Examinations Enforcement: Settlement

Cetera did not require the reps to place aggregated orders through internal systems, which would have prevented the post-trade allocations from being made

It can amount to easy pickings for the SEC when an adviser has an obligation to file information with the Commission but neglects to fulfill ...

Vistia Capital did not timely amend its Form CRS to disclose that one of its financial professionals had disciplinary history as required

Prior to and after being approached by the Commission, Stifel enhanced its P&Ps, increased training on use of approved communications methods, and provided some personnel ...

The Commission requested documents in an unrelated investigation that revealed the use of off-channel and unpreserved communications. As a result, Glazer’s recordkeeping failures likely impacted ...

The firm gathered and produced emails and text messages, including those at senior levels, that were sent or received by text message on personal phones ...

Merrill personnel became aware that Harvest was not systematically adjusting the number of options contracts that Harvest purchased in numerous accounts with pre-2017 IMAs, but ...

Brighton did not disclose the incentives related to the Clearing Agreement to its advisory clients and prospective clients until June 2022 when it revised its ...

The firms provided certain personnel with firm-issued devices that included technology that enabled the capture, retention, and archiving of communications (including text messages) sent and ...

After discovering the off-channel communications, the firm voluntarily conducted an internal review ... and took remedial actions by making changes to its compliance program, including ...