Action against Respondent, an investment adviser, for alleged failure to disclose conflicts of interest.  According to the SEC, Respondent advised clients to purchase higher-cost mutual fund shares without disclosing the financial benefits Respondent received as a result.  Respondent agreed to pay disgorgement of $2,755,879 and prejudgment interest of $230,710.94 with all but disgorgement of $645,000 being subject to potential waiver.

SEC Order