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Examinations Enforcement: Settlement
Chang misappropriated $58,560 from the Investors via 40 unauthorized ACH transfers to accounts in Chang’s name at two online payment applications. Chang took advantage that ...
Senior personnel repeatedly violated policies by, among other things, sending emails to current investors, potential investors, and industry contacts which, in certain cases, unnecessarily disclosed ...
The firm acted as an investment adviser or principal underwriter to registered investment companies or ESCs in violation of the ineligibility provisions of the Investment ...
ECM failed to engage an independent public accountant to verify by actual examination at least once during each calendar year the REOC Funds’ funds and ...
Although Laidlaw had monitoring procedures to detect potential violations by reps of the quantitative prong of the Care Obligation, Laidlaw did not reasonably maintain and ...
Respondents employed a strategy of taking quick profits on part of a particular securities position resulting in frequent trade recommendations in these accounts .... As ...
In connection with BlackRock’s investigation of potential misconduct by Aviron’s CEO, BlackRock identified its reporting errors
The Canadian-based exempt reporting adviser has since undertaken certain remedial steps, including updating and revising its Rule 105 policies and procedures to prevent future Rule ...
The adviser did not fulfill its duty of care obligations when it exchanged Wrap Program clients’ existing assets in certain mutual funds for other investments ...
When questioned by its bookkeeper, the CEO/CCO responded that they consisted of short-term loans from Fund A that he subsequently repaid to Fund A. However, ...