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Examinations Enforcement: Settlement
The adviser was also unable to substantiate performance claims, failed to disclose material conflicts of interest related to advertised testimonials and failed to implement certain ...
Delphia failed to lay out a clear advertising review and approval process, either in its policies and procedures or otherwise, that would enable its personnel ...
‘Tis the season for Form ADV updates for most advisers, so it’s worth heeding a compliance lesson tied to faulty disclosures
Both of these agreements created conflicts of interest, because they created an incentive for 3D/L to use funds managed by the ETF Manager in 3D/L’s ...
HG Vora Capital Management failed to file the required Schedule 13D disclosing its “control” purpose, current shareholdings, and other specified information within ten days
Twice, Contrarian purchased offering shares from an underwriter participating in a follow-on or secondary public offering of stock despite causing at least one advisory client ...
The Reg BI violations affected about 5,900 retail accounts, causing the clients to pay $936,000 more in expenses for substantially equivalent funds than they otherwise ...
The Influencer’s planned involvement and the details of the anticipated licensing arrangement were not disclosed to the independent trustees of the VanEck ETF Trust for ...
In the new legal cases targeting advisers, the SEC cited their responsibilities under Advisers Act section 204 (reports by IAs) and the books and records ...
Commission staff uncovered Cambridge’s misconduct after commencing a risk-based initiative to investigate the use of off-channel and unpreserved communications at broker-dealers. Cambridge has initiated a ...