any
management person
been the subject of, an arbitration claim alleging damages in excess of $2,500,
				involving any of the following:
(1) any investment or an
investment-related
business or activity?.. [] [] ..........................................
(2) fraud, false statement, or omission?.. [] []
				......................................................................................................
(3) theft, embezzlement, or other wrongful taking of
				property?.. [] []
				..................................................................
(4) bribery, forgery, counterfeiting, or extortion?.. [] []
				.........................................................................................
(5) dishonest, unfair, or unethical practices?.. [] []
				...............................................................................................
For "yes" answers to the following questions, complete
				a Civil Judicial Action DRP:
F. Are you, any
advisory affiliate,
or any
management person
currently subject to, or have you, any
advisory affiliate,
or any
management person
been
found
liable in, a civil,
self- regulatory
				organization,
or administrative
proceeding
involving
				any of the following:
(1) an investment or
investment-related
business or activity?.. [] []
				..............................................
(2) fraud, false statement, or omission?.. [] []
				....................................................................................................
(3) theft, embezzlement, or other wrongful taking or
				property?.. [] []
				...............................................................
(4) bribery, forgery, counterfeiting, or extortion?.. [] []
				......................................................................................
(5) dishonest, unfair, or unethical practices?.. [] []
				............................................................................................
FORM ADV
................................................................ Your Name
						  _______.. CRD Number _______
Part 1B
...................................................................... Date
						  _______.. SEC 801-Number ______
Page 3 of 4
G. Other Business Activities
(1) Are you actively engaged in business as a(n) (check all
				that apply):
[] Attorney
[] Certified public accountant
[] Tax preparer
(2) If you are actively engaged in any business other than
				those listed in Item 6.A. of Part 1A or Item 2.G(1) of Part 1B, describe the
				business and the approximate amount of time spent on that business:
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
___________________________________________________________________________________
H. If you provide financial planning services, the investments
				made based on those services at the end of your last fiscal year
				totaled:
Securities
Non-Securities
Investments
Investments
Under $100,000
[]
[]
$100,001 to $500,000
[]
[]
$500,001 to $1,000,000
[]
[]
$1,000,001 to $2,500,000
[]
[]
$2,500,001 to $5,000,000
[]
[]
More than $5,000,000
[]
[]
If securities investments are over $5,000,000, how much? $ ___
				(round to the nearest $1,000,000)
If non-securities investments are over $5,000,000, how much? $
				___ (round to the nearest $1,000,000)
I.
Custody
..
Yes No
.........................................................................................................................................
(1) Do you withdraw advisory fees directly from your
clients'
accounts?.. [] [] ..........................
(2) Do you act as a general partner for any partnership or
				trustee for any trust in which your advisory
clients
are
				either partners of the partnership or beneficiaries of the trust?.. [] []
				................................................................................
FORM ADV
........................................................
						  Your Name _______.. CRD Number _______
Part 1B
.............................................................. Date _______..
						  SEC 801-Number ______
Page 4 of 4
..
Yes No
.................................................................................................................................
(3) If you answered "yes" to Item 2.I(1) or 2.I(2), respond to
				the following:
(a) Do you send a copy of your invoice to the custodian or
				trustee at the same time that you send a copy to the
client?
.. [] [] ..............
(b) Do you send quarterly statements to your
clients
showing all disbursements for the custodian account,
				including the amount of the advisory fees? [] [] .......
(c) Do your
clients
provide written
				authorization permitting you to be paid directly for their accounts held by the
				custodian or trustee?.. [] [] .............
(d) If you are the general partner of a partnership, have you
				engaged an attorney or an independent certified public accountant to provide
				authority permitting each direct payment or any transfer of funds or securities
				from the partnership account?.. [] [] .......
(4) Do you require prepayment of fees of more than $500 per
client
and for six months or more in advance? .. [] []
				.......
J. If you are organized as a sole proprietorship, please answer
				the following:
..
Yes No
.....................................................................................................................................
(1)(a) Have you passed, on or after January 1, 2000, the Series
				65 examination?.. [] [] ..........................
(b) Have you passed, on or after January 1, 2000, the Series 66
				examination and also passed, at any time, the Series 7 examination?.. [] []
				.......
(2)(a) Do you have any investment advisory professional
				designations?.. [] [] ..............................................
If "no," you do not need to answer Item 2.J.(2)(b).
(b) I have earned and I am in good standing with the
				organization that issued the following credential:
[] 1. Certified Financial Planner ("CFP")
[] 2. Chartered Financial Analyst ("CFA")
[] 3. Chartered Financial Consultant ("ChFC")
[] 4. Chartered Investment Counselor ("CIC")
[] 5. Personal Financial Specialist ("PFS")
[] 6. None of the above
(3) Your social security number: _______
FORM ADV
.................................................................. Your Name:
						  ______.. SEC File No.:______
Schedule A
..................................................................................
						  Date: ______.. CRD No.: ______
Direct Owners and Executive
							 Officers
1. Complete Schedule A only if you are submitting an
							 initial application. Schedule A asks for information about your direct owners
							 and executive officers. Use Schedule C to amend this information.
2. Direct Owners and Executive Officers. List below
							 the names of:
(a) each Chief Executive Officer, Chief Financial
							 Officer, Chief Operations Officer, Chief Legal Officer, Chief Compliance
							 Officer, director, and individuals with similar status or
							 functions;
(b) if you are organized as a corporation, each
							 shareholder that is a direct owner of 5% or more of a class of your voting
							 securities, unless you are a public reporting company (a company subject to
							 Section 12 or 15(d) of the Exchange Act);
Direct owners may include any
person
that owns, beneficially owns, has the right to vote, or has the power to sell
							 or direct the sale of, 5% or more of a class of your voting securities. For
							 purposes of this Schedule, a
person
beneficially owns any
							 securities: (i) owned by his/her child, stepchild, grandchild, parent,
							 stepparent, grandparent, spouse, sibling, mother-in-law, father-in-law,
							 son-in-law, daughter-in-law, brother-in-law, or sister-in-law, sharing the same
							 residence; or (ii) that he/she has the right to acquire, within 60 days,
							 through the exercise of any option, warrant, or right to purchase the
							 security.
(c) if you are organized as a partnership,
all
general partners and those limited and special partners
							 that have the right to receive upon dissolution, or have contributed, 5% or
							 more of your capital;
(d) in the case of a trust that directly owns 5% or
							 more of a class of your voting securities, or that has the right to receive
							 upon dissolution, or has contributed, 5% or more of your capital, the trust and
							 each trustee; and
(e) if you are organized as a limited liability
							 company ("LLC"), (i) those members that have the right to receive upon
							 dissolution, or have contributed, 5% or more of your capital, and (ii) if
							 managed by elected managers, all elected managers;
3. Do you have any indirect owners to be reported on
							 Schedule B? [] Yes [] No
4. In the DE/FE/I column below, enter "DE" if the
							 owner is a domestic entity, "FE" if the owner is an entity incorporated or
							 domiciled in a foreign country, or "I" if the owner or executive officer is an
							 individual.
5. Complete the Title or Status column by entering
							 board/management titles; status as partner, trustee, sole proprietor, elected
							 manager, shareholder, or member; and for shareholders or members, the class of
							 securities owned (if more than one is issued).
6. Ownership codes are: NA - less than 5%
.................................................................................................................................................................................................................
B - 10% buy less than 25%
.................................................................................................................................................................................................................
D - 50% but less than 75%
A - 5% but less than 10%
.................................................................................................................................................................................................................
C - 25% but less than 50%
.................................................................................................................................................................................................................
E - 75% or more
7. (a) In the
Control Person
column,
							 enter "Yes" if the person has
control
as defined in the
							 Glossary of Terms to Form ADV, and enter "No" if the
person
does not have control. Note that under this definition, most executive officers
							 and all 25% owners, general partners, elected managers, and trustees are
control persons.
(b) In the PR column, enter "PR" if the owner is a
							 public reporting company under Sections 12 or 15(d) of the Exchange
							 Act.
(c) Complete each column.
FULL LEGAL NAME
Title
Date Title
Owner-
Control
CRD No.
(Individuals: Last Name,
DE/FE/I
or
or Status
ship
Person
If None: S.S. No. and Date of Birth,
First Name, Middle Name)
Status
Acquired
Code
IRS Tax No., or Employer ID No.
MM
YYYY
PR
FORM ADV
...........................................................................
						  Your Name: ______.. SEC File No.:______
Schedule B
...........................................................................................
						  Date: ______.. CRD No.: ______
Indirect Owners
1. Complete Schedule B only if you are submitting an
							 initial application. Schedule B asks for information about your indirect
							 owners; you must first complete Schedule A, which asks for information about
							 your direct owners. Use Schedule C to amend this information.
2. Indirect Owners. With respect to each owner listed
							 on Schedule A (except individual owners), list below:
(a) in the case of an owner that is a corporation,
							 each of its shareholders that beneficially owns, has the right to vote, or has
							 the power to sell or direct the sale of, 25% or more of a class of a voting
							 security of that corporation;
For purposes of this Schedule, a
person
beneficially owns any securities: (i) owned by his/her
							 child, stepchild, grandchild, parent, stepparent, grandparent, spouse, sibling,
							 mother-in-law, father-in-law, son-in-law, daughter-in-law, brother-in-law, or
							 sister-in-law, sharing the same residence; or (ii) that he/she has the right to
							 acquire, within 60 days, through the exercise of any option, warrant, or right
							 to purchase the security.
