As Summit’s sole owner and investment adviser representative, President, and Chief Compliance Officer, Richard Urciuoli was responsible for Summit’s failures
The CCO "did not review the offering materials or take other steps to determine whether her transfers were consistent with representations to CS Manager investors ...
"Since 2012, when Two Point first registered with the Commission, Two Point failed to adopt and implement reasonably designed compliance policies and procedures, and to ...
As UCB Advisers’ CCO, Garcia compliance duties related to securities, including penny stocks, and was tasked with ensuring that UCB Advisers and its IARs comply ...