After 2019, Aventura Capital continued to revise its disclosures with respect to its conflict of interest concerning 12b-1 fees, but Aventura Capital’s revised disclosures did ...
Since at least January 2016, and continuing from the date Harnish purchased KMA in February 2020 and through December 2020, KMA invested the vast majority ...
These disclosures did not adequately disclose all material facts regarding the conflicts of interest that arose when it invested advisory clients through the Introducing Broker-Dealer ...
The certification shall identify the undertakings, provide written evidence of compliance in the form of a narrative, and be supported by exhibits sufficient to demonstrate ...
JWCA, although eligible to do so, did not self-report this 12b-1 fee related conflict of interest to the Commission pursuant to the Division of Enforcement’s ...
The settlement touches on violations of the adviser's fiduciary duty, undisclosed 12b-1 fees, errant fee calculations, suitability, hidden revenue sharing, conflicts, as well as sweep ...
Graham Bordelon caused its clients to receive credits on 12b-1 fees back to their accounts and began a process of converting its clients’ mutual fund ...