(b) in the case of an owner that is a partnership,
all
general partners and those limited and special partners
							 that have the right to receive upon dissolution, or have contributed, 25% or
							 more of the partnership's capital;
(c) in the case of an owner that is a trust, the
							 trust and each trustee; and
(d) in the case of an owner that is a limited
							 liability company ("LLC"), (i) those members that have the right to receive
							 upon dissolution, or have contributed, 25% or more of the LLC's capital, and
							 (ii) if managed by elected managers, all elected managers.
3. Continue up the chain of ownership listing all 25%
							 owners at each level. Once a public reporting company (a company subject to
							 Sections 12 or 15(d) of the Exchange Act) is reached, no further ownership
							 information need be given.
4. In the DE/FE/I column below, enter "DE" if the
							 owner is a domestic entity, "FE" if the owner is an entity incorporated or
							 domiciled in a foreign country, or "I" if the owner is an
							 individual.
5. Complete the Status column by entering the owner's
							 status as partner, trustee, elected manager, shareholder, or member; and for
							 shareholders or members, the class of securities owned (if more than one is
							 issued).
6. Ownership codes are: C - 25% but less than 50%
...............................................................................................................................................................................................................
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" if the
person
has
control
as
							 defined in the Glossary of Terms to Form ADV, and enter "No" if the
person
does not have
control.
Note that under
							 this definition, most executive officers and all 25% owners, general partners,
							 elected managers, and trustees are
control
							 persons.
(b) In the PR column, enter "PR" if the owner is a
							 public reporting company under Sections 12 or 15(d) of the Exchange
							 Act.
(c) Complete each column.
FULL LEGAL NAME
Entity in
Date
Owner-
Control
CRD No. If None:
(Individuals: Last Name,
DE/FE/I
Which Interest
Status
Status
ship
Person
S.S. No. and Date of Birth,
First Name, Middle Name)
is Owned
Acquired
Code
IRS Tax No. or Employer ID No.
MM
YYYY
PR
FORM ADV
................................................................... Your Name:
						  ______.. SEC File No.:______
Schedule C
....................................................................................
						  Date: ______.. CRD No.: ______
Amendments to Schedules A and B
1. Use Schedule C only to amend information requested on
						  either Schedule A or Schedule B. Refer to Schedule A and Schedule B for
						  specific instructions for completing this Schedule C. Complete each
						  column.
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% C - 25% but
						  less than 50% G- Other (general partner, A - 5% but less than 10% D - 50% but
						  less than 75% trustee, or elected member) B - 10% but less than 25% E -75% or
						  more
4. List below all changes to Schedule A (Direct Owners
						  and Executive Officers):
FULL LEGAL NAME
Type of
Title
Date Title
Owner-
Control
CRD No. If None:
(Individuals: Last Name,
DE/FE/I
Amend-
or
or Status
ship
Person
S.S. No. and Date of Birth,
First Name, Middle Name)
ment
Status
Acquired
Code
IRS Tax No. or Employer ID No.
MM
YYYY
PR
5. List below all changes to Schedule B
						  (Indirect Owners):
FULL LEGAL NAME
DE/FE/I
Type of
Entity in
Date
Owner-
Control
CRD No. If None:
(Individuals: Last Name,
Amend-
Which Interest
Status
Status
ship
Person
S.S. No. and Date of Birth,
First Name, Middle Name)
ment
is Owned
Acquired
Code
IRS Tax No. or
Employer ID No.
MM
YYYY
PR
FORM ADV
............................................................. Your Name:
						  ______.. SEC File No.:______
Schedule D
..............................................................................
						  Date: ______.. CRD No.: ______
Page 1 of 5
Certain items in Part 1A of Form ADV require
							 additional information on Schedule D. Use this Schedule D Page 1 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 Page
							 1.
SECTION 1.B. Other Business Names
List your other business names and the jurisdictions
							 in which you use them. You must complete a separate Schedule D for each
							 business name.
Check only one box: [] Add [] Delete [] Amend Name
							 ___________ Jurisdictions ________
SECTION 1.F. Other Offices
Complete the following information for each office,
							 other than your
principal office and place of business,
at
							 which you conduct investment advisory business. You must complete a separate
							 Schedule D Page 1 for each location. If you are applying for registration, or
							 are registered, only with the SEC, list only the largest five (in terms of
							 numbers of employees).
Check only one box: [] Add [] Delete
(number and street)
(city)
............................................................................................................................................................................................................
(state/country)
(zip+4/postal code)
If this address is a private residence, check this
							 box: []
__________ __________
(area code) (telephone number) (area code) (facsimile
							 number)
SECTION 1.I. World Wide Web Site
							 Addresses
List your World Wide Web site addresses. You must
							 complete a separate Schedule D for each World Wide Web site
							 address.
Check only one box: [] Add [] Delete
World Wide Web Site Address:
							 _____________
SECTION 1.K. Location of Books and
							 Records
Complete the following information for each location
							 at which you keep your books and records, other than your
principal
							 office and place of business.
You must complete a separate Schedule D
							 Page 1 for each location.
Check only one box: [] Add [] Delete []
							 Amend
Name of entity where books and records are
							 kept:____________________________________________________
(number and street)
(city)
.....................................................................................................................................................................................................
(state/country)
(zip+4/postal code)
If this address is a private residence, check this
							 box: []
__________ __________
(area code) (telephone number) (area code) (facsimile
							 number)
This is (check one): [] one of your branch offices or
							 affiliates. [] a third-party unaffiliated recordkeeper. [] other.
Briefly describe the books and records kept at this
							 location: ________
FORM ADV
.................................................................. Your Name:
						  ______.. SEC File No.:______
Schedule D
...................................................................................
						  Date: ______.. CRD No.: ______
Page 2 of 5
Use this Schedule D Page 2 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 Page
						  2.
SECTION 1.L. Registration with
Foreign Financial
						  Regulatory Authorities
List the name, in English, of each
foreign
						  financial regulatory authority
and country with which you are
						  registered. You must complete a separate Schedule D Page 2 for each
foreign financial regulatory authority
with whom you are
						  registered.
Check only one box: []Add [] Delete
English Name of
Foreign Financial Regulatory
						  Authority
_______________
Name of Country _______________________
SECTION 2.A(7) Affiliated Adviser
If you are relying on the exemption in rule 203A-2(c)
						  from the prohibition on registration because you
control,
are
controlled
by, or are under common
control
with an investment adviser that is registered with the SEC and your
principal office and place of business
is the same as that of
						  the registered adviser, provide the following information:
Name of Registered Investment Adviser
						  _______________
CRD Number of Registered Investment Adviser (if any)
						  __________
SEC Number of Registered Investment Adviser
						  801-__________
SECTION 2.A(8) Newly Formed Adviser
If you are relying on rule 203A-2(d), the newly formed
						  adviser exemption from the prohibition on registration, you are required to
						  make certain representations about your eligibility for SEC registration. By
						  checking the appropriate boxes, you will be deemed to have made the required
						  representations. You must make both of these representations:
[] I am not registered or required to be registered with
						  the SEC or a state securities authority and I have a reasonable expectation
						  that I will be eligible to register with the SEC within 120 days after the date
						  my registration with the SEC becomes effective.
[] I undertake to withdraw from SEC registration if, on
						  the 120th day after my registration with the SEC becomes effective, I would be
						  prohibited by Section 203A(a) of the Advisers Act from registering with the
						  SEC.
SECTION 2.A(9) Multi-State Adviser
If you are relying on rule 203A-2(e), the multi-state
						  adviser exemption from the prohibition on registration, you are required to
						  make certain representations about your eligibility for SEC registration. By
						  checking the appropriate boxes, you will be deemed to have made the required
						  representations.
If you are applying for registration as an investment
						  adviser with the SEC, you must make both of these representations:
[] I have reviewed the applicable state and federal laws
						  and have concluded that I am required by the laws of 30 or more states to
						  register as an investment adviser with the securities authorities in those
						  states.
[] I undertake to withdraw from SEC registration if I
						  file an amendment to this registration indicating that I would be required by
						  the laws of fewer than 25 states to register as an investment adviser with the
						  securities authorities of those states.
If you are submitting your
annual updating
						  amendment,
you must make this representation:
[] Within 90 days prior to the date of filing this
						  amendment, I have reviewed the applicable state and federal laws and have
						  concluded that I am required by the laws of at least 25 states to register as
						  an investment adviser with the securities authorities in those states.
FORM ADV
..................................................................... Your
						  Name: ______.. SEC File No.:______
Schedule D
......................................................................................
						  Date: ______.. CRD No.: ______
Page 3 of 5
Use this Schedule D Page 3 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 Page
						  3.
