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 ...
"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 ...
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 ...
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 ...