Carl Ayers
Helikon did not qualify for an exception to Rule 105 when it purchased shares in the Offering
Oseas Zuluaga knew, or should have known, that Revere’s proprietary holdings should have been included in the calculation of Revere’s net capital
Coda did not always provide its subscribers with information indicating where their orders had been routed or executed
"This fiscal year, this division is again on track to complete approximately 3,000 examinations [of IAs], which are critical to ensuring that firms comply with ...
That’s why I agree with the ARRC that the Secured Overnight Financing Rate (SOFR), which is based on a nearly trillion-dollar market, is a preferable alternative ...
Certain MMLIS and MSI advisory clients to invest in share classes of mutual funds in the Clearing Broker’s NTF and TF Programs that resulted in ...
Korth did not have policies and procedures concerning riskless principal transactions until March 2018. The policies and procedures Korth adopted in March 2018 were not ...
Regal’s compliance manual designated Yarch with implementing Regal’s compliance program as well as monitoring and updating Regal’s Form ADV disclosures. In November 2019, Regal adopted ...
BFC’s Form ADV Part 2A brochures disclosed that advisory clients “may incur” 12b-1 fees, and that because IARs “may receive 12b-1 fees … there is ...
By causing certain advisory clients to invest in share classes of mutual funds that charged 12b-1 fees or share classes of money market funds that ...