Action against Respondents, an investment adviser and its representatives, for alleged breaches of fiduciary duty and fraud.  According to the SEC, Respondents invested client funds in certain mutual fund share classes that charged 12b-1 fees when less expensive share classes were available.  The SEC further alleges that Respondents misled clients and maintained inadequate policies and procedures.  Respondent adviser has agreed to pay $740,250.20 in disgorgement, $108,368.10 in prejudgment interest, and a civil penalty of $260,000.  One Respondent representative has agreed to pay $217,883.16 in disgorgement, $31,750.80 in prejudgment interest, and a civil penalty of $75,000.  The other Respondent representative has agreed to pay $158,032.42 in disgorgement, $22,957.20 in prejudgment interest, and a civil penalty of $65,000.

SEC Order 

SEC Administrative Summary