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None of the 40,000 back-up tapes handled by Moving Company complied with these policies and procedures. MSSB never inspected the equipment used to destroy those ...
From 2013 until June 30, 2020, however, Arcadia failed to obtain the required surprise examinations for the client accounts for which it had custody
Waddell failed to implement its Compliance Policy over a six-year period when it repeatedly failed to follow up, including by failing to move clients from ...
The staff will review whether investment advisers have adopted and implemented written policies and procedures that are reasonably designed to prevent violations
In August 2018, a covered associate of Respondent made a campaign contribution to a candidate for elected office in California, which office had influence over ...
Between December 2020 and April 2021, two covered associates of Respondent made campaign contributions to a candidate for elected office in New York, New York, ...
In July 2018, an officer of the Bank of Hawaii made a campaign contribution to an incumbent for elected office in Hawaii, which office had ...
In May 2021, a covered associate of Respondent made a campaign contribution to a candidate for elected office in Massachusetts, which office had influence over ...
Respondents did not undertake a process to determine whether the loans were in the best interests of the lending Funds
BAG’s compliance manual included P&Ps requiring that trade orders include instructions for how the shares in the block trade are to be allocated. However, Brander ...