Totals in Fines:  Disgorgement: $11,000,000 + Prejudgment Interest $3,375,072, Firm Civil Penalty: $4,400,000, and Adviser Civil Penalty: $600,000

• Jesy is drinking wine in the laundry room 😊 
• Rules
  • Investment Advisers Act Rule 206-2
  • Investment Company Act Section 17(A)1 and 17(A)2
• Investment Adviser Act uses anti-fraud for Best Execution
• The Asset Management Company was pricing the bond trades, not the broker dealers 
• Asset Manager prices the executions, executions impact the evaluated pricing model, Net Asset Value (NAV) is calculated with the evaluated price, Asset Manager is paid a % of the NAV
• Good opportunity for both Broker Dealers and Investment Advisers to review their Best Execution and Fair Pricing practices

SEC Enforcement

SEC Risk Alert

SEC Statement on Investment Company Cross Trading 

Registration for TRADEliance's Upcoming Bullet Point Panel

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