SEC Actions

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”) ...

Hennig’s written policies and procedures failed to adequately address its Disclosure Obligation because, among other things, they did not provide sufficient guidance or procedures for ...

As Summit’s sole owner and investment adviser representative, President, and Chief Compliance Officer, Richard Urciuoli was responsible for Summit’s failures

Elm Partners published on its website at https://elmweath.com/returns-view that constituted advertisements because they offered Elm Partners’ investment advisory services with regard to securities to prospective ...