Item 1: Cover Page ADV Part 2A
This brochure provides information about the qualification and business practices of Prometheus Financial Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at 415-272-3317, or by email at firstname.lastname@example.org. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority.
Additional information about Prometheus Financial Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov.
Registration does not imply a certain level of skill or training, and no inference to the contrary should be made.
CRD No: 314653
Item 2: Material Changes
This is Prometheus Financial Advisors, LLC’s first brochure. In the future, this section will be used to communicate any material changes.
Item 3: Table of Contents
- Item 1: Cover Page ADV Part 2A
- Item 2: Material Changes
- Item 3: Table of Contents
- Item 4: Advisory Business
- Item 5: Fees and Compensation
- Item 6: Performance-Based Fees & Side-by-Side Management
- Item 7: Types of Clients
- Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
- Item 9: Disciplinary Information
- Item 10: Other Financial Industry Activities and Affiliations
- Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
- Item 12: Brokerage Practices
- Item 13: Review of Accounts
- Item 14: Client Referrals and Other Compensation
- Item 15: Custody
- Item 16: Investment Discretion
- Item 17: Voting Client Securities
- Item 18: Financial Information
- Item 19: Requirements for State-Registered Advisers
- Item 1: Cover Page Part 2B: Paul Barnaby
Item 4: Advisory Business
Prometheus Financial Advisors, LLC (“Prometheus Financial Advisors”) the investment advisory arm, was formed March 24, 2021, along with its related entities, Prometheus Alternatives Investments, Inc., Prometheus Financial Advisor, LLC, Prometheus Access Manager, LLC, Prometheus Access Administrator, LLC, and Studio Prometheus, LLC (collectively, “Prometheus”) to be one of the world’s first social marketplace for alternative investments. The Prometheus platform couples a social network built around investment manager professionals, with an in-house media production team which helps clients produce high-quality videos, and a direct-to-consumer digital marketplace where investors can discover, research, and invest in opportunities across all alternative strategies. Prometheus' mission is to create access and transparency in a previously exclusive industry and is committed to bringing the highest quality fund managers, educational content, and investment opportunities to the largest number of global investors possible. The mission will be achieved by democratizing tools for wealth creation, closing educational and information gaps for investors, and reducing the operational friction across the alternatives investing lifecycle.
We are required to disclose all material conflicts of interest, which have been disclosed herein within the ADV Part 2A.
Prometheus Financial Advisors is 100% owned by its parent company, Prometheus Alternatives Investments, Inc. (“Prometheus Alternatives”). Michael Wang is the principal owner and CEO of Prometheus Alternatives.
Types of Advisory Services
Through the Prometheus Platform, users will gain access to video content, educational material, company’s news, and market information. Accredited investors will gain further access, following an accreditation process, to information related to unaffiliated private funds. Through the Prometheus platform, algorithms will be used to highlight unaffiliated private funds, based on the users’ interests and suitability. Further, well-vetted and qualified unaffiliated fund managers on the platform may be featured and/or highlighted at various points in time.
Prometheus Access Administrator, LLC (“Prometheus Access Administrator”) will set up a series of Feeder Funds, in which affiliated entity Prometheus Access Administrator serves as the sponsor and adviser. Prometheus Access Administrator has filed as an exempt reporting advisor with the SEC and State of California. The Feeder Funds will be funds which pool investor contributions to invest within one or more of the unaffiliated private funds identified on the Prometheus Platform. The Feeder Funds will allow for accredited investors to make investments into suitable unaffiliated private funds they may not otherwise have access to, due to the larger initial contribution requirements.
Feeder Funds will not be tailored to investors’ individual bespoke requirements or restrictions. The Investment Committee of Prometheus Financial Advisors will select the underlying unaffiliated funds that are presented on the Prometheus Platform based upon a robust due diligence process discussed further in Item 8 of this brochure. The investors utilizing the Prometheus Platform will have the opportunity to direct investments into one or more of the unaffiliated funds through a Feeder Fund.
Wrap Fee Programs
Prometheus Financial Advisors does not participate in wrap fee programs.
As of May 9, 2022, Prometheus Financial Advisors has $0 in discretionary and non-discretionary assets.
