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Cowen determined that a government money market fund, as opposed to another type of money market fund, was an appropriate cash sweep vehicle for its ...
Buttonwood and McGraw therefore had a financial conflict of interest with their clients—they had an incentive to select investments for clients that would allow Buttonwood ...
By making the false and misleading statements about the fee markups in its Firm Brochures or otherwise, Roberts and TCFG violated the fiduciary duties they ...
In total, on about 3,000 occasions, Polevikov used this material non-public information to execute trades in his wife’s brokerage account in the same securities and ...
Helikon did not qualify for an exception to Rule 105 when it purchased shares in the Offering
Oseas Zuluaga knew, or should have known, that Revere’s proprietary holdings should have been included in the calculation of Revere’s net capital
Coda did not always provide its subscribers with information indicating where their orders had been routed or executed
Certain MMLIS and MSI advisory clients to invest in share classes of mutual funds in the Clearing Broker’s NTF and TF Programs that resulted in ...
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 ...
Regal’s compliance manual designated Yarch with implementing Regal’s compliance program as well as monitoring and updating Regal’s Form ADV disclosures. In November 2019, Regal adopted ...