SECTION 2.A(10) SEC Exemptive Order
If you are relying upon an SEC order exempting you from
						  the prohibition on registration, provide the following information:
Application Number: 803- ________ Date of order:
						  _______
(mm/dd/yyyy)
SECTION 4 Successions
Complete the following information if you are succeeding
						  to the business of a currently-registered investment adviser. If you acquired
						  more than one firm in the succession you are reporting on this Form ADV, you
						  must complete a separate Schedule D Page 3 for each acquired firm. See Part 1A
						  Instruction 4.
Name of Acquired Firm _______________
Acquired Firm's SEC File No. (if any) 801- ________
						  Acquired Firm's CRD Number (if any) ________
SECTION 5.I(2)
Wrap Fee Programs
If you are a portfolio manager for one or more
wrap fee programs,
list the name of each program and its
sponsor.
You must complete a separate Schedule D Page 3 for
						  each
wrap fee program
for which you are a portfolio
						  manager.
Check only one box: [] Add [] Delete [] Amend
Name of Wrap Fee Program ____________________
Name of Sponsor _______________________
SECTION 6.B. Description of Primary Business
Describe your primary business (not your investment
						  advisory business): ________
SECTION 7.A. Affiliated Advisers
Complete the following information for each adviser with
						  whom you are affiliated. You must complete a separate Schedule D Page 3 for
						  each affiliated adviser.
Check only one box: [] Add [] Delete [] Amend
Legal Name of Affiliated Adviser: __________________
Primary Business Name of Affiliated Adviser:
						  ____________
Affiliated Adviser's SEC File Number (if any) 801-
						  ________
Affiliated Adviser's CRD Number (if any) ________
FORM ADV
...................................................................... Your
						  Name: ______.. SEC File No.:______
Schedule D
.......................................................................................
						  Date: ______.. CRD No.: ______
Page 4 of 5
Use this Schedule D Page 4 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 Page
							 4.
SECTION 7.B. Limited Partnership
							 Participation
You must complete a separate Schedule D Page 4 for
							 each limited partnership in which you or a
related person
is a
							 general partner and each limited liability company for which you or a
related person
is a manager.
Check only one box: [] Add [] Delete []
							 Amend
Name of Limited Partnership or Limited Liability
							 Company: ________________________________________________________
Are your
clients
solicited to invest
							 in the limited partnership or limited liability company? [] yes []
							 no
Approximately what percentage of your
clients
have invested in this limited partnership or limited
							 liability company? ___%
Minimum investment commitment required of a limited
							 partner or member: $ ____
Current value of the total assets of the limited
							 partnership or limited liability company: $ ________
SECTION 10
Control
							 Persons
You must complete a separate Schedule D Page 4 for
							 each
control person
not named in Item 1.A. or Schedules A, B,
							 or C that directly or indirectly
controls
your management or
							 policies.
Check only one box: [] Add [] Delete []
							 Amend
Firm or Organization Name
							 _______________________________________________________________________________
CRD Number (if any) _____ Effective Date ____
							 Termination Date ________
.......................................................................................................................................................................................mm/dd/yyyy..
							 mm/dd/yyyy
Business address:
(number and street)
(city)
......................................................................................................................................................................................................
(state/country)
(zip+4/postal code)
If this address is a private residence, check this
							 box: []
Individual Name (if applicable) (Last, First,
							 Middle)_________________________________________________________
CRD Number (if any) _____ Effective Date ____
							 Termination Date ________
..............................................................................................................................................................
							 mm/dd/yyyy.. mm/dd/yyyy
Business address:
(number and street)
(city)
......................................................................................................................................................................................................
(state/country)
(zip+4/postal code)
If this address is a private residence, check this
							 box: []
Briefly describe the nature of the
control:
____________________________________________________
FORM ADV
........................................................................ Your
						  Name: ______.. SEC File No.:______
Schedule D
........................................................................................
						  Date: ______.. CRD No.: ______
Page 5 of 5
Use this Schedule D Page 5 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 Page
						  5.
Miscellaneous
You may use the space below to explain a response to an
						  Item or to provide any other information.
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Items 11.A. or 11.B. of Form ADV.
Check item(s) being responded to: [] 11.A(1) []
							 11.A(2) [] 11.B(1) []11.B(2)
Use a separate DRP for each event or
proceeding.
The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
Multiple counts of the same charge arising out of the
							 same event(s) should be reported on the same DRP. Unrelated criminal actions,
							 including separate cases arising out of the same event, must be reported on
							 separate DRPs. Use this DRP to report all charges arising out of the same
							 event. One event may result in more than one affirmative answer to the items
							 listed above.
PART I
A. The
person(s)
or entity(ies) for whom this
				DRP is being filed is (are): [] You (the advisory firm) [] You and one or more
				of your
advisory affiliates
[] One or more of your
advisory affiliates
If this DRP is being filed for an
advisory
				affiliate,
give the full name of the
advisory
				affiliate
below (for individuals, Last name, First name, Middle
				name).
If the
advisory affiliate
has a CRD number,
				provide that number. If not, indicate "non- registered" by checking the
				appropriate box.
Your Name
Your CRD Number
ADV DRP -
ADVISORY AFFILIATE
CRD Number
This
advisory affiliate
is [] a firm []
						  an individual Registered: [] Yes [] No
Name (For individuals, Last, First, Middle)
[] This DRP should be removed from the ADV record because the
advisory affiliate(s)
is no longer associated with the
				adviser.
[] This DRP should be removed from the ADV record because: (1)
				the event or proceeding occurred more than ten years ago or (2) the adviser is
				registered or applying for registration with the SEC and the event was resolved
				in the adviser's or advisory affiliate's favor.
B. If the
advisory affiliate
is registered
				through the IARD system or CRD system, has the
advisory
				affiliate
submitted a DRP (with Form ADV, BD or U-4) to the IARD or
				CRD for the event? If the answer is "Yes," no other information on this DRP
				must be provided. [] Yes [] No
NOTE: The completion of this form does not relieve the
advisory affiliate
of its obligation to update its IARD or CRD
				records.
(continued)
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
(continuation)
PART II
1. If charge(s) were brought against an organization over which
				you or an
advisory affiliate
exercise(d) control: Enter
				organization name, whether or not the organization was an
investment-
				related
business and your or the
advisory affiliate's
position, title, or relationship.
2. Formal Charge(s) were brought in: (include name of Federal,
				Military, State or Foreign Court, Location of Court - City or County
and
State or Country, Docket/Case number).
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. Event Disclosure Detail (include Charge(s)/Charge
				Description(s), and for each charge provide: (1) number of counts, (2)
felony
or
misdemeanor,
(3) plea for each
				charge, and (4) product type if charge is
investment-related).
C. Did any of the Charge(s) within the Event involve a
felony
? [] Yes [] No
D. Current status of the Event? [] Pending [] On Appeal []
				Final
E. Event Status Date (complete unless status is Pending)
				(MM/DD/YYYY): ________
[] Exact [] Explanation
If not exact, provide explanation:
						  _________________________________________________________________
4. Disposition Disclosure Detail: Include for each charge (a)
				Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b)
				Date, (c) Sentence/Penalty, (d) Duration (if sentence- suspension, probation,
				etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date
				Paid.
(continued)
CRIMINAL DISCLOSURE REPORTING PAGE (ADV)
(continuation)
5. Provide a brief summary of circumstances leading to the
				charge(s) as well as the disposition. Include the relevant dates when the
				conduct which was the subject of the charge(s) occurred. (Your response must
				fit within the space provided.)
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form
							 ADV.
Check item(s) being responded to: [] 11.C(1)
							 []11.C(2) []11.C(3) []11.C(4) []11.C(5) []11.D(1) []11.D(2) []11.D(3) []11.D(4)
							 []11.D(5) []11.E(1) []11.E(2) []11.E(3) []11.E(4) []11.F. []11.G.
Use a separate DRP for each event or
proceeding.
The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
One event may result in more than one affirmative
							 answer to items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report
							 details related to the same event. If an event gives rise to actions by more
							 than one regulator, provide details for each action on a separate
							 DRP.
PART I
A. The
person(s)
or entity(ies) for whom this
				DRP is being filed is (are): [] You (the advisory firm) [] You and one or more
				of your
advisory affiliates
[] One or more of your
advisory affiliates
If this DRP is being filed for an
advisory
				affiliate,
give the full name of the
advisory
				affiliate
below (for individuals, Last name, First name, Middle
				name).
If the
advisory affiliate
has a CRD number,
				provide that number. If not, indicate "non- registered" by checking the
				appropriate box.
Your Name
Your CRD Number
ADV DRP -
ADVISORY AFFILIATE
CRD Number
This
advisory affiliate
is [] a firm []
						  an individual Registered: [] Yes [] No
Name (For individuals, Last, First, Middle)
[] This DRP should be removed from the ADV record because the
advisory affiliate(s)
is no longer associated with the
				adviser.
[] This DRP should be removed from the ADV record because: (1)
				the event or proceeding occurred more than ten years ago or (2) the adviser is
				registered or applying for registration with the SEC and the event was resolved
				in the adviser's or advisory affiliate's favor.
If you are registered or registering with a
state
				securities authority,
you may remove a DRP for an event you reported
				only in response to Item 11.D(4), and only if that event occurred more than ten
				years ago. If you are registered or registering with the SEC, you may remove a
				DRP for any event listed in Item 11 that occurred more than ten years
				ago.
