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Examinations Enforcement: Settlement

Conflict Of Interest
Because Ally Investโ€™s affiliated broker-dealer received a rebate reflecting a portion of the interest that was generated by the cash held in the Cash-Enhanced Accounts, ...
In response to the market disruption, the adviser took steps to increase monitoring of its existing portfolio companies but it did not perform other analyses ...
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The Advisory Agreements contained hedge clauses that purported to broadly limit Respondentsโ€™ liability. The language, when read in its entirety, is inconsistent with an adviserโ€™s ...
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Specifically, Engaged failed to disclose the conflicts created by its investment in the foundersโ€™ shares and private placement warrants
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Thirteen percent of staff walked out the door after Elon Musk's DOGE raid. 'In practical terms, this puts more responsibility on asset managers,' Major, Lindsey ...
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The email account takeovers resulted in unauthorized, malicious phishing and credential-harvesting emails to many of the adviser's customers, potentially exposing their PII to bad actors
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The violations included failing to conduct annual reviews, not implementing compliance P&Ps, producing inaccurate Form ADV brochures and not obtaining written advisory agreements for all ...
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MH Investment was aware of the Accountantโ€™s wifeโ€™s investment at the time it proposed that MH Elite engage the Accountant to serve as its auditor ...
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Tradebook distributed marketing materials stating that market data was provided at speeds 'in fractions of seconds' but this was misleading because Tradebook knew there were ...
The client engaged the RIA in 2007 as her investment adviser. At about this time, James Warringโ€™s relationship with the client became more personal and, ...
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