Examinations Enforcement: Settlement

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

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 ...

MH Investment was aware of the Accountant’s wife’s investment at the time it proposed that MH Elite engage the Accountant to serve as its auditor ...

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 Warring’s relationship with the client became more personal and, ...

So far so good except the firm erred in what it disclosed about the program

Meridian failed to conduct an annual review of the adequacy of its compliance P&Ps and the effectiveness of their implementation, nor did it comply with ...

Another lesson this case presents is don’t promise the SEC you will do something—and then not do it

Although the adviser's policy required it to identify and disclose conflicts of interest, it lacked any written P&Ps to ensure that conflicts of interest around ...

Remedial actions taken by the firms include the hiring of new compliance professionals at senior levels with extensive broker-dealer and investment adviser experience