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Examinations Enforcement: Settlement

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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, ...
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The Commission is aware of one former employee who was initially discouraged from communicating with Commission staff about potential violations of securities laws due to ...
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Using their personal devices, these employees communicated both internally and externally by personal text messages, or other text messaging platforms such as WhatsApp and GroupMe ...
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Maxim failed to file SARs for numerous transactions that it should have had reason to suspect involved possible fraudulent activity or had no business or ...
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Because Woodbury failed to obtain verification by actual examination of the client funds and securities in the accounts by an independent public accountant, Woodbury violated ...
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Reps recommended and executed over 2,000 trades in these customers’ accounts without regard for the high transaction costs This high volume of recommended transactions and ...
Conflict Of Interest
Apexium did not document why investing with the Affiliated Manager was in the best interest of any particular client or group of clients at the ...
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The firm's revised P&Ps now require reps to request oral consent to electronic delivery from customers using a consent and disclosure script. If a customer ...
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The adviser would 'periodically' have its disclosures 'reviewed and revised by WAM’s internal and external legal and compliance professionals, but those revisions did not adequately ...
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AssetMark failed to provide full and fair disclosure of conflicts of interest arising from ATC’s cash sweep program, which transferred, or “swept,” clients’ uninvested cash ...
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