Below are examples of deficiencies or weaknesses observed by the staff related to funds’ and their advisers’ compliance programs for portfolio management and other business ...
The firm failed to file and deliver Form CRS by these deadlines, not becoming compliant until in or after late March 2021
ERISA fiduciaries can make investment decisions that reflect climate change and other ESG considerations, including climate-related financial risk, and choose economically targeted investments selected, in ...
"Today, the staff of the Securities and Exchange Commission published a report on the “meme stock” events of winter 2021, and how these events affected ...
Under federal law, an investment adviser is a fiduciary.104 With respect to securities lending, advisers have a fiduciary duty to consider the tradeoffs between continuing ...
Redwood had custody of its clients’ Mortgage Company promissory notes because it had possession of and direct access to them, and it failed to comply ...
TCA and GP fraudulently inflated the TCA Funds’ net asset value and performance results through the recording of non-binding transactions
The Form ADV brochures failed to disclose information about an unpaid $208,700 judgment against Clark and Soteira in favor of a former client
Cowen determined that a government money market fund, as opposed to another type of money market fund, was an appropriate cash sweep vehicle for its ...
Buttonwood and McGraw therefore had a financial conflict of interest with their clients—they had an incentive to select investments for clients that would allow Buttonwood ...