Examinations Enforcement: Settlement

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 ...

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 ...

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 ...

Neither the adviser or its principal mentioned that the money invested by clients in an affiliated company would be used to fund payroll or to ...

While the firm's compliance policy required advertising materials to be accurate, it did not adopt procedures for compliance personnel to verify the accuracy or completeness ...

While the adviser trained investment professionals on the ESG Integration Policy, some in senior portfolio management positions were not aware of the ESG Integration Policy ...

The firm's P&Ps called for its AML software to be calibration or tuned at least every one to three years. The system was only fully ...

The Monitoring Agreement did not contain a provision authorizing AIM to accelerate future monitoring fees from the Portfolio Company for the entire contract period if ...

The mismarking violations occurred as a result of a coding error in the logic used to compute Citadel Securities’s position calculated for Regulation SHO purposes ...

These proceedings arise out of Respondent’s failure to submit to the Commission complete and accurate data in response to Commission staff electronic blue sheets (“EBS”) ...