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Examinations Enforcement: SEC Actions

The dual registrant will pay a $1.5 million penalty
OCIE considers "dozens" of potential risk factors when identifying exam targets
OCIE's 2020 exam priorities include "perennial risk areas" along with some new additions
The defendants’ conduct involved fraud, deceit, or deliberate or reckless disregard of regulatory requirements
The SEC claims this case is about lying, forgery, and other deceptive conduct by Alan Seidel and Benjamin Mekawy
I cannot ignore the thousands Rossi spent gambling.
Springer concealed from prospective clients his prior disciplinary history with the SEC
Leissner received more than $43M in illicit payments for his role
Failure to adopt P&Ps connected to client objectives, restrictions
Randall wrote the agency to admit that he “‘wasn’t even aware of this [Advisers] Act or its potential applicability’ to himself
Burroughs "misappropriated his clients’ money, and provided his clients with fake documents to cover up what he had done"
Although Barnett and Aven had never worked for a hedge fund or created a valuation model, they thought that they knew better than the rest ...
"We have recognized previously that other demands on a CCO’s time may be a mitigating factor and [recognize] competing demands on" the CCO's time as ...
Fake documentation was used to deceive clients
Goulding "used Nutmeg as his personal piggybank"
Defendants used the money to make Ponzi-like payments to investors and to fund Merrill's and Ledford's extravagant lifestyles
Peirce suggested being wary of simply counting cases and tallying penalties
A jury found the defendants made false and misleading statements in the private placement offering of American Growth Funding II
Failures tied to share class selection calculator trip up dual registrant
Investment advisers continue to lead the league in spending time in the SEC’s penalty box, the Commission has concluded its in annual enforcement report. Thirty-six ...

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