Item 5: Fees and Compensation
Prometheus Financial Advisors is not compensated for its services and therefore does not deduct fees from the client’s account. Investors in the Feeder Funds will not pay Prometheus Financial Advisors a management fee or performance fee. Users of the Prometheus Platform will not pay Prometheus Financial Advisors a fee for utilizing the Prometheus Platform. The sponsor, Prometheus Access Administrator, LLC, will charge the underlying unaffiliated private funds an administrative fee for the Feeder Funds’ investment. This administrative fee will be negotiated with each unaffiliated private fund. Investors will not be responsible for paying this administrative fee.
Prometheus Financial Advisors and its affiliated parties will not charge additional fees or expenses to the investors of the Feeder Funds. However, each of the underlying unaffiliated invested private funds of the Feeder Funds will have their own fees and expenses that will be allocated to applicable end investors within the Feeder Funds. Prometheus Financial Advisors will make available to each investor on its platform all fund-related documents on the invested unaffiliated private funds that will clearly detail the fees and expenses born by the investors. Lower fees for comparable services may be available from other sources. Additionally, investors in the unaffiliated funds will be responsible for commissions charged for the unaffiliated private funds transacting in underlying securities.
Fees Paid in Advance
The Feeder Funds, advised by Prometheus Access Administrator, will invest in a variety of unaffiliated private funds, including but not limited to private equity, private credit, hedge fund, and real estate funds. Investors will be responsible for all fees and expenses due up to point of liquidation and/or distribution in accordance with the terms of the unaffiliated private funds, which are charged in either advance or arrears for a specific time period (e.g. quarterly, annually, etc.) as defined in the respective unaffiliated fund’s documents. Prometheus Financial Advisors will make available to each investor on its platform all fund-related documents on the invested unaffiliated private funds that will clearly detail the fees and expenses born by the investors and terms for refunds, if any.
Supervised persons of Prometheus Financial will not receive additional compensation from investors for recommending the funds on the Prometheus Platform or on the invested capital raised by the Feeder Funds. Supervised Persons will not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. The affiliated broker dealer Prometheus Financial, LLC will receive a placement fee from the unaffiliated funds invested in by the Feeder Funds. The affiliated sponsor/advisor to the Feeder Funds, Prometheus Access Administrator, LLC will receive an administrative fee from the unaffiliated private funds of the Feeder Funds. Since Prometheus Financial is under common control with Prometheus Access Administrator, LLC and Prometheus Financial, LLC, shared supervised persons indirectly receive compensation for the sale of securities. This is the primary compensation for the related parties. This presents a conflict of interest, because supervised persons have a financial incentive to recommend investments in the products in which compensation is received. Investors have the option to invest in any of the unaffiliated private funds identified on the platform outside of Prometheus Financial and its related entities.
Item 6: Performance-Based Fees & Side-by-Side Management
Prometheus Financial Advisors does not charge a performance-based fee, however the unaffiliated private funds of the Feeder Funds may charge a performance fee, which will be clearly detailed in the respective funds’ related documents made available on the Prometheus Platform. In order to be charged a performance-based fee, the accredited investor must further be a Qualified Client, defined as having either $1.1 million in assets under management or $2.2 million in net worth. Prometheus Financial Advisors will make available to each investor on its platform all fund-related documents on the invested unaffiliated private funds that will clearly detail the fees and expenses born by the investors.
Item 7: Types of Clients
The Prometheus Platform will be available to Individuals, High Net Worth (HNW) Individuals, and Institutions. Access to details related to unaffiliated private funds will only be made available to accredited investors. Certain unaffiliated private funds may further restrict access to their information to only Qualified Clients or Qualified Purchasers. Additionally, only suitably accredited investors may invest in the Feeder Funds. The Prometheus Platform has the ability to enforce proper investor accreditation and suitability screening controls in an automated fashion. The clients of Prometheus Financial Advisors will be the Feeder Funds.
