Wrap Fee

The adviser did not fulfill its duty of care obligations when it exchanged Wrap Program clients’ existing assets in certain mutual funds for other investments ...

Noted deficiencies related to inadequate disclosures and compliance programs that failed to measure up

Form CRS surfaced undisclosed production credit fees for Merrill Lynch wrap fee program clients

Merrill further enhanced its wrap fee program disclosure documents, disclosing specifically that the wrap program fee does not cover Foreign Currency Exchanges and providing a ...

IA acted contrary to its client disclosures and internal policies concerning reviewing accounts of clients in wrap program

"KAI failed to (i) review these advisory accounts for inactivity as required under its internal policies and external disclosures, to determine whether wrap accounts remained ...

This Advisers Act rule addresses the delivery of Form ADV

Examiners found deficiencies related to inadequate disclosures and compliance programs that failed to measure up. For instance, some advisers didn’t monitor “the trading activity in ...

Advisers did not monitor the trading activity in clients’ accounts or their monitoring activities were ineffective

The settlement touches on violations of the adviser's fiduciary duty, undisclosed 12b-1 fees, errant fee calculations, suitability, hidden revenue sharing, conflicts, as well as sweep ...