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Examinations Enforcement: Settlement

Although Haupt conducted certain reviews of GGHC’s trading in 2017, she conducted no reviews for excessive trading or the impact of GGHC’s trading strategies or ...
Rule 15c3-l, promulgated thereunder (the “net capital rule”), requires that a broker-dealer “at all times have and maintain net capital” no less than the greatest ...
Respondent has submitted a sworn Statement of Financial Condition, dated February 29, 2020, supplemented as of June 30, 2020, and other evidence and has asserted ...
Roosevelt lacked policies and procedures reasonably designed to prevent and detect these violations by its registered representatives
Welsh placed orders for new issue municipal bonds with Dockside and Murphy to obtain bonds for Roosevelt’s inventory when he should have known that they, ...
A New York private fund adviser has agreed to pay $75,000 to settle SEC claims that it violated the custody rule for two private funds ...
Graham Bordelon caused its clients to receive credits on 12b-1 fees back to their accounts and began a process of converting its clients’ mutual fund ...
SQN Capital relied on the Audited Financials Alternative to attempt to comply with the custody rule during the relevant period but failed to do so
Compliance personnel recommended moving the FuelCell account to another trading desk to take advantage of that desk’s “newly built execution protocols for issuer stock sales.” ...
At the time he was fired, Tropiano was married to the daughter of Respondent. Tropiano went to see Respondent, his father-in-law, for advice on finding ...
Pizzuti was associated with other broker-dealers registered with the Commission, some of which were also registered as investment advisers
A Miami private fund adviser incorrectly billed real estate funds it advised $3 million in expense reimbursement, costs that should’ve been billed to its co-investment ...
SCF failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection ...
Perez received $137,275 in commissions from his fraudulent conduct
Turney received $281,914 in commissions from his fraudulent conduct
IB did not have sufficient resources in its compliance function to adequately review and/or address the issues identified by its surveillance systems
A Miami private fund adviser has been censured and will pay $350,000 in fines to settle SEC claims that it overcharged the real estate funds ...
The cost allocation methodology Rialto used to calculate Third Party Tasks increased general overhead expenses. Rialto did not fully disclose this increase to the Advisory ...
WBI and Millington, in their roles as investment advisers, disclosed to clients that Millington, in its role as a broker-dealer, received payments for order flow ...
Day Trade Clients received risk-free day trades with small profits while the Buy and Hold Clients effectively bore all market risk for the Day Trade ...
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