Administrative Proceedings

This matter arises out of fraudulent conduct by TitleCard Capital Group, LLC (“TCCG”), an exempt reporting investment adviser with the Commission, and its only managing ...

This matter involves violations of Municipal Securities Rulemaking Board (“MSRB”) rules by MSSB. Between June 2013 and December 2017, MSSB recommended 135 “swap” transactions to ...

RJ Advisers’ policies and procedures required FAs and the Compliance Department to monitor the Inactive Accounts. Specifically, FAs were to “continually monitor their client accounts,” ...

First, from January 2014 through October 2016, Tysdal and Carter raised approximately $25 million from debt investors in Cobalt for the stated purpose of making ...

In 2015, the securities lending agent employee mentioned the conflict to the Respondents’ Chief Compliance Officer (“CCO”), advising him that, since 2005, Prudential had been ...

Both the missing transactions and inaccurate data reported were caused primarily by Stifel’s utilization of “trade compression,” a process by which data relating to multiple ...

BMO CMC’s submissions contained inaccurate EBS fields related to information about the securities transactions reported, such as average price account data, solicited codes, contra-party identifiers, ...

Vandham’s AML Policies expressly specified certain “red flags” indicative of potential money laundering or other criminal or unlawful activity. An employee encountering suspicious activity or ...

In July 2016, GIG’s Chief Compliance Officer identified the omission of parties from the Application and the resulting non-compliance with the Co-Invest Order and informed ...

ED Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written policies and procedures reasonably ...