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Principal Trades

Before engaging in a principal trade, an adviser would first have to disclose certain information to the client
$125,000 in fines for failing to obtain client consent
 Investment advisers are struggling with disclosure rules tied to agency cross trades, and when selling or buying securities from their clients—especially when pooled investments are ...
This Risk Alert provides an overview of the most common compliance issues identified by the Office of Compliance Inspections and Examinations (“OCIE”)∗ related to principal ...
These proceedings concern the failure of a registered investment adviser, Ophrys, LLC, to provide adequate written disclosure to clients regarding the capacity in which it ...
These proceedings concern Bayes Capital’s violations of Regulation SHO (“Reg SHO”) of the Exchange Act, in connection with its principal trading practices. As described more ...
Starting in approximately March 2013 and continuing through December 2015, Tarpinian knowingly placed approximately 2,785 trades between the Principal Account and advisory client accounts, including ...
Seven years after the SEC first threatened to retract its temporary principal trading rule, it’s finally going to happen when 2016 ends (IA Watch, Sept. ...
Maybe the fourth time’s the charm for Moloney Securities Co. and its President and Chief Investment Officer Joseph Medley, Jr. After three separate SEC examinations ...
An under-resourced compliance department and inadequate P&Ps tied to cross and principal trading have led to a $250,000 SEC civil money penalty against a Chicago-based ...
Every two years like clockwork, the SEC has extended its temporary rule permitting principal trades with certain clients by dual-registrants. The last time was two ...
WFGA overcharged clients in one of its advisory wrap account programs contrary to its disclosures to these clients. WFGA represented to clients participating in a ...
You propose that, if an Adviser determines to sell out of a client position consisting of whole shares and fractional shares, the Adviser or a ...
This year could bring the end of Advisers Act rule 206(3)-3T (temporary rule for principal trades with certain advisory clients) – although this has been ...
The staff of the U.S. Securities and Exchange Commission’s Risk and Examinations Office of the Division of Investment Management is reviewing how firms that are ...
CGMI’s trade surveillance failed to detect these principal transactions for more than two years because it relied on an exception report that was not reasonably ...
When the SEC releases three enforcement cases on the same day – tied to the same issue – you know a message is being sent. ...
TSA engaged in thousands of securities transactions with advisory clients on a principal basis through an affiliated broker-dealer, without providing prior written disclosure to, or ...
Parallax, an investment adviser registered with the Commission from March 2010 to November 2012, willfully violated the principal transaction prohibitions and the custody and compliance rules ...
Between late 2010 and 2011, Respondents caused the Funds to purchase three notes, with a total principal value of $7 million, from VERO Asset Management, ...
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