B. If the
advisory affiliate
is registered
				through the IARD system or CRD system, has the
advisory
				affiliate
submitted a DRP (with Form ADV, BD or U-4) to the IARD or
				CRD for the event? If the answer is "Yes," no other information on this DRP
				must be provided. [] Yes [] No
NOTE: The completion of this form does not relieve the
advisory affiliate
of its obligation to update its IARD or CRD
				records.
(continued)
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
(continuation)
PART II
1. Regulatory Action initiated by: [] SEC [] Other Federal []
				State [] SRO [] Foreign
(Full name of regulator,
foreign financial regulatory
				authority,
federal, state or SRO)
2. Principal Sanction (check appropriate item):
[] Civil and Administrative Penalty(ies)/Fine(s)
[] Bar
[] Cease and Desist
[] Censure
[] Denial
[] Disgorgement
[] Expulsion
[] Injunction
[] Prohibition
[] Reprimand
[] Restitution
[] Revocation
[] Suspension
[] Undertaking
[] Other ___
Other Sanctions:
3. Date Initiated (MM/DD/YYYY): _____ [] Exact []
				Explanation
If not exact, provide explanation:
						  ___________________________________________________________
4. Docket/Case Number:
5.
Advisory Affiliate
Employing Firm when
				activity occurred which led to the regulatory action (if applicable):
6. Principal Product Type (check appropriate item):
[] Annuity(ies) - Fixed
[] Annuity(ies) - Variable
[] CD(s)
[] Commodity Option(s)
[] Debt - Asset Backed
[] Debt - Corporate
[] Debt - Government
[] Debt - Municipal
[] Derivative(s)
[] Direct Investment(s) - DPP & LP Interest(s)
[] Equity - OTC
[] Equity Listed (Common & Preferred Stock)
[] Futures - Commodity
[] Futures - Financial
[] Index Option(s)
[] Insurance
[] Investment Contract(s)
[] Money Market Fund(s)
[] Mutual Fund(s)
[] No Product
[] Options
[] Penny Stock(s)
[] Unit Investment Trust(s)
[] Other ____
Other Product Types:
(continued)
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
(
continuation
)
7. Describe the allegations related to this regulatory action
				(your response must fit within the space provided):
8. Current status? [] Pending [] On Appeal [] Final
9. If on appeal, regulatory action appealed to (SEC, SRO,
				Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending
				Actions, complete Item 13 only.
10. How was matter resolved (check appropriate item):
[] Acceptance, Waiver & Consent (AWC)
[] Consent
[] Decision
[] Decision & Order of Offer of Settlement
[] Dismissed
[] Order
[] Settled
[] Stipulation and Consent
[] Vacated
[] Withdrawn
[] Other ___
11. Resolution Date (MM/DD/YYYY): ____ [] Exact []
				Explanation
If not exact, provide explanation:
						  _____________________________________________________________
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all
				appropriate items)?
[] Monetary/Fine [] Revocation/Expulsion/Denial []
				Disgorgement/Restitution
Amount: $ ___ [] Censure [] Cease and Desist/Injunction [] Bar
				[] Suspension
B. Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide
				duration including start date and capacities affected (General Securities
				Principal, Financial Operations Principal, etc.). If requalification by
				exam/retraining was a condition of the sanction, provide length of time given
				to requalify/retrain, type of exam required and whether condition has been
				satisfied. If disposition resulted in a fine, penalty, restitution,
				disgorgement or monetary compensation, provide total amount, portion levied
				against you or an
advisory affiliate,
date paid and if any
				portion of penalty was waived:
(continued)
REGULATORY ACTION DISCLOSURE REPORTING PAGE (ADV)
(continuation)
13. Provide a brief summary of details related to the action
				status and (or) disposition and include relevant terms, conditions and dates
				(your response must fit within the space provided).
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Item 11.H. of Part 1A and Item 2.F. of Part 1B of Form
							 ADV.
Check Part 1A item(s) being responded to:
							 []11.H(1)(a) []11.H(1)(b) []11.H(1)(c) []11.H(2)
Check Part 1B item(s) being responded to: []2.F(1)
							 []2.F(2) []2.F(3) []2.F(4) []2.F(5)
Use a separate DRP for each event or
proceeding.
The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
One event may result in more than one affirmative
							 answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to
							 report details related to the same event. Unrelated civil judicial actions must
							 be reported on separate DRPs.
PART I
A. The
person(s)
or entity(ies) for whom this
				DRP is being filed is (are): [] You (the advisory firm) [] You and one or more
				of your
advisory affiliates
[] One or more of your
advisory affiliates
If this DRP is being filed for an
advisory
				affiliate,
give the full name of the
advisory
				affiliate
below (for individuals, Last name, First name, Middle
				name).
If the
advisory affiliate
has a CRD number,
				provide that number. If not, indicate "non-registered" by checking the
				appropriate box.
Your Name
Your
CRD
Number
ADV DRP -
ADVISORY AFFILIATE
CRD Number
This
advisory affiliate
is [] a firm []
						  an individual Registered: [] Yes [] No
Name (For individuals, Last, First, Middle)
[] This DRP should be removed from the ADV record because the
advisory affiliate(s)
is no longer associated with the
				adviser.
[] This DRP should be removed from the ADV record because: (1)
				the event or proceeding occurred more than ten years ago or (2) the adviser is
				registered or applying for registration with the SEC and the event was resolved
				in the adviser's or advisory affiliate's favor.
If you are registered or registering with a
state
				securities authority,
you may remove a DRP for an event you reported
				only in response to Item 11.H(1)(a), and only if that event occurred more than
				ten years ago. If you are registered or registering with the SEC, you may
				remove a DRP for any event listed in Item 11 that occurred more than ten years
				ago.
B. If the
advisory affiliate
is registered
				through the IARD system or CRD system, has the
advisory
				affiliate
submitted a DRP (with Form ADV, BD or U-4) to the IARD or
				CRD for the event? If the answer is "Yes," no other information on this DRP
				must be provided. [] Yes [] No
NOTE: The completion of this form does not relieve the
advisory affiliate
of its obligation to update its IARD or CRD
				records.
(continued)
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
(continuation)
PART II
1. Court Action initiated by: (Name of regulator,
foreign financial regulatory authority, SRO
, commodities
				exchange, agency, firm, private plaintiff, etc.)
2. Principal Relief Sought (check appropriate item):
[] Cease and Desist
[] Civil Penalty(ies)/Fine(s)
[] Disgorgement
[] Injunction
[] Money Damages (Private/ Civil Complaint)
[] Restitution
[] Restraining Order
[] Other ___
Other Relief Sought:
3. Filing Date of Court Action (MM/DD/YYYY): _____ [] Exact []
				Explanation
If not exact, provide explanation:
						  ____________________________________________________________
4. Principal Product Type (check appropriate item):
[] Annuity(ies) - Fixed
[] Annuity(ies) - Variable
[] CD(s)
[] Commodity Option(s)
[] Debt - Asset Backed
[] Debt - Corporate
[] Debt - Government
[] Debt - Municipal
[] Derivative(s)
[] Direct Investment(s) - DPP & LP Interest(s)
[] Equity - OTC
[] Equity Listed (Common &Preferred Stock)
[] Futures - Commodity
[] Futures - Financial
[] Index Option(s)
[] Insurance
[] Investment Contract(s)
[] Money Market Fund(s)
[] Mutual Fund(s)
[] No Product
[] Options
[] Penny Stock(s)
[] Unit Investment Trust(s)
[] Other ____
Other Product Types:
5. Formal Action was brought in (include name of Federal, State
				or Foreign Court, Location of Court - City or County
and
State
				or Country, Docket/Case Number):
6.
Advisory Affiliate
Employing Firm when
				activity occurred which led to the civil judicial action (if
				applicable):
(continued)
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
(
continuation
)
7. Describe the allegations related to this civil action (your
				response must fit within the space provided):
8. Current status? [] Pending [] On Appeal [] Final
9. If on appeal, action appealed to (provide name of court) and
				Date Appeal Filed (MM/DD/YYYY):
10. If pending, date notice/process was served (MM/DD/YYYY)
				___[] Exact [] Explanation
If not exact, provide explanation:
						  _________________________________________________________________
If Final or On Appeal, complete all items below. For Pending
				Actions, complete Item 14 only.
11. How was matter resolved (check appropriate item):
[] Consent
[] Dismissed
[] Judgment Rendered
[] Opinion
[] Settled
[] Withdrawn
[] Other ___
12. Resolution Date (MM/DD/YYYY): ____ [] Exact []
				Explanation
If not exact, provide explanation:
						  __________________________________________________________________
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief
				Granted (check appropriate items)?
[] Monetary/Fine [] Revocation/Expulsion/Denial []
				Disgorgement/Restitution
Amount: $ ___ [] Censure [] Cease and Desist/Injunction [] Bar
				[] Suspension
B. Other Sanctions:
(continued)
CIVIL JUDICIAL ACTION DISCLOSURE REPORTING PAGE (ADV)
(
continuation
)
C. Sanction detail: if suspended, enjoined or barred, provide
				duration including start date and capacities affected (General Securities
				Principal, Financial Operations Principal, etc.). If requalification by
				exam/retraining was a condition of the sanction, provide length of time given
				to requalify/retrain, type of exam required and whether condition has been
				satisfied. If disposition resulted in a fine, penalty, restitution,
				disgorgement or monetary compensation, provide total amount, portion levied
				against you or an
advisory affiliate,
date paid and if any
				portion of penalty was waived:
14. Provide a brief summary of circumstances related to the
				action(s), allegation(s), disposition(s) and/or finding(s) disclosed above
				(your response must fit within the space provided).
