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Examinations Enforcement: Settlement

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The SEC’s settlement suggests one compliance action you could consider
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Thrivent promptly identified and reported the violations during an SEC examination and paid $22k to 846 retail customers as a result
Dollar Parts
G.A. Repple did not adequately disclose all material facts regarding its share class selection practices and the conflicts of interest that arose when it recommended ...
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There were no P&Ps for Marathon employees to conduct due diligence concerning advisers’ evaluation or handling of any potential MNPI or for obtaining a representation ...
False marriage between two people not sincere
Cetera did not require the reps to place aggregated orders through internal systems, which would have prevented the post-trade allocations from being made
Tripping
It can amount to easy pickings for the SEC when an adviser has an obligation to file information with the Commission but neglects to fulfill ...
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Vistia Capital did not timely amend its Form CRS to disclose that one of its financial professionals had disciplinary history as required
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Prior to and after being approached by the Commission, Stifel enhanced its P&Ps, increased training on use of approved communications methods, and provided some personnel ...
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The Commission requested documents in an unrelated investigation that revealed the use of off-channel and unpreserved communications. As a result, Glazer’s recordkeeping failures likely impacted ...
We're the duo for the task
The firm gathered and produced emails and text messages, including those at senior levels, that were sent or received by text message on personal phones ...
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