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As an adviser that often relied on subadviser or other third-party-produced performance and marketing materials, both in hiring or retaining subadvisers and in marketing a ...
Ameriprise had inadequate written policies and procedures for evaluating and monitoring the accuracy of advertisements or performance information where the information came from third-party sources, ...
The documents also contained material misstatements concerning the inflated, hypothetical, and backtested performance track record of the Fund’s sub-adviser, F-Squared Investments, Inc. (“F-Squared”). IIA did ...
Five years after the SEC charged Ray Lucia over backtested performance claims, his case has sparked the Commission to ratify its five ALJs to “put ...
Most of the $35 million the now-bankrupt RIA F-Squared Investments paid in an SEC settlement represented “disgorgement” – or punishment for how investors were harmed. ...
Nearly three years after the SEC charged Howard Present, CEO of the ill-fated advisory firm F-Squared Investments, a federal jury has found Present liable for ...
“Advertising has been a perennial issue for us,” said Kevin Kelcourse, associate OCIE regional director in Boston, in explaining OCIE’s newest risk alert. It points ...
Advisers should review their compliance programs and practices in light of the topics noted in this Risk Alert. This information is intended to assist advisers ...
A peer shares the firm's policies and procedures for marketing materials and advertising.
A peer passes on the firm's policies and procedures for marketing.