BOND DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Item 2.C. of Part 1B of Form ADV.
Use a separate DRP for each event or
proceeding
. The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
Your Name
Your
CRD
Number
1. Firm Name: (Policy Holder)
2. Bonding Company Name:
3. Disposition Type: (check appropriate item)
[] Denied [] Payout [] Revoked
4. Disposition Date (MM/DD/YYYY): ____ [] Exact []
				Explanation
If not exact, provide explanation:
						  ______________________________________________________________
5. If disposition resulted in Payout; list Payout Amount and
				Date Paid:
6. Summarize the details of circumstances leading to the
				necessity of bonding company action: (your response must fit within the space
				provided):
JUDGMENT / LIEN DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Item 2.D. of Part 1B of Form ADV.
Use a separate DRP for each event or
proceeding.
The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
Your Name
Your
CRD
Number
1. Judgment/Lien Amount:
2. Judgment/Lien Holder:
3. Judgment/Lien Type: (check appropriate item)
[] Civil [] Default [] Tax
4. Date Filed (MM/DD/YYYY): ____ [] Exact [] Explanation
If not exact, provide explanation:
						  _____________________________________________________________
5. Is Judgment/Lien outstanding? [] Yes [] No
If no, provide status date (MM/DD/YYYY): ____ [] Exact []
				Explanation
If not exact, provide explanation:
						  _____________________________________________________________
If no, how was matter resolved? (check appropriate item)
[] Discharged [] Released [] Removed [] Satisfied
6. Court (Name of Federal, State or Foreign Court), Location of
				Court (City or County
and
State or Country) and Docket/Case
				Number:
7. Provide a brief summary of events leading to the action and
				any payment schedule details including current status (if applicable) (your
				response must fit within the space provided):
ARBITRATION DISCLOSURE REPORTING PAGE (ADV)
GENERAL
							 INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an []
							 INITIAL
OR
[] AMENDED response used to report details for
							 affirmative responses to Item 2.E. of Part 1B of Form ADV.
Check Part 1B item(s) being responded to: [] 2.E(1)
							 [] 2.E(2) [] 2.E(3) [] 2.E(4) [] 2.E(5)
Use a separate DRP for each event or
proceeding.
The same event or
proceeding
may
							 be reported for more than one
person
or entity using one DRP.
							 File with a completed Execution Page.
One event may result in more than one affirmative
							 answer to Item 2.E. Use only one DRP to report details related to the same
							 event. Unrelated arbitration actions must be reported on separate
							 DRPs.
PART I
A. The
person(s)
or entity(ies) for whom this
				DRP is being filed is (are): [] You (the advisory firm) [] You and one or more
				of your
advisory affiliates
[] One or more of your
advisory affiliates
If this DRP is being filed for an
advisory
				affiliate,
give the full name of the
advisory
				affiliate
below (for individuals, Last name, First name, Middle
				name).
If the
advisory affiliate
has a
CRD
number, provide that number. If not, indicate
				"non-registered" by checking the appropriate checkbox.
Your Name
Your
CRD
Number
ADV DRP -
ADVISORY AFFILIATE
CRD Number
This
advisory affiliate
is [] a firm []
						  an individual Registered: [] Yes [] No
Name (For individuals, Last, First, Middle)
[] This DRP should be removed from the ADV record because the
advisory affiliate(s)
is no longer associated with the
				adviser.
NOTE: The completion of this form does not relieve the
advisory affiliate
of its obligation to update its IARD or
CRD
records.
PART II
1. Arbitration/Reparation Claim initiated by: (Name of private
				plaintiff, firm, etc.)
2. Principal Relief Sought (check appropriate item)
[] Restraining Order
[] Civil Penalty(ies)/Fine(s)
[] Disgorgement
[] Injunction
[] Money Damages (Private/Civil Claim)
[] Restitution
[] Other ___
(continued)
ARBITRATION DISCLOSURE REPORTING PAGE (ADV)
(continuation)
Other Relief Sought:
3. Initiation Date of Arbitration/Reparation Claim
				(MM/DD/YYYY): _____ [] Exact [] Explanation
If not exact, provide explanation:
						  ______________________
4. Principal Product Type (check appropriate item):
[] Annuity(ies) - Fixed
[] Annuity(ies) - Variable
[] CD(s)
[] Commodity Option(s)
[] Debt - Asset Backed
[] Debt - Corporate
[] Debt - Government
[] Debt - Municipal
[] Derivative(s)
[] Direct Investment(s) - DPP & LP Interest(s)
[] Equity - OTC
[] Equity Listed (Common &Preferred Stock)
[] Futures - Commodity
[] Futures - Financial
[] Index Option(s)
[] Insurance
[] Investment Contract(s)
[] Money Market Fund(s)
[] Mutual Fund(s)
[] No Product
[] Options
[] Penny Stock(s)
[] Unit Investment Trust(s)
[] Other ____
Other Product Types:
5. Arbitration/Reparation Claim was filed with
				(
NASD,
AAA, NYSE, CBOE, CFTC, etc.) and Docket/Case
				Number:
6.
Advisory Affiliate
Employing Firm when
				activity occurred which led to the arbitration/reparation (if
				applicable):
7. Describe the allegations related to this
				arbitration/reparation (your response must fit within the space
				provided):
8. Current status? [] Pending [] On Appeal [] Final
9. If on appeal, action appealed to (provide name of court) and
				Date Appeal Filed (MM/DD/YYYY):
(continued)
ARBITRATION DISCLOSURE REPORTING PAGE (ADV)
(continuation)
10. If pending, date notice/process was served (MM/DD/YYYY):
				_____ [] Exact [] Explanation
If not exact, provide explanation:
						  _____________________________
If Final or On Appeal, complete all items below. For Pending
				Actions, complete Item 14 only.
11. How was matter resolved (check appropriate item):
[] Consent
[] Dismissed
[] Judgment Rendered
[] Opinion
[] Settled
[] Withdrawn
[] Other ___
12. Resolution Date (MM/DD/YYYY): ____ [] Exact []
				Explanation
If not exact, provide explanation:
						  _______________________________
13. Resolution Detail:
A. Were any of the following Sanctions Ordered or Relief
				Granted (check appropriate items)?
[] Monetary Award [] Settlement []
				Disgorgement/Restitution
Amount: $ ___ [] Injunction
B. Other Sanctions:
C. Sanction detail: if disposition resulted in a penalty,
				restitution, disgorgement or monetary compensation, provide total amount,
				portion levied against you or an
advisory affiliate,
date paid
				and if any portion of the penalty was waived:
14. Provide a brief summary of circumstances related to the
				action(s), allegation(s), disposition(s) and/or finding(s) disclosed above
				(your response must fit within the space provided).
FORM ADV
Uniform Application for Investment Adviser Registration
Part II - Page 1
Name of Investment Adviser:
Address: (Number and Street) (City) (State) (Zip
						  Code)
Area Code Telephone Number
()
This part of Form ADV gives information about the investment
				adviser and its business for the use of clients.
The information has not been approved or verified by any
				governmental authority.
Table of Contents
Item Number Item
				Page
..................................
1
.....................................................................
Advisory Services and Fees
2
2
........................................................................
Types of Clients
2
3
........................................................................
Types of Investments
3
4
........................................................................
Methods of Analysis, Sources of Information and Investment
				Strategies
3
5
............................................................................
Education and Business Standards
4
6
................................................................................
Education and Business Background
4
7
...............................................................................
Other Business Activities
4
8
...................................................................................
Other Financial Industry Activities or Affiliations
4
9
....................................................................................
Participation or Interest in Client Transactions
5
10
....................................................................................
Conditions for Managing Accounts
5
11
......................................................................................
Review of Accounts
5
12
.......................................................................................
Investment or Brokerage Discretion
6
13
.....................................................................................
Additional Compensation
6
14
.........................................................................................
Balance Sheet
6
...........................................................................................
Continuation Sheet
Schedule F
.............................................................................................
Balance Sheet, if required
Schedule G
(Schedules A, B, C, D, and E are included with
						  Part I of this Form, for the use of regulatory bodies, and are not distributed
						  to clients.)
Potential persons who are to respond to the collection of
				information contained in this form are not required to respond unless the form
				displays a currently valid OMB control number.
FORM ADV
Part II - Page 2
Applicant:
SEC File Number: 801-
Date:
1. A. Advisory Services and Fees. (check the
						  applicable boxes) For each type of service provided, state the approximate
						  .......
% of total advisory billings from that
						  service.
..........................................................................................................................................(See
						  instruction below.) .......
Applicant:
[] (1)
Provides investment supervisory services
						  ...........................................
________%
[] (2)
Manages investment advisory accounts not involving
						  investment supervisory services .......
