Action against Respondent, an investment adviser, for allegedly overcharging customer advisory fees.  According to the SEC, Respondent falsely informed clients about the reason for transfers of their assets and made material misstatements in SEC filings.  The SEC also alleges that Respondent failed to implement required policies and procedures.  Respondent has agreed to a three-year supervisory and compliance bar and to pay disgorgement of $367,176, prejudgment interest of $38,205, and a civil penalty of $100,000.

SEC Order

SEC Press Release