"We are concerned that the Order may be misconstrued regarding an adviser’s fiduciary duties with respect to voting proxies on behalf of its clients, as ...
The adviser repeatedly violated the Advisers Act by casting proxy votes at more than 200 shareholder meetings without taking any steps to determine whether the ...
Waddell failed to implement its Compliance Policy over a six-year period when it repeatedly failed to follow up, including by failing to move clients from ...
Following a prior exam, the SEC continued to find hundreds of inactive accounts—each regularly paying IA fees—and determined the adviser failed its fiduciary duty in ...
Problems were 'first identified by staff of the Commission’s Division of Examinations' in September 2019 but the adviser failed to remediate in an adequate manner