Each Feeder Fund will have its own minimum initial investment amount and minimum add-on subscription amount that is dependent upon the unaffiliated funds in which the Feeder Fund is investing within. However, investors will not have an ongoing account minimum once the initial subscription amount is satisfied to initiate the investment. The minimum investment will generally be $25,000, however, this may be waived.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Prometheus Financial Advisors has established an Investment Committee that performs a holistic due diligence evaluation process on every candidate unaffiliated private fund prior to their inclusion (or rejection) on the Prometheus Platform, as well as to the establishment of any Feeder Fund for the purposes of directing investment into said underlying, unaffiliated private fund.
Prometheus' fund selection process is the result of decades of combined expertise across the entire spectrum of the alternatives industry. Team members have experience with stock selection, portfolio construction, risk management, performance evaluation, investor reporting, hedge fund administration, and developing the technologies to support these functions. Our holistic due diligence process extends beyond an evaluation of Business, Investment, and Operational Risks and is reflected in the radical transparency required to participate in Prometheus' social community.
The Prometheus due diligence program takes a risk-based approach to assessing an unaffiliated private fund:
Business Risk: The risks that key business functions or processes unrelated to investment activities are not sufficiently resourced to support a successful investment program. This may include management changes, unsustainable cost structures, insufficient assets, or other situations which could negatively impact investment processes.
Investment Risk: These are risks related to the investment decision making process, including security selection, portfolio construction, leverage and position sizing, as well as position-specific and market-related risks. Such risks may also include financial statistics such as volatility, as well as underperformance versus target returns.
Operational Risk: The risks that the operational processes and infrastructure supporting investment decisions and activities, including such functions as portfolio accounting and valuation, fund administration, and IT security, are not sufficiently robust or resourced. Once again, risks in these areas can result in investment risks.
Data is gathered using technology to allow for an efficient gathering and comprehensive assessment of critical fund data. Each unaffiliated fund candidate is reviewed on a granular level, taking into consideration factors such as, but not limited to, people, philosophy, performance, process, and the portfolio. The Investment Committee evaluates unaffiliated funds across their executive and investment teams, their track record and investment program quality, portfolio risk management, operational risk management, valuation policy, audit and fund governance, legal, compliance, and technology, including data privacy policies.
In addition to a due diligence questionnaire, each candidate, unaffiliated fund must also satisfactorily evidence that they meet comprehensive standards detailed in a proprietary Fund Assessment guide, as well as provide various policies, procedures, and other related items contained within a document checklist.
Only those unaffiliated funds that meet the stringent due diligence criteria will be added to the Prometheus Platform and taken into consideration for investment through the Feeder Funds. The Investment Committee has the final review and selection of unaffiliated funds.
Once an unaffiliated fund has been added to the Prometheus Platform, quantitative, qualitative, and operational factors are continuously reviewed. Any negative catalysts or trends may result in an unaffiliated fund being downgraded or removed from the platform.
There are no specific investment strategies.
Risk of Loss
Investing in securities involves risk of loss that each qualified investor must acknowledge they are able and prepared to bear prior to subscribing to any Feeder Fund. The key risks involved, include, but are not limited to:
Future and Past Performance: The performance of the fund’s prior investments, or those of any prior firm, is not necessarily indicative of a fund’s future results.
Illiquidity; Lack of Current Distributions: An investment in a fund should be viewed as an illiquid investment. It is uncertain as to when profits, if any, will be realized. Losses on unsuccessful investments may be realized before gains on successful investments are realized. The return of capital and the realization of gains, if any, generally will occur only upon the partial or complete disposition of an investment. While an investment may be sold at any time, it is generally expected that this will not occur for a number of years after the initial investment. Before such time, there may be no current return on the investment. Furthermore, the expenses of operating a fund (including any Management or Performance Fee payable to the relevant fund) may exceed its income, thereby requiring that the difference be paid from the fund’s capital, including unfunded commitments.
Reliance on the General Partners: Control over the operation of a fund is typically vested entirely with the applicable General Partner, and the fund’s profitability depends largely upon the business and investment acumen of the principals of such General Partner. The loss or reduction of service of one or more of the principals could have an adverse impact on a fund’s ability to realize its investment objectives. Limited partners generally have no right or power to take part in the management of a fund, and, as a result, the investment performance of the fund will depend entirely on the actions of the relevant General Partner.