________%
[] (3)
Furnishes investment advice through consultations not
						  included in either service described above .......
________%
[] (4)
Issues periodicals about securities by subscription
						  .......
________%
[] (5)
Issues special reports about securities not included in
						  any service described above .......
________%
[] (6)
Issues, not as part of any service described above, any
						  charts, graphs, formulas, or other devices which clients may use to evaluate
						  securities .....................................
________%
[] (7)
On more than an occasional basis, furnishes advice to
						  clients on matters not involving securities
						  .........................................
________%
[] (8)
Provides a timing service
						  ............................................
________%
[] (9)
Furnishes advice about securities in any manner not
						  described above .......................................
________%
(Percentages should be based on applicant's
						  last fiscal year. If applicant has not completed its first fiscal year, provide
						  estimates of advisory billings for that year and state that the percentages are
						  estimates.)
Yes No
B. Does applicant call any of the services
						  it checked above financial planning or some similar term?
						  ..................................
[] []
C. Applicant offers investment advisory
						  services for: (check all that apply)
[] (1)
A percentage of assets under management
						  ...................................................................................................................................................................
						  [] (4) Subscription fees
[] (2)
Hourly charges
						  ...................................................................................................................................................................
						  [] (5) Commissions
[] (3)
Fixed fees (not including subscription fees)
						  ...................................................................................................................................................................
						  [] (6) Other
D. For each checked box in A above, describe
						  on Schedule F:
*
the services provided, including the name of any
						  publication or report issued by the adviser on a subscription basis or for a
						  fee
*
applicant's basic fee schedule, how fees are charged and
						  whether its fees are negotiable
*
when compensation is payable, and if compensation is
						  payable before service is provided, how a client may get a refund or may
						  terminate an investment advisory contract before its expiration date
2.
Types of clients
-Applicant
						  generally provides investment advice to: (check those that apply)
[] A.
Individuals
						  ..........................................................................................................................................................................................
						  [] E. Trusts, estates, or charitable organizations
[] B.
Banks or thrift institutions [] F.
						  Corporations or business entities other than those listed above
						  ............................
[] C.
Investment companies
						  .........................................................................................................................................................................................
						  [] G. Other (describe on Schedule F)
[] D.
Pension and profit sharing plans
Answer all items. Complete amended pages in full,
						  circle amended items and file with execution page (page 1).
FORM ADV
Part II - Page 3
Applicant:
SEC File Number: 801-
Date:
3.
Types of Investments.
Applicant offers advice on the following: (check those that apply)
A.
Equity securities
[] H.
United States government securities
[]
(1) exchange-listed securities
I.
Options contracts on:
[]
(2) securities traded over-the-counter
[]
(3) foreign issuers
[]
(1) securities
(2) commodities
[]
[] B.
Warrants
J.
Futures contracts on:
[] C.
Corporate debt securities (other than commercial
						  paper)
[]
(1) tangibles
[]
(2) intangibles
[] D.
Commercial paper
[] E.
Certificates of deposit
K.
Interests in partnerships investing in:
[] F.
Municipal securities
[]
(1) real estate
[]
(2) oil and gas interests
G.
Investment company securities:
[]
(3) other (explain on Schedule F)
[]
(1) variable life insurance
[]
(2) variable annuities
[] L.
Other (explain on Schedule F)
[]
(3) mutual fund shares
4.
Methods of Analysis, Sources of
						  Information, and Investment Strategies.
A. Applicant's security analysis methods
						  include: (check those that apply)
(1) []
Charting
(4) []
Cyclical
(2) []
Fundamental
(5) []
Other (explain on Schedule F)
(3) []
Technical
B. The main sources of information applicant
						  uses include: (check those that apply)
(1) []
Financial newspapers and magazines
(5) []
Timing services.
(2) []
Inspections of corporate activities
(6) []
Annual reports, prospectuses, filings with the
(3) []
Research materials prepared by others
Securities and Exchange Commission
(4) []
Corporate rating services
(7) []
Company press releases
(8) []
Other (explain on Schedule F)
C. The investment strategies used to
						  implement any investment advice given to clients include: (check those that
						  apply)
(1) []
Long term purchases
(5) []
Margin transactions
(securities held at least a year)
(6) []
Option writing, including covered options,
(2) []
Short term purchases
uncovered options, or spreading strategies
(Securities sold within a year)
(7) []
Other (explain on Schedule F)
(3) []
Trading (securities sold within 30 days)
(4) []
Short sales
Answer all items. Complete amended pages in full,
						  circle amended items and file with execution page (page 1).
FORM ADV Part II - Page 4
Applicant:
SEC File Number: 801-
Date:
5.
Education and Business
						  Standards.
Are there any general standards of education
						  or business experience that applicant requires of those involved in determining
						  or giving investment advice to clients? .......
Yes No [] []
(If yes, describe these standards on Schedule F.)
6.
Education and Business
						  Background.
For:
*
each member of the investment committee or group that
						  determines general investment advice to be given to clients, or
*
if the applicant has no investment committee or group,
						  each individual who determines general investment advice given to clients (if
						  more than five, respond only for their supervisors)
*
each principal executive officer of applicant or each
						  person with similar status or performing similar functions
On Schedule F, give the:
*
name " formal education after high school
						  ...........................................................
*
year of birth " business background for the preceding
						  five years ..................................................
7.
Other Business Activities.
(check those that apply)
[] A.
Applicant is actively engaged in a business other than
						  giving investment advice.
[] B.
Applicant sells products or services other than
						  investment advice to clients.
[] C.
The principal business of applicant or its
						  principal executive officers involves something other than providing investment
						  advice.
(For each checked box describe the other
						  activities, including the time spent on them, on Schedule F.)
8.
Other Financial Industry Activities
						  or Affiliations.
(check those that apply)
[] A.
Applicant is registered (or has an application pending)
						  as a securities broker-dealer.
[] B.
Applicant is registered (or has an
						  application pending) as a futures commission merchant, commodity pool operator
						  or commodity trading adviser.
C.
Applicant has arrangements that are material
						  to its advisory business or its clients with a related person who is a:
[] (1)
broker-dealer [] (7) accounting firm
						  ...............................................................................
[] (2)
investment company [] (8) law firm
						  ....................................................................
[] (3)
other investment adviser [] (9) insurance
						  company or agency .....................................................
[] (4)
financial planning firm [] (10) pension
						  consultant ..................................................
[] (5)
commodity pool operator, commodity trading
						  [] (11) real estate broker or dealer ..................................
adviser or futures commission merchant
[] (6)
banking or thrift institution [] (12) entity
						  that creates or packages limited partnerships .......
(For each checked box in C, on Schedule F
						  identify the related person and describe the relationship and the
						  arrangements.)
D.
Is applicant or a related person a general partner in
						  any partnership in which clients are solicited to invest? .......
Yes No [] []
(If yes, describe on Schedule F the
						  partnerships and what they invest in.)
Answer all items. Complete amended pages in full,
						  circle amended items and file with execution page (page 1).
FORM ADV Part II - Page 5
Applicant:
SEC File Number: 801-
Date:
9.
Participation or Interest in Client
						  Transactions.
Applicant or a related person: (check those
						  that apply)
[] A.
As principal, buys securities for itself from or sells
						  securities its owns to any client.
[] B.
As broker or agent effects securities transactions for
						  compensation for any client.
[] C.
As broker or agent for any person other than a client
						  effects transactions in which client securities are sold to or brought from a
						  brokerage customer.
[] D.
Recommends to clients that they buy or sell securities or
						  investment products in which the applicant or a related person has some
						  financial interest.
[] E.
Buys or sells for itself securities that is also
						  recommends to clients.
(For each box checked, describe on Schedule F when the
						  applicant or a related person engages in these transactions and what
						  restrictions, internal procedures, or disclosures are used for conflicts of
						  interest in those transactions.)
10.
Conditions for Managing
						  Accounts.
Does the applicant provide investment supervisory services,
						  manage investment advisory accounts or hold itself out as providing financial
						  planning or some similarly termed services
and
impose a
						  minimum dollar value of assets or other conditions for starting or maintaining
						  an account?
						  ......................................................................................
Yes No [] []
(If yes, describe on Schedule F.)
11.
Review of Accounts.
If
						  applicant provides investment supervisory services, manages investment advisory
						  accounts, or holds itself out as providing financial planning or some similarly
						  termed services:
A.
Describe below the reviews and reviewers of the accounts.
For reviews,
include their frequency, different levels, and
						  triggering factors.
For reviewers,
include the number of
						  reviewers, their titles and functions, instructions they receive from applicant
						  on performing reviews, and number of accounts assigned each.
B.
Describe below the nature and frequency of regular
						  reports to clients on their accounts.
Answer all items. Complete amended pages in full,
						  circle amended items and file with execution page (page 1).
FORM ADV Part II - Page 6
Applicant:
SEC File Number: 801-
Date:
12.
Investment or Brokerage
						  Discretion.
A.
Does applicant or any related person have authority to
						  determine, without obtaining specific client consent, the:
(1) securities to be bought or sold?
						  ..........................................................................
Yes No [] []
(2) amount of the securities to be bought or sold?
						  ............................................................................
Yes No [] []
(3) broker or dealer to be used?
