Examinations Enforcement: Settlement

He failed to disclose his financial interest in a group of private affiliated companies that had committed to investing $30 million in a company that ...

During the examination, Commission staff informed Ali about the Advisers Act custody rule’s requirements and its prohibition against commingling client money with the firm’s. However, ...

CCA benefited from this arrangement by deferring payment on its legal costs for multiple years

A staffer at the adviser "made a campaign contribution to a candidate for elected office in Minnesota, which office had influence over selecting investment advisers ...

Bradesco disseminated hypothetical performance in advertisements to a mass audience rather than presenting hypothetical performance relevant to the likely financial situation and investment objectives of ...

Credicorp failed to adopt and implement policies and procedures reasonably designed to ensure that the performance was relevant to the likely financial situation and investment ...

The advertisements included hypothetical performance that consisted of performance derived from model portfolios. The advertisements on the website were disseminated to the general public rather ...

InSight advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant ...

On its public website and on various social media sites, GeaSphere included a promotional video called “The GeaSphere Difference” that made false and misleading statements

Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate