Examinations Enforcement: Settlement

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 ...

Because Woodbury failed to obtain verification by actual examination of the client funds and securities in the accounts by an independent public accountant, Woodbury violated ...

Reps recommended and executed over 2,000 trades in these customers’ accounts without regard for the high transaction costs This high volume of recommended transactions and ...

Apexium did not document why investing with the Affiliated Manager was in the best interest of any particular client or group of clients at the ...

The firm's revised P&Ps now require reps to request oral consent to electronic delivery from customers using a consent and disclosure script. If a customer ...

The adviser would 'periodically' have its disclosures 'reviewed and revised by WAM’s internal and external legal and compliance professionals, but those revisions did not adequately ...

AssetMark failed to provide full and fair disclosure of conflicts of interest arising from ATC’s cash sweep program, which transferred, or “swept,” clients’ uninvested cash ...

Neither the adviser or its principal mentioned that the money invested by clients in an affiliated company would be used to fund payroll or to ...

While the firm's compliance policy required advertising materials to be accurate, it did not adopt procedures for compliance personnel to verify the accuracy or completeness ...

While the adviser trained investment professionals on the ESG Integration Policy, some in senior portfolio management positions were not aware of the ESG Integration Policy ...