Disciplinary Information. There are no legal or disciplinary events to disclose in response to this item.
Disciplinary Information. The disciplinary information shall include documentation generated in accordance with Article 14.
Disciplinary Information. Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that have occurred in the last 10 years that would be material to a client’s evaluation of Confluence or the integrity of Confluence’s management. Confluence has no information applicable to this item to disclose.
Disciplinary Information. Disciplinary action, including discharge, may be taken by the County against any employee or employees engaging in a violation of this Article while on paid duty time. Disciplinary action that goes to the grievance procedure under Article 25.2 is limited to whether the employee(s) engaged in the alleged conduct.
Disciplinary Information. There are no legal or disciplinary events that would be material to your evaluation of this supervised person providing investment advice.
Disciplinary Information. On September 18, 2018, the SEC instituted a settled order against the firm and Xxxxx X. Xxxxxxx, the firm’s president. Creative Planning distributed hundreds of radio advertisements that contained prohibited client testimonials. The radio station DJ had become a client of the firm and, on air, discussed his and his wife’s satisfaction with our services and with their advisor. Creative should have been aware of these testimonials and stopped them. Creative and Mallouk failed to enforce the firm’s code of ethics with regard to the radio advertisements and the reporting and review of certain securities accounts in which the firm’s president had a beneficial interest. Creative failed to keep true and accurate books and records and failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Creative consented to a cease-and-desist order, a censure, and a civil penalty of $200,000 and Mallouk consented to a cease-and-desist order and a civil penalty of $50,000.
Disciplinary Information. Registered investment advisers must disclose all material facts about any legal or disciplinary events that would be material to evaluation of SPARROW or the integrity of the firm’s management. XXXXXXX does not have any legal, financial or other “disciplinary” item to report.
Disciplinary Information. As an investment advisor and broker-dealer regulated by the SEC, LPL has been subject to the following SEC orders: • The SEC found that LPL willfully violated Rule 30(a) of Regulation S-P, which requires broker-dealers and registered investment advisors to have written policies and procedures that are reasonably designed to safeguard customer records and information. The SEC ordered LPL to cease and desist from committing future violations of Rule 30(a), censured it for its conduct, and ordered it to pay the $275,000 penalty (2008). • The SEC found that LPL willfully violated Section 17(a)(2) of the Securities Act of 1933 and Rule 10b-10 under the Securities Exchange Act of 1934 in connection with the SEC’s finding that LPL sold mutual fund shares as a broker-dealer without providing certain customers with breakpoint discounts. In connection with the SEC’s order, LPL agreed to pay a fine of $1,116,402 (2004). LPL, as a broker-dealer, is a member of the Financial Industry Regulatory Authority (“FINRA”) and has found to be in violation of FINRA’s rules related to its brokerage activities. In particular, LPL consented to the following sanctions related to the following matters: • LPL’s supervisory systems to monitor and ensure the timely delivery of mutual fund prospectuses, resulting in a censure and fine of $400,000 (2012). • LPL’s procedures regarding its review of e-mail communications, resulting in a censure and fine of $100,000 (2011). • LPL’s procedures on transmittals of cash and securities from customer accounts to third party accounts, resulting in a censure and fine of $100,000 (2011). • LPL’s procedures on supervision of variable annuity exchanges, resulting in a censure and fine of $175,000 (2010). • Allegations that LPL failed to reasonably supervise a registered representative regarding his use of strategies and recommendations involving UITs, resulting in a censure and fine of $125,000 (2008). • LPL’s procedures on supervision of variable annuity exchanges, resulting in a censure and fine of $300,000 (2006). • LPL’s procedures regarding mutual fund Class B and Class C shares, resulting in a censure and fine of $2,400,000 (2005). • LPL’s procedures on supervision activities of its registered representative in connection with wire transfers, resulting in a censure and fine of $75,000 (2005). • Allegations that LPL maintained revenue sharing programs in which mutual fund complexes paid a fee for preferential treatment, resulting in a censure and ...
Disciplinary Information. 1. Material originating within the DISTRICT and which relates to an employee's conduct, service, character, competence, or personality shall not be placed in an employee's file unless the employee has had an opportunity to read the material. The employee shall acknowledge that he/she has read such material by affixing his/her signature on the actual copy to be filed. Such signature does not necessarily indicate agreement with the content of such material. Anonymous material shall not be placed in the file.
2. The employee shall have the right to photocopy, answer or comment upon material filed, and his/her answer or comments shall be attached to the file copy.
Disciplinary Information. We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose.
