Dual Registrants

The five settled cases are tied to unsuitable sales of volatility-linked exchange-traded products

CSM to pay $260K for breaching fiduciary duty, not adequately disclosing conflicts, and failing to seek best execution

Compliance bulletins on manipulative trading techniques seemingly ignored

Altered reports were delivered to OCIE and Enforcement by the CCO

A failure to deliver final prospectuses in shelf offerings triggers enforcement action

Communications to fund boards' on arrangement considered misleading

"Include any considerations and limitations on making recommendations to retail customers (including when recommendations must be documented) and the disclosures must be made to retail ...

The fact that the recipient of the recommendation is a regulated financial services industry professional would not excuse a firm from complying with Regulation Best ...

"This may create incentives to act against your best interest to generate trading profits or minimize losses"

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