Action against Respondent, a dually registered broker-dealer and investment adviser, for alleged misrepresentations to clients. According to the SEC, Respondent’s predecessor in interest made misstatements in Form ADV filings and client contracts about services and prices offered by its in-house broker. The SEC alleges that Respondent’s predecessor in interest failed to disclose to clients that it benefitted financially when clients selected this broker. Respondent has agreed to pay disgorgement of $4,712,366, prejudgment interest of $497,387, and a civil penalty of $500,000.

SEC Order

SEC Press Release