Klaff

• No — Form ADV Item 11 asks: “Do any of the events below involve you or any of your supervised persons?”
• No — Form ADV Item 11A(1) asks: “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?”
• No — Form ADV Item 11A(2) asks: “A. (2) been charged with any felony?”
• No — Form ADV Item 11B(1) asks: “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?”
• No — Form ADV Item 11B(2) asks: “B. (2) been charged with a misdemeanor listed in Item 11.B(1)?”
• No — Form ADV Item 11C(1) asks: “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?”
• No — Form ADV Item 11C(2) asks: “C. (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?”
• No — Form ADV Item 11C(3) asks: “C. (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?”
• No — Form ADV Item 11C(4) asks: “C. (4) entered an order against you or any advisory affiliate in connection with investment-related activity?”
• No — Form ADV Item 11C(5) asks: “C. (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?”
• No — Form ADV Item 11D(1) asks: “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?”
• No — Form ADV Item 11D(2) asks: “D. (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?”
• No — Form ADV Item 11D(3) asks: “D. (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?”
• No — Form ADV Item 11D(4) asks: “D. (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?”
• No — Form ADV Item 11D(5) asks: “D. (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?”
• No — Form ADV Item 11E(1) asks: “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?”
• No — Form ADV Item 11E(2) asks: “E. (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)?”
• No — Form ADV Item 11E(3) asks: “E. (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?”
• No — Form ADV Item 11E(4) asks: “E. (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?”
• No — Form ADV Item 11F asks: “F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?”
• No — Form ADV Item 11G asks: “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.?”
• No — Form ADV Item 11H(1)(a) asks: “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?”
• No — Form ADV Item 11H(1)(b) asks: “H. (1)(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?”
• No — Form ADV Item 11H(1)(c) asks: “H. (1)(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?”
• No — Form ADV Item 11H(2) asks: “H. (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)?”

Answers as filed by the adviser on Form ADV Part 1A, Item 11; question text quoted from the form. Details of each “Yes” are in the Disclosure Reporting Pages of the Form ADV (PDF) ↗.