| 2022-03