CCO Liability

SEC Commissioner Hester Peirce has picked up the mantle carried by former SEC Commissioner Dan Gallagher in openly supporting compliance staff (IA Watch, June 16, ...

The Commission’s complaint alleged that Respondent misappropriated at least $7.9 million from at least 15 investment advisory clients by perpetrating a Ponzi scheme in which ...

Nadel fraudulently induced clients of RIA to invest tens of millions of dollars in what he falsely represented as a liquid, cash management investment program ...

In reality, Black Diamond managed no marketable assets at the time and has never met the minimum requirements for investment adviser registration with the Commission.

This matter involves a registered investment adviser—Hedgeable—that disseminated false and misleading marketing materials and performance data. Hedgeable operates a “robo-adviser”: an automated digital investment advisory ...

OCIE has made no secret of its interest in undisclosed compensation and failures to seek best execution. So the $598,000 in fines assessed against Landaas ...

L&C’s policies and procedures did not include any factors it considered when selecting a broker for its clients or how it obtained the most favorable ...

The life of Pennant Management, a Wisconsin advisory firm, would run 20 years. It may have continued if only its leader listened to its CCO, ...

During this time, Elste was aware that Pennant’s compliance program lacked sufficient resources but failed timely to address this deficiency, which contributed substantially to Pennant’s ...

Pennant, an investment adviser, negligently failed to perform adequate due diligence and monitoring of certain investments contrary to representations in its Form ADV Part 2A ...