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Cross-Trades

A Kansas private fund adviser thought it could save its clients a few bucks but it didn’t properly disclose or manage its cross-trading policies, and ...
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 ...
The most frequent principal trading and agency cross transaction compliance issues identified by OCIE staff in examinations of adviser
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 ...
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