State Farm failed to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Regulation BI because it did not provide ...
The five business day restricted period under Rule 105 began on August 30, 2023. Because Gates Capital, on behalf of its fund clients, sold short ...
Form 13F requires institutional investment managers to disclose the fair market value of its Section 13(f) Securities under management
The adviser has had investment discretion over at least $100 million of reportable securities and was obligated to file quarterly Forms 13F beginning by 2020., ...
In August 2024, the firm filed 19 Forms 13F, which covered the period from the quarter ending March 31, 2019, to the quarter ending September ...
In April 2024, the firm self-reported to the Commission its failures to file Forms 13F and 13H
The firm failed to resolve known compliance system deficiencies related to the merger
While JZAI compliance personnel reviewed various records and correspondence in the ordinary course of business, JZAI did not conduct spot-checks of books and records of ...
The two advisers had overlapping owners, overlapping managers, overlapping advisory personnel, and overlapping operations including shared office space, without any policies or procedures to ensure ...
Collett did not reconcile the block trade tickets to the trade log to ensure that the block trades were properly allocated. Instead, Collett trusted that ...