						  ........................................................................................
Yes No [] []
(4) commission rates paid?
						  ...........................................................................................................
Yes No [] []
B.
Does applicant or a related person suggest brokers to
						  clients? ..........................................................
Yes No [] []
For each yes answer to A describe on Schedule F any
						  limitations on the authority. For each yes to A(3), A(4) or B, describe on
						  Schedule F the factors considered in selecting brokers and determining the
						  reasonableness of their commissions. If the value of products, research and
						  services given to the applicant or a related person is a factor, describe:
* the products, research and services
* whether clients may pay commissions higher than those
						  obtainable from other brokers in return for those products and services
* whether research is used to service all of applicant's
						  accounts or just those accounts paying for it; and
* any procedures the applicant used during the last
						  fiscal year to direct client transactions to a particular broker in return for
						  products and research services received.
13.
Additional
						  Compensation.
Does the applicant or a related person have
						  any arrangements, oral or in writing, where it:
A.
is paid cash by or receives some economic benefit
						  (including commissions, equipment or non- research services) from a non-client
						  in connection with giving advice to clients? ...............................
Yes No [] []
B.
directly or indirectly compensates any person for client
						  referrals? ..................................................
Yes No [] []
(For each yes, describe the arrangements on Schedule
						  F.)
14.
Balance Sheet.
Applicant
						  must provide a balance sheet for the most recent fiscal year on Schedule G if
						  applicant:
*
has custody of client funds or securities; or
*
requires prepayment of more than $500 in fees per client
						  and 6 or more months in advance
Has applicant provided a Schedule G balance sheet?
						  .......
Yes No [] []
Answer all items. Complete amended pages in full,
						  circle amended items and file with execution page (page 1).
Schedule F of FORM ADV Continuation Sheet for Form
						  ADV Part II
Applicant:
SEC File Number: 801-
Date:
(Do not use this Schedule as a continuation sheet for Form ADV
				Part I or any other schedules.)
1. Full name of applicant exactly as stated in Item 1A of
						  Part I of Form ADV:
IRS Empl. Ident. No.:
Item of Form (identify)
Answer
Complete amended pages in full, circle amended
						  items and file with execution page (page 1).
Schedule G of Form ADV Balance Sheet
Applicant:
SEC File Number: 801-
Date:
(Answers in Response to Form ADV Part II Item 14.)
1. Full name of applicant exactly as stated in Item 1A of
						  Part I of Form ADV:
IRS Empl. Ident. No.:
Instructions
1. The balance sheet must be:
A. Prepared in accordance with generally accepted
						  accounting principles ....................................................
B. Audited by an independent public accountant
						  ......................................................
C. Accompanied by a note stating the principles used to
						  prepare it, the basis of included securities, and any other explanations
						  required for clarity.
						  .............................................................................
2. Securities included at cost should show their market
						  or fair value parenthetically.
3. Qualifications and any accompanying independent
						  accountant's report must conform to Article 2 of Regulation S-X (17 CFR
						  210.2-01 et seq.).
4. Sole proprietor investment advisers:
A. Must show investment advisory business assets and
						  liabilities separate from other business and personal assets and liabilities
						  ..............................................................
B. May aggregate other business and personal assets and
						  liabilities unless there is an asset deficiency in the total financial
						  position. .....................................................................
Complete amended pages in full, circle amended
						  items and file with execution page (page 1).
Schedule H of Form ADV Page 1
Applicant:
SEC File Number: 801-
Date: MM/DD/YY
(for sponsors of wrap fee programs)
Name of wrap fee program or programs described in
						  attached brochure:
1.
Applicability of
						  Schedule.
This Schedule must be completed by applicants that
						  are compensated under a wrap fee program for sponsoring, organizing, or
						  administering the program, or for selecting, or providing advice to clients
						  regarding the selection of, other investment advisers in the program
						  ("sponsors"). A wrap fee program is any program under which a specified fee or
						  fees not based directly upon transactions in a client's account is charged for
						  investment advisory services (which may include portfolio management or advice
						  concerning the selection of other investment advisers) and execution of client
						  transactions.
2.
Use of Schedule.
This
						  Schedule sets forth the information the sponsor must include in the wrap fee
						  brochure it is required to deliver or offer to deliver to clients and
						  prospective clients of its wrap fee programs under Rule 204-3 of the federal
						  Advisers Act and similar rules of the jurisdictions. The wrap fee brochure
						  prepared in response to this Schedule must be filed with the Commission and the
						  jurisdictions as part of Form ADV by completing the identifying information on
						  this Schedule and attaching the brochure. Brochures should be prepared
						  separately, not on copies of this Schedule. Any wrap fee brochure filed with
						  the Commission as part of an amendment to Form ADV shall contain in the upper
						  right hand corner of the cover page the sponsor's registration number (801-
						).
3.
General Contents of
						  Brochure.
Unlike Parts I and II of this form, this Schedule is
						  not organized in "check-the- box" format. These instructions, including the
						  requests for information in Item 7 below, should not be repeated in the
						  brochure. Rather, this Schedule describes minimum disclosures that must be made
						  in the brochure to satisfy the sponsor's duty to disclose all material facts
						  about the sponsor and its wrap fee programs.
Nothing in this Schedule
						  relieves the sponsor from any obligation under any provision of the federal
						  Advisers Act or rules thereunder, or other federal or state law to disclose
						  information to its advisory clients or prospective advisory clients not
						  specifically required by this Schedule.
4.
Multiple Sponsors.
If
						  two or more persons fall within the definition of "sponsor" in Item 1 above for
						  a single wrap fee program, only one such sponsor need complete the Schedule.
						  The sponsors may choose among themselves the sponsor that will complete the
						  Schedule.
5.
Omission of Inapplicable
						  Information.
Any information not specifically required by this
						  Schedule that is included in the brochure should be applicable to clients and
						  prospective clients of the sponsor's wrap fee programs. If the sponsor is
						  required to complete this Schedule with respect to more than one wrap fee
						  program, the sponsor may omit from the brochure furnished to clients and
						  prospective clients of any wrap fee program or programs information required by
						  this Schedule that is not applicable to clients or prospective clients of that
						  wrap fee program or programs. If a sponsor of more than one wrap fee program
						  prepares separate wrap fee brochures for clients of different programs, each
						  brochure prepared must be filed with the Commission and the jurisdictions
						  attached to a separate copy of this Schedule. Each such brochure must state
						  that the sponsor sponsors other wrap fee programs and state how brochures for
						  those programs may be obtained.
6.
Updating.
Sponsors are
						  required to file an amendment to the brochure promptly after any information in
						  the brochure becomes materially inaccurate. Amendments may be made by use of a
						  "sticker,"
i.e.,
a supplement affixed to the brochure that
						  indicates what information is being added or updated and states the new or
						  revised information, as long as the resulting brochure is readable. Stickers
						  should be dated and should be incorporated into the text of the brochure when
						  the brochure itself is revised.
7.
Contents of Brochure.
Include in the brochure prepared in response to this Schedule:
(a) on the cover page, the sponsor's name, address,
						  telephone number, and the following legend in bold type or some other prominent
						  fashion: .......
This brochure provides clients with information
						  about [name of sponsor] and the [name of program or programs] that should be
						  considered before becoming a client of the [name of program or programs]. This
						  information has not been approved or verified by any governmental
						  authority.
(b) a table of contents reflecting the subject headings
						  in the sponsor's brochure; ...................................................
(c) the amount of the wrap fee charged for each program
						  or, if fees vary according to a schedule established by the sponsor, a table
						  setting forth the fee schedule, whether such fees are negotiable, the portion
						  of the total fee (or the range of such amounts) paid to persons providing
						  advice to clients regarding the purchase or sale of specific securities under
						  the program ("portfolio managers"), and the services provided under each
						  program (including the types of portfolio management services);
						  ............................................................................
Schedule H of Form ADV Page 2
Applicant:
SEC File Number: 801-
Date: MM/DD/YY
(d)
a statement that the program may cost the client more or
						  less than purchasing such services separately and a statement of the factors
						  that bear upon the relative cost of the program (
e.g.,
the
						  cost of the services if provided separately and the trading activity in the
						  client's account);
(e)
if applicable, a statement that the person recommending
						  the program to the client receives compensation as a result of the client's
						  participation in the program, that the amount of this compensation may be more
						  than what the person would receive if the client participated in other programs
						  of the sponsor or paid separately for investment advice, brokerage, and other
						  services, and that the person may therefore have a financial incentive to
						  recommend the wrap fee program over other programs or services;
(f)
a description of the nature of any fees that the client
						  may pay in addition to the wrap fee and the circumstances under which these
						  fees may be paid (including, if applicable, mutual fund expenses and mark-ups,
						  mark-downs or spreads paid to market makers from whom securities were obtained
						  by the wrap fee broker);
(g)
how the program's portfolio managers are selected and
						  reviewed, the basis upon which portfolio managers are recommended or chosen for
						  particular clients, and the circumstances under which the sponsor will replace
						  or recommend the replacement of the portfolio manager;
(h)
(1) if applicable, a statement to the effect that
						  portfolio manager performance information is not reviewed by the sponsor or a
						  third party and/or that performance information is not calculated on a uniform
						  and consistent basis,
(2) if performance information is reviewed to determine
						  its accuracy, the name of the party who reviews the information and a brief
						  description of the nature of the review,
(3) a reference to any standards (
i.e.,
industry standards or standards used solely by the sponsor) under which
						  performance information may be calculated;
(i)
a description of the information about the client that is
						  communicated by the sponsor to the client's portfolio manager, and how often or
						  under what circumstances the sponsor provides updated information about the
						  client to the portfolio manager;
(j)
any restrictions on the ability of clients to contact and
						  consult with portfolio managers;
(k)
in narrative text, the information required by Items 7
						  and 8 of Part II of this form and, as applicable to clients of the wrap fee
						  program, the information required by Items 2, 5, 6, 9A and C, 10, 11, 13 and 14
						  of Part II;
(l)
if any practice or relationship disclosed in response to
						  Item 7, 8, 9A, 9C and 13 of Part II presents a conflict between the interests
						  of the sponsor and those of its clients, explain the nature of any such
						  conflict of interest; and
(m)
if the sponsor or its divisions or employees covered
						  under the same investment adviser registration as the sponsor act as portfolio
						  managers for a wrap fee program described in the brochure, a brief, general
						  description of the investments and investment strategies utilized by those
						  portfolio managers.
