Examinations Enforcement: Settlement

The firm's P&Ps called for its AML software to be calibration or tuned at least every one to three years. The system was only fully ...

The Monitoring Agreement did not contain a provision authorizing AIM to accelerate future monitoring fees from the Portfolio Company for the entire contract period if ...

The mismarking violations occurred as a result of a coding error in the logic used to compute Citadel Securities’s position calculated for Regulation SHO purposes ...

These proceedings arise out of Respondent’s failure to submit to the Commission complete and accurate data in response to Commission staff electronic blue sheets (“EBS”) ...

Hennig’s written policies and procedures failed to adequately address its Disclosure Obligation because, among other things, they did not provide sufficient guidance or procedures for ...

As Summit’s sole owner and investment adviser representative, President, and Chief Compliance Officer, Richard Urciuoli was responsible for Summit’s failures

Elm Partners published on its website at https://elmweath.com/returns-view that constituted advertisements because they offered Elm Partners’ investment advisory services with regard to securities to prospective ...

Hypothetical performance is defined as performance results that were not actually achieved by any portfolio of the investment adviser

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

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