In May 2021, a covered associate of Respondent made a campaign contribution to a candidate for elected office in Massachusetts, which office had influence over ...
Respondents did not undertake a process to determine whether the loans were in the best interests of the lending Funds
BAG’s compliance manual included P&Ps requiring that trade orders include instructions for how the shares in the block trade are to be allocated. However, Brander ...
Hudson and Lone Star Global failed to fully disclose Hudson’s practice for calculating and charging certain fees. Hudson charged $54.6 million in incremental and undisclosed ...
Biscayne failed to timely distribute annual audited financial statements prepared in accordance with Generally Accepted Accounting Principles (“GAAP”) to investors in certain private funds that ...
Lend Academy failed to conduct and timely distribute annual audited financial statements prepared in accordance with Generally Accepted Accounting Principles (“GAAP”) to investors in certain ...
Ridgeview received the audit opinion for the Opportunity Fund on June 30, 2021. However, Ridgeview did not update or revise its Form ADV to “Yes” ...
QVR received audit opinions for the Funds on March 31, 2021. However, QVR did not update or revise its Form ADV until its next annual ...
Polaris purported to rely on the Audited Financials Alternative in order to comply with the custody rule, but Polaris failed to timely deliver the audited ...
Janus failed to timely deliver the audited financials to approximately 10% of the Best Ideas Fund’s investors in 2018, 2019, and 2020