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Wrap Fee (30)
Your search for Wrap Fee returned 30 results.
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9/07/2018 | Content area: Investment Adviser
BB&T Investment Services failed to disclose sufficient facts to enable clients to determine that the compensation arrangement between BB&T Investment ...
8/16/2018 | Content area: Investment Adviser
A new settlement with an adviser first caught up in an OCIE sweep exam launched four years ago looking at wrap fee programs attests to the need for sp...
8/14/2018 | Content area: Investment Adviser
This matter arises from Lockwood’s failure to adopt and implement policies and procedures reasonably designed to prevent violations of the Advisers Ac...
4/05/2018 | Content area: Investment Adviser
One aftermath of the surge in OCIE exams is that the percentage of reviews referred to the SEC’s Enforcement Division has fallen to a low of 5%. Howev...
2/13/2018 | Content area: Investment Adviser
A peer shares the OCIE document request letter received by the firm. This one concentrates on wrap fee programs. It also featured an example of an ext...
3/16/2017 | Content area: Investment Adviser
Using your Form ADV brochure to alert wrap fee program clients that they may face higher trading costs if their adviser uses a broker other than the p...
3/13/2017 | Content area: Investment Adviser
Historically, Stifel did not track or monitor which sub-advisers were trading away from Stifel, how often those sub-advisers were trading away, or the...
1/27/2017 | Content area: Investment Adviser
More evidence that OCIE’s wrap fee program sweep has produced results (IA Watch, Aug. 4, 2014). The dual-registrant Citigroup Global Markets settled c...
10/20/2016 | Content area: Investment Adviser | Broker-Dealer
The SEC has confirmed that it has succeeded in bolstering its staffing in the investment adviser/investment company exam program by roughly 20%. The C...
9/08/2016 | Content area: Investment Adviser
A summer that’s included several actions against investment advisers that feature wrap fee programs produced two more cases that suggest you should mo...
9/08/2016 | Content area: Investment Adviser
The additional costs incurred as a result of the subadvisors trading away are embedded in the price of the security on the periodic account statements...
9/08/2016 | Content area: Investment Adviser
Raymond James did not obtain information regarding the amount of commissions charged for these transactions or whether that amount was material. Inste...
8/18/2016 | Content area: Investment Adviser
If there’s one solid takeaway from the recent RiverFront enforcement action it’s to be as clear as you can in describing your step-out trades within w...
8/17/2016 | Content area: Investment Adviser
This brochure includes detailed language on step-out or trading away trades from a wrap fee sponsor following an SEC enforcement action.
7/21/2016 | Content area: Investment Adviser
The SEC has long trained its sights on wrap fee programs (IA Watch, Aug. 4, 2014). The latest example of this interest can be seen in the $300,000 fin...
7/14/2016 | Content area: Investment Adviser
The SEC has long trained its sights on wrap fee programs (IA Watch, Aug. 4, 2014). The latest example of its interest can be seen in a $300,000 fine a...
7/14/2016 | Content area: Investment Adviser
RiverFront significantly increased its trading away activity during 2009 and early 2010. Consequently, trading away began to constitute a majority of ...
6/30/2016 | Content area: Investment Adviser
We’re left to wonder why WFG Advisors ($1.4B in AUM) in Dallas would pay a compliance consultant to come in twice, be warned that the way it charged w...
6/28/2016 | Content area: Investment Adviser
WFGA overcharged clients in one of its advisory wrap account programs contrary to its disclosures to these clients. WFGA represented to clients partic...
4/21/2016 | Content area: Investment Adviser
Some may flinch at the thought of government asking private entities for the names of staffers who have made political contributions but OCIE’s doing ...


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