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Conflicts of Interest
The SEC found that the RIA's advisory agreements and Form ADV failed to disclose the 'exit fees' that its custodian would charge clients
So far so good except the firm erred in what it disclosed about the program
Access Persons must certify annually to, among other things, their personal securities holdings, their securities accounts and transactions and compliance with various firm policies
Although the adviser's policy required it to identify and disclose conflicts of interest, it lacked any written P&Ps to ensure that conflicts of interest around ...
Remedial actions taken by the firms include the hiring of new compliance professionals at senior levels with extensive broker-dealer and investment adviser experience
Compliance issues were tied to the supervision of outside brokerage accounts and the flow of information between research analysts and trading personnel
Transamerica Retirement Advisors paid incentive compensation to its Retirement Planning Consultants for referring employer plan participants to its investment advisor reps
The firm's use of the letter was also improper because it required its clients, all of whom are retail clients, to agree to a waiver ...
These transactions were known within Rose Park both leading up to and at the time of signing the documents in March 2021, including by the ...
G.A. Repple did not adequately disclose all material facts regarding its share class selection practices and the conflicts of interest that arose when it recommended ...









