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Disclosure
The advisers' "Forms ADV Part 2A, included misleading statements about the Respondents’ cash allocation decisions for the SIP portfolios, and failed to adequately disclose the ...
Trust Advisory Group did not provide full and fair disclosure regarding the revenue AGES Financial Services received from the Clearing Broker based on client assets ...
Since at least January 2016, and continuing from the date Harnish purchased KMA in February 2020 and through December 2020, KMA invested the vast majority ...
These disclosures did not adequately disclose all material facts regarding the conflicts of interest that arose when it invested advisory clients through the Introducing Broker-Dealer ...
These disclosures that commission rates charged “may” not be the “lowest,” the “absolute lowest,” or even “not the lowest” failed to fully and fairly disclose ...
Cornerstone 'officers acted with at least extreme recklessness,' Commission claims in new suit
In reaffirming 'existing obligations,' the SEC also gives examples of what advisers should and shouldn’t do
The certification shall identify the undertakings, provide written evidence of compliance in the form of a narrative, and be supported by exhibits sufficient to demonstrate ...
Advisers would have to describe their use of ESG factors, their strategies, methods of analysis and how they voted relevant proxies
"Funds are admonished to include in their compliance policies and procedures a requirement that employees memorialize the discussion of ESG issues"