12b-1 Fees

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 ...

SCF failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection ...

Three VALIC employees worked to steer union members to the advisory firm while being “deceptively identified” as union employees

In March of 2017, VFA disclosed for the first time the receipt of Revenue Sharing, but still did not fully and fairly disclose that conflict ...

For two Clients who explicitly requested that Vescio disclose the fees charged, Vescio negligently failed to include 12b-1 fees

Large penalty even though dual registrant began reimbursing 12b-1 fees in 2016

The SEC was clear in detailing what was lacking from a disclosure standpoint

There is no question that advisers acted in conformity with the Commission’s Form ADV. The Commission cannot turn around now and claim—with the threat of ...

The Commission considered that Cozad self-reported to the Commission staff in the fall of 2018 after learning that the Unaffiliated BD/IA had participated in the ...

The Commission considered that Respondent self-reported its conduct to the Commission pursuant to the SCSD Initiative