Conflicts of Interest

Because Ally Invest’s affiliated broker-dealer received a rebate reflecting a portion of the interest that was generated by the cash held in the Cash-Enhanced Accounts, ...

Specifically, Engaged failed to disclose the conflicts created by its investment in the founders’ shares and private placement warrants

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 ...