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Examinations Enforcement: Settlement

An investment adviser’s fiduciary duty includes, among other things, an obligation to seek best execution for client transactions
Alderson is no longer associated with Touchstone Advisory. Alderson, 42 years old, is a resident of the United Kingdom
FAV’s compliance department discovered the breaches of the limits in Section 12(d)(1)(A)
Tannen negligently disregarded that the Brokers would be conducting unauthorized trades in these customer accounts. Tannen was compensated $20,000 for his actions
A Massachusetts broker-dealer and its top salesman will each pay $50,000 to settle SEC claims that they misled investors on their ability to execute sophisticated, ...
BNPP was aware of red flags that indicated that the Hedge Fund might not be able to deliver sufficient shares
Based on this consultant’s findings and recommendations, SGAS implemented new controls and procedures over its EBS reporting process intended to ensure the completeness and accuracy ...
To all outward appearances, Richard Diver stood as a pillar of rectitude. The co-founder of Manhattan-based M&R Capital Management ($487M in AUM), Diver, 63, ran ...
Lucia refused “to bow to an agency with unlimited resources unwilling to admit that its prosecution efforts had become wholly disproportionate to the alleged infraction”
Diver defrauded clients by electronically debiting invoice client accounts more than what they owed to M&R and redirected the excess to his personal bank account
The Commission commenced this proceeding on September 5, 2012
The firm's compliance department knew it had monitoring issues
A routine FINRA cycle exam uncovered the issues
In March, OCIE Director Pete Driscoll promised private fund advisers that the SEC would this year issue a risk alert directed at them. “That’s something ...
For two Clients who explicitly requested that Vescio disclose the fees charged, Vescio negligently failed to include 12b-1 fees
Large penalty even though dual registrant began reimbursing 12b-1 fees in 2016
Compliance staff failed to comply with policies and procedures designed to prevent misuse of information
TSP Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written P&Ps
Clients, however, did not have this information available to them because execution costs from trading away were not visible to clients on their account documents ...
For nearly three decades, Marko Dimitrijevic was an impresario in emerging market funds. His firm, Everest Capital, attracted early investments from George Soros and Dimitrijevic’s ...

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