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Cross-Trades

Before engaging in a principal trade, an adviser would first have to disclose certain information to the client
$125,000 in fines for failing to obtain client consent
 Investment advisers are struggling with disclosure rules tied to agency cross trades, and when selling or buying securities from their clients—especially when pooled investments are ...
This Risk Alert provides an overview of the most common compliance issues identified by the Office of Compliance Inspections and Examinations (“OCIE”)∗ related to principal ...
Nadel fraudulently induced clients of RIA to invest tens of millions of dollars in what he falsely represented as a liquid, cash management investment program ...
The manner in which Harrison effected the trades on behalf of Putnam resulted in undisclosed favorable treatment of certain advisory clients over others. Specifically, Harrison ...
Cushing, on behalf of a hedge fund it managed, sold 1,565,786 units of a publicly traded master limited partnership (“MLP”) to a closed-end fund and ...
Cross trading practices inconsistent with its compliance P&Ps, regulatory compliance manual and Forms ADV have yielded SEC charges against a New York-based investment adviser.   In ...
Hamlin selected these two dealers because they were willing to execute cross trades at favorable, pre-determined, spreads that were narrower than the average bid/ask spread ...
An under-resourced compliance department and inadequate P&Ps tied to cross and principal trading have led to a $250,000 SEC civil money penalty against a Chicago-based ...
A peer shares an example of a form that provides details of a cross trade.
(a) An investment adviser, or a person registered as a broker-dealer under section 15 of the Securities Exchange Act of 1934 and controlling, controlled by, ...
When the SEC forces you to hire a compliance consultant as part of a giant settlement, you know there are issues with your program.Compliance missteps ...
Like striking a match in a tinderbox, engaging in cross trades creates hazards that can easily burn an adviser (see related story). Let's recap the ...
Click here to open a Word file that is a matrix containing procedures for three tests: 1. cross trades 2. sampling fee calculations and 3. ...
Click here to see a cross trade consent form, which comes courtesy of Brookfield Investment Management in New York. This is a Word 2009 file.
Gardner Russo & Gardner: No-Action letter dated June 7, 2006 Investment Advisers Act of 1940 – Section 206(3) Gardner Russo & Gardner June 7, 2006 ...
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