Instead of paying back Fund II during this time period, Respondent used the management fees it charged and collected for its own operating expenses
The analyst replied to Compliance Officer’s initial email, stating that he did not see anything that would require SARC to take immediate action, such 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 ...
None of the 40,000 back-up tapes handled by Moving Company complied with these policies and procedures. MSSB never inspected the equipment used to destroy those ...
From 2013 until June 30, 2020, however, Arcadia failed to obtain the required surprise examinations for the client accounts for which it had custody
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 ...
The staff will review whether investment advisers have adopted and implemented written policies and procedures that are reasonably designed to prevent violations
In August 2018, a covered associate of Respondent made a campaign contribution to a candidate for elected office in California, which office had influence over ...
Between December 2020 and April 2021, two covered associates of Respondent made campaign contributions to a candidate for elected office in New York, New York, ...
In July 2018, an officer of the Bank of Hawaii made a campaign contribution to an incumbent for elected office in Hawaii, which office had ...