Uncertain Economic, Social and Political Environment: Consumer, corporate and financial confidence may be adversely affected by current or future tensions around the world, fear of terrorist activity and/or military conflicts, localized or global financial crises or other sources of political, social or economic unrest. Such erosion of confidence may lead to or extend a localized or global economic downturn. Furthermore, such confidence may be adversely affected by local, regional or global health crises including, but not limited to, the rapid and pandemic spread of novel viruses commonly known as SARS, MERS and COVID-19 (Coronavirus).
Each unaffiliated funds’ offering documents disclose risks relative to each specific investment and are available on the Prometheus Platform for accredited investors to review before making any investment decision.
Item 9: Disciplinary Information
Neither Prometheus Financial Advisors, nor any affiliated party or supervised person of the firm have any criminal or civil actions, administrative proceedings, self-regulatory organization (SRO) proceedings, and disciplinary information to disclose.
Item 10: Other Financial Industry Activities and Affiliations
Prometheus Alternative Investments, Inc is the parent company of Prometheus Financial Advisors and all affiliated entities, discussed herein. While each of the affiliated entities may receive some form of compensation, as disclosed below, there is no compensation arrangements between Prometheus Financial Advisors, LLC and the affiliated entities.
Prometheus Financial, LLC, a registered and affiliated broker-dealer, offers brokerage services by acting as a placement agent for issuers to offer private placements in alternative funds to accredited retail and institutional investors. Prometheus Financial, LLC does not offer traditional brokerage services, which typically include the buying and selling of publicly traded stocks, bonds, ETFs, options, and futures contracts. Prometheus Financial, LLC will not maintain physical custody of assets. Prometheus Financial, LLC will not charge fees to the investors using the Prometheus Platform and investing in the Feeder Funds. Prometheus Financial, LLC placement agent fees will be charged to the underlying, unaffiliated private funds listed on the Prometheus Platform when an investor subscribes to their fund. Supervised persons of Prometheus Financial Advisors are registered representatives of the broker-dealer, Prometheus Financial, LLC. See Item 5: Fees and Compensation, Additional Compensation for discloses on the potential conflicts of interest.
Prometheus Access Administrator, LLC is the administrator and sponsor to the Feeder Funds. The sponsor will not charge investors any administrative fees through the Feeder Funds. The administrative fee will be charged to the unaffiliated private funds invested in by Prometheus Access Administrator, LLC.
Prometheus Content, LLC will be responsible for monitoring and overseeing the social media content of the Prometheus Platform. Prometheus Content, LLC will not charge any fees to investors to gain access to the social media content.
Employees of Prometheus Financial Advisors may also work for one or more of the affiliated parties noted above. In instances where potential conflicts occur, policies will be established to mitigate.
None of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.
Recommend or Select Other Private Fund Investment Advisers
The Prometheus Platform will provide information and recommend unaffiliated funds that have passed the holistic due diligence process of Prometheus Financial Advisors, which includes making sure they are properly licensed and registered. There are no fees being earned by Prometheus Financial Advisors for recommending the unaffiliated funds on the Prometheus Platform, however the affiliated entities Prometheus Financial, LLC and Prometheus Access Administrator, LLC receive fees for investors that have made investments in the unaffiliated funds, as disclosed under Item 5: Fees and Compensation. Prometheus Financial Advisors may recommend other unaffiliated private funds, however, will not receive any compensation from other registered investment advisers.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics
Prometheus Financial Advisors has adopted a Code of Ethics designed to address the confidentiality of client transactions, insider trading and potential conflicts of interest that may arise with regard to personal trading. All supervised persons of Prometheus Financial Advisors must read, understand and follow the firm’s Code of Ethics.
A copy of Prometheus Financial Advisors’ Code of Ethics shall be provided to any client or prospective client upon request.
Recommend Securities with Material Financial Interest
Prometheus Financial Advisors has a financial incentive, due to the affiliated entities receiving compensation as disclosed herein within Item 5: Fees and Compensation, to recommend investors contribute to one or more of the Feeder Funds. Investors may invest directly in the unaffiliated funds rather than through the Feeder Funds, if they desire and are able to meet the underlying, unaffiliated funds investing minimums.
