Regulatory Alerts2026-06-23
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Wingert Investment Management, LLC Stephen A. Wingert
Wingert Investment Management, LLC failed to maintain the required minimum net worth of $35,000 while holding custody of client funds or securities from January 2022 through December 2025. The entity also failed to promptly notify the Department in writing on Form ADV regarding its custody status. These violations provide grounds to deny, suspend, revoke, or condition the firm's registration or to censure it under Section 305(a)(v) of the 1972 Act.
- WIM, CRD #116049, was at all material times herein, a Pennsylvania limited liability company organized under the laws of Pennsylvania with a principal office located at • Redacted
- From in or around October 2005 until the present, WIM was registered pursuant to Section 301(c) of the 1972 Act, 70 P.S. § 1-301(c), as an investment adviser.
- On September 19, 2025, staff of the Bureau conducted a routine examination of WIM at its place of business, pursuant to§ l-304(d) of the 1972 Act, 70 P.S. § 1-304(d).
- The exam revealed that, from .January 2022 to December 2025, WIM had "custody" over client funds or securities as defined in 10 Pa. Code § 102.021(a).
- The exam revealed that, at all times material herein, WIM failed to maintain a minimum net worth of$35,000.
- Pursuant to Regulation 303.042(a)(3), 10 Pa. Code§ 303.042(a)(3) as promulgated under Section 303 of the 1972 Act, an investment adviser that has its principal place of business in this Commonwealth and has custody of client funds or securities shall maintain at all times a minimum net worth of $35,000. VIOLATION
- By engaging in the acts and conduct set forth in paragraphs 3 through 8 above, WIM had custody of client funds or securities within the meaning of 10 Pa. Code§ 102.02l(a) and failed to notify the Department promptly in writing on Form ADV that it has or may have custody, which acts and conduct form a basis to deny, suspend, revoke, or condition the registration of WIM or censure WIM, pursuant to Section 305(a)(v) of the 1972 Act, 70 P.S. § 1-305(a)(v), and Regulation 404.014(a)(l), 10 Pa Code § 404.014(a)(l). 2
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