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Examinations Enforcement: Settlement
ECM failed to engage an independent public accountant to verify by actual examination at least once during each calendar year the REOC Funds’ funds and ...
Although Laidlaw had monitoring procedures to detect potential violations by reps of the quantitative prong of the Care Obligation, Laidlaw did not reasonably maintain and ...
Respondents employed a strategy of taking quick profits on part of a particular securities position resulting in frequent trade recommendations in these accounts .... As ...
In connection with BlackRock’s investigation of potential misconduct by Aviron’s CEO, BlackRock identified its reporting errors
The Canadian-based exempt reporting adviser has since undertaken certain remedial steps, including updating and revising its Rule 105 policies and procedures to prevent future Rule ...
The adviser did not fulfill its duty of care obligations when it exchanged Wrap Program clients’ existing assets in certain mutual funds for other investments ...
When questioned by its bookkeeper, the CEO/CCO responded that they consisted of short-term loans from Fund A that he subsequently repaid to Fund A. However, ...
The Commission is aware of one former employee who was initially discouraged from communicating with Commission staff about potential violations of securities laws due to ...
Using their personal devices, these employees communicated both internally and externally by personal text messages, or other text messaging platforms such as WhatsApp and GroupMe ...
Maxim failed to file SARs for numerous transactions that it should have had reason to suspect involved possible fraudulent activity or had no business or ...