Recommend Securities in which Related Parties act as General Partner
Prometheus Financial Advisors recommends the Feeder Funds, in which the affiliated entity Prometheus Access Administrator serves as the General Partner. This presents a conflict of interest due to the financial incentive to make a recommendation for the Feeder Funds. Investors are never obligated to invest within the Feeder Funds.
Invest in Same Securities Recommended to Clients
Supervised persons of Prometheus Financial Advisors may invest in the same unaffiliated funds offered to clients. Since the unaffiliated funds do not trade like a traditional equity security, there isn’t the ability to front run against client investments. Supervised persons of Prometheus Financial Advisors will need to meet the same criteria and financial requirements as investors and complete the required subscription documents.
Item 12: Brokerage Practices
Prometheus Financial Advisors does not invest in securities nor have discretionary authority to select and or recommend broker dealers for transactions. The affiliated broker-dealer Prometheus Financial, LLC will serve as the placement agent for the unaffiliated private funds on the Prometheus Platform and selected by the Feeder Funds for investment. Unaffiliated funds identified on the Prometheus Platform will be limited to those in which Prometheus Financial, LLC services as placement agent.
Prometheus Financial Advisors does not receive research or other products or services or execution from a broker-dealer or a third party (‘’soft dollar benefits’’) in connection with client securities transactions. Prometheus Financial Advisors does not receive client referrals from a broker-dealer or third party.
Prometheus Financial Advisors will not recommend, request or require that a client direct you to execute transactions through a specified broker-dealer. The unaffiliated private funds listed on the Prometheus Platform pay the affiliated broker-dealer Prometheus Financial, LLC a placement agent fee for investors that subscribe to the unaffiliated funds. This fact and conflict are further disclosed in Item 10: Other Industry Affiliations and Activities.
Item 13: Review of Accounts
Once an unaffiliated fund has been added to the platform, quantitative, qualitative, and operational factors are continuously reviewed. The Investment Committee is responsible for all reviews. Any negative catalysts or trends may result in the unaffiliated funds proprietary screening being downgraded and removed from the Prometheus Platform. Prometheus Financial Advisors does not review investors accounts or financial plans.
Items or events within an unaffiliated fund which could potentially trigger either an ad hoc review, or more frequent reviews, include organizational changes, key personnel departures, negative reputational events, performance deterioration, style or strategy drifts, negative regulatory or compliance events, or reduced operational integrity.
The underlying, unaffiliated funds of the Feeder Funds may have reporting for their investors, within the Feeder Fund. Prometheus Financial Advisors will make available to each investor on its platform all fund-related documents on the invested, unaffiliated funds that will clearly detail the fees and expenses born by the investors. The fund administrator, NAV Consulting, will be providing investors of the Feeder Funds monthly or quarterly written reports depending on the activity within their account. If there is no activity, at a minimum quarterly written reports will be provided.
Item 14: Client Referrals and Other Compensation
Prometheus Financial Advisors does not have any relationships with third parties to compensate them for referrals and/or solicitations nor do they receive any compensation for client referrals. Prometheus Financial, LLC, an affiliated broker dealer, will serve as the placement agent for the funds on the Prometheus Platform and will receive a placement agent fee from the unaffiliated funds invested in by the Feeder Funds and on the Prometheus Platform. More information on this and potential conflicts can be found under Item 10 of this brochure.
Prometheus Financial Advisors does not receive an economic benefit from someone that is not a client for providing investment advice or other advisory services.
Item 15: Custody
Prometheus Financial Advisors will not maintain physical custody of investor assets. Prometheus Access Administrator, an affiliated exempt reporting adviser, serves as the sponsor/advisor to the Feeder Funds, therefore the Feeder Funds will undergo an annual financial statement audit and provide the statements to the investors within 120 days following each Feeder Fund’s fiscal year-end.
Item 16: Investment Discretion
Prometheus Financial Advisors does not have discretionary authority to manage securities on behalf of client accounts. The sponsor Prometheus Access Administrator will provide administrative and advisory services to the Feeder Funds and has registered as an exempt reporting advisor with the SEC and State of California. Prometheus Access Administrator will have full discretion over the Feeder Funds, including what unaffiliated private funds to invest, the amount, and the broker dealer to be used. The Feeder Funds do not allow clients to place restrictions.
