Examinations Enforcement: Settlement

Schwab provided its personnel with firm-issued devices or other firm-approved applications, making communications through approved channels more readily available, and disciplined personnel who violated its ...

An unauthorized third party fraudulently persuaded a Robinhood employee to download remote access software onto a Robinhood computer and give the actor control of the ...

These off-channel communications included records required to be preserved under the Advisers Act because they related to a recommendation made or proposed to be made ...

The adviser failed to implement sufficient monitoring to ensure that its recordkeeping and communications policies were being followed

The firm didn't have sufficient resources devoted to its compliance function to adequately review and address the suspicious activity identified by its surveillance systems

The compliance department did not collect the referenced WhatsApp messages from the partner

Liquidnet also made material misrepresentations to subscribers and potential subscribers in response to due diligence inquiries about the safeguards it maintained over confidential subscriber trading ...

Even though the funds' governing documents specified how expenses would be allocated, managers did not adopt or implement any written P&Ps reasonably designed to prevent ...

Touradji Capital failed to produce the requested documents to the Exam Staff, though Touradji Capital ultimately provided requested records in response to a subpoena served ...

The adviser lacked a process for reviewing the type of information shared with customers about agency CMO bonds and lacked any process for reviewing their ...