Principal Trades

JP Morgan IM failed to adopt and implement adequate policies and procedures to prevent unlawful principal trades by its investment professionals during the Relevant Period ...

Before engaging in a principal trade, an adviser would first have to disclose certain information to the client

The adviser did not have procedures or controls in place to identify or monitor cross trades involving RICs. It also did not conduct any testing ...

Perini Capital and CEO Michael Perini charged with directing principal trades without first providing disclosure and obtaining client consent

The Advisers Act, which prohibits an investment adviser, while acting as a principal for his own account, from knowingly selling any security to or purchasing ...

Korth did not have policies and procedures concerning riskless principal transactions until March 2018. The policies and procedures Korth adopted in March 2018 were not ...

The most embarrassing evidence examiners uncovered was firms that prohibited such trades yet were unaware that “these trades had occurred.” The risk alert encourages best ...

Nearly two-thirds of the examined advisers received staff-issued deficiency letters, which addressed the staff’s observations regarding a variety of topics. However, the vast majority of ...

$125,000 in fines for failing to obtain client consent

 Investment advisers are struggling with disclosure rules tied to agency cross trades, and when selling or buying securities from their clients—especially when pooled investments are ...