Item 17: Voting Client Securities
Prometheus Financial Advisors will not have or accept authority for voting proxies. In the event the underlying, unaffiliated private funds were to hold public companies, the underlying, unaffiliated private funds would be responsible for voting proxies. Information on how to receive proxies or other solicitations and how investors can contact regarding questions on their proxies will be noted within each of the unaffiliated private funds fund documentation.
Item 18: Financial Information
Prometheus Financial Advisors does not charge or solicit clients to prepay fees of $500 per client, six or more months in advance, nor of any financial concerns to disclose. Prometheus Financial Advisors does not have financial conditions that impair our ability to meet contractual commitments to clients. Prometheus Financial Advisors is not subject to bankruptcy petition at any time during the past 10 years.
Item 19: Requirements for State-Registered Advisers
Identify Principal Executive Officers and Management Person
Michele Singh, Chief Compliance Officer
- 3/2021 – Present: Chief Compliance Officer; Prometheus Financial Advisor, LLC
- 9/2021 – Present: Senior Compliance Officer; Prometheus Alternative Investments, LLC
- 9/2021 – Present: Compliance Officer; Prometheus Financial, LLC
- 6/2020 – 8/2021: Senior Compliance Manager, Digital Services; Charles Schwab
- 2/2020 – 6/2020: Director of Compliance; Alpaca
- 9/2018 – 2/2020: Compliance & Operations Analyst; Alpaca
- 08/2014 – 9/2018: Compliance Specialist; AssetMark
- Bachelor of Science in Child Development, California Polytechnic State University
Describe Business Other Than Investment Advice
See Employment History for all of Michele’s outside business activities, which include affiliated firms Prometheus Alternative Investments, LLC as the Senior Compliance Officer and Prometheus Financial, LLC as the Compliance Officer.
Performance-Based Fee Compensation
Prometheus Financial Advisors does not receive compensation based on performance-based fees.
Neither Prometheus Financial Advisors, nor any affiliated party or supervised person of the firm have been involved in an award or found liable in an arbitration claim alleging damages in excess of $2,500 or found liable in any civil, self-regulatory organization, or administrative proceedings.
Relationships with Issuers of Securities
Please see Item 10: Other Industry Affiliations and Activities for the fees received by affiliated entities Prometheus Financial, LLC and Prometheus Access Administrator in relation to the unaffiliated funds identified on the Prometheus Platform and the Feeder Funds.
Item 1: Cover Page Part 2B: Paul Barnaby
Mr. Paul Barnaby
Prometheus Financial Advisors, LLC
This brochure supplement provides information about Paul Barnaby that supplement’s Prometheus Financial Advisor, LLC’s brochure. Please contact us at (925) 285-1398, or by email at email@example.com if you do not receive Prometheus Financial Advisors, LLC’s brochure.
Additional information about Paul Barnaby is also available on the SEC's website at www.adviserinfo.sec.gov.
Individual CRD number: 6383985
Item 2: Educational Background & Business Experience
- 1995: Master’s in business administration in Finance, Loyola University Maryland
- 1991: Bachelor of Science in Marketing, Towson University
- 12/2021 – Present: Director of Client Service; Prometheus Alternative Investments
- 12/2021 – Present: Investment Committee Member; Prometheus Financial Advisors
- 09/2019 – 9/2020: Senior Implementation Consultant; Private Client Resources
- 04/2016 – 09/2019: Financial Advisor; Prudential Financial
Item 3: Disciplinary Information
Paul does not have any disciplinary activity.
Item 4: Other Business Activities
Paul is the Director of Client Service for Prometheus Alternative Investments, LLC, the parent company of Prometheus Financial Advisors, LLC and its affiliates.
Item 5: Additional Compensation
Paul’s only form of compensation is a salary and bonus as an employee of Prometheus Alternative Investments, Inc.
Item 6: Supervision
Paul is not under the direct supervision of any one individual. Paul is part of the Investment Team responsible for making all recommendations. The activities of the Investment Team are supervised by Michele Singh, the Chief Compliance Officer. Michele can be reached at (415) 272-3317.
Item 7: Requirements for State-Registered Advisers
Paul is not subject to any disciplinary activities, nor has he been subject to bankruptcy.