8.
Organization and Cross
						  References.
Except for the cover page requirements in Item 7(a)
						  above, information contained in the brochure need not follow the order of the
						  items listed in Item 7. However, the brochure should not be organized in such a
						  manner that important information called for by the form is obscured.
Set forth below the page(s) of the brochure
						  on which the various disclosures required by Item 7 are provided.
Page(s)
Page(s)
Page(s)
...............................................................................
Item 7(a) cover
						  ...........................................................................................................................................................................
						  Item 7(f) Item 7(j)
#7(b)................................................................................................................................................................................
						  # 7(g) #7(k)
#7(c).................................................................................................................................................................................
						  # 7(h) #7(l)
#7(d).......................................................................................................................................................................
						  # 7(i) #7(m)
#7(e)
FORM ADV (Paper Version)
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
DOMESTIC INVESTMENT ADVISER EXECUTION
						  PAGE
You must complete the following Execution Page to Form ADV.
				This execution page must be signed and attached to your initial application for
				SEC registration and all amendments to registration.
Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned
				adviser, irrevocably appoint the Secretary of State or other legally designated
				officer, of the state in which you maintain your
principal office and
				place of business
and any other state in which you are submitting a
notice filing,
as your agents to receive service, and agree
				that such persons may accept service on your behalf, of any notice, subpoena,
				summons,
order
instituting
proceedings,
demand for arbitration, or other process or papers, and you further agree that
				such service may be made by registered or certified mail, in any federal or
				state action, administrative
proceeding
or arbitration brought
				against you in any place subject to the jurisdiction of the United States, if
				the action,
proceeding
or arbitration (a) arises out of any
				activity in connection with your investment advisory business that is subject
				to the jurisdiction of the United States, and (b) is founded, directly or
				indirectly, upon the provisions of: (i) the Securities Act of 1933, the
				Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the
				Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any
				rule or regulation under any of these acts, or (ii) the laws of the state in
				which you maintain your
principal office and place of business
or of any state in which you are submitting a
notice
				filing.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with
				the authority of, the investment adviser. The investment adviser and I both
				certify, under penalty of perjury under the laws of the United States of
				America, that the information and statements made in this ADV, including
				exhibits and any other information submitted, are true and correct, and that I
				am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be
				preserved and available for inspection as required by law. Finally, I authorize
				any
person
having
custody
or possession of
				these books and records to make them available to federal and state regulatory
				representatives.
Signature: __________ Date: _______
				.....................................................................................................
Printed Name: __________ Title: _______
				.............................................................................
Adviser
CRD
Number: _______
FORM ADV (Paper Version)
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
STATE-REGISTERED INVESTMENT ADVISER EXECUTION
						  PAGE
You must complete the following Execution Page to Form ADV.
				This execution page must be signed and attached to your initial application for
				state registration and all amendments to registration.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned
				adviser, irrevocably appoint the legally designated officers and their
				successors, of the state in which you maintain your
principal office
				and place of business
and any other state in which you are applying
				for registration or amending your registration, as your agents to receive
				service, and agree that such persons may accept service on your behalf, of any
				notice, subpoena, summons,
order
instituting
proceedings,
demand for arbitration, or other process or
				papers, and you further agree that such service may be made by registered or
				certified mail, in any federal or state action, administrative
proceeding
or arbitration brought against you in any place
				subject to the jurisdiction of the United States, if the action,
proceeding
or arbitration (a) arises out of any activity in
				connection with your investment advisory business that is subject to the
				jurisdiction of the United States, and (b) is founded, directly or indirectly,
				upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange
				Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
				1940, or the Investment Advisers Act of 1940, or any rule or regulation under
				any of these acts, or (ii) the laws of the state in which you maintain your
principal office and place of business
or of any state in
				which you are applying for registration, or amending your registration.
2. State-Registered Investment Adviser Affidavit
If you are subject to state regulation, by signing this Form
				ADV, you represent that, you are in compliance with the registration
				requirements of the state in which you maintain your principal place of
				business and are in compliance with the bonding, capital, and recordkeeping
				requirements of that state.
Signature
I, the undersigned, sign this Form ADV on behalf of, and with
				the authority of, the investment adviser. The investment adviser and I both
				certify, under penalty of perjury under the laws of the United States of
				America, that the information and statements made in this ADV, including
				exhibits and any other information submitted, are true and correct, and that I
				am signing this Form ADV Execution Page as a free and voluntary act.
I certify that the adviser's books and records will be
				preserved and available for inspection as required by law. Finally, I authorize
				any
person
having
custody
or possession of
				these books and records to make them available to federal and state regulatory
				representatives.
Signature: __________ Date: _______
				...........................................................................................
Printed Name: __________ Title: _______
				.............................................................................................
Adviser
CRD
Number: _______
FORM ADV (Paper Version)
UNIFORM APPLICATION FOR INVESTMENT ADVISER REGISTRATION
NON-RESIDENT
INVESTMENT ADVISER EXECUTION
PAGE 1
..............................................................................................
You must complete the following Execution Page to Form ADV.
				This execution page must be signed and attached to your initial application for
				SEC registration and all amendments to registration.
1. Appointment of Agent for Service of Process
By signing this Form ADV Execution Page, you, the undersigned
				adviser, irrevocably appoint each of the Secretary of the SEC, and the
				Secretary of State or other legally designated officer, of any other state in
				which you are submitting a
notice filing,
as your agents to
				receive service, and agree that such persons may accept service on your behalf,
				of any notice, subpoena, summons,
order
instituting
proceedings,
demand for arbitration, or other process or
				papers, and you further agree that such service may be made by registered or
				certified mail, in any federal or state action, administrative
proceeding
or arbitration brought against you in any place
				subject to the jurisdiction of the United States, if the action,
proceeding
or arbitration (a) arises out of any activity in
				connection with your investment advisory business that is subject to the
				jurisdiction of the United States, and (b) is founded, directly or indirectly,
				upon the provisions of: (i) the Securities Act of 1933, the Securities Exchange
				Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of
				1940, or the Investment Advisers Act of 1940, or any rule or regulation under
				any of these acts, or (ii) the laws of any state in which you are submitting a
notice filing.
2. Appointment and Consent: Effect on Partnerships
If you are organized as a partnership, this irrevocable power
				of attorney and consent to service of process will continue in effect if any
				partner withdraws from or is admitted to the partnership, provided that the
				admission or withdrawal does not create a new partnership. If the partnership
				dissolves, this irrevocable power of attorney and consent shall be in effect
				for any action brought against you or any of your former partners.
3.
Non-Resident
Investment Adviser Undertaking
				Regarding Books and Records
By signing this Form ADV, you also agree to provide, at your
				own expense, to the U.S. Securities and Exchange Commission at its principal
				office in Washington D.C., at any Regional or District Office of the
				Commission, or at any one of its offices in the United States, as specified by
				the Commission, correct, current, and complete copies of any or all records
				that you are required to maintain under Rule 204-2 under the Investment
				Advisers Act of 1940. This undertaking shall be binding upon you, your heirs,
				successors and assigns, and any person subject to your written irrevocable
				consents or powers of attorney or any of your general partners and
managing agents.
NON-RESIDENT
INVESTMENT ADVISER
						  EXECUTION
..
PAGE 2
.....................................................
Signature
I, the undersigned, sign this Form ADV on behalf of, and with
				the authority of, the
non-resident
investment adviser. The
				investment adviser and I both certify, under penalty of perjury under the laws
				of the United States of America, that the information and statements made in
				this ADV, including exhibits and any other information submitted, are true and
				correct, and that I am signing this Form ADV Execution Page as a free and
				voluntary act.
I certify that the adviser's books and records will be
				preserved and available for inspection as required by law. Finally, I authorize
				any
person
having
custody
or possession of
				these books and records to make them available to federal and state regulatory
				representatives.
Signature: __________ Date: _______
				..................................................................
Printed Name: __________ Title: _______
				..........................................................
Adviser
CRD
Number: _______
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