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 $1,246,133.60, prejudgment interest of $229,332.28, and a civil penalty of $140,000.

SEC Order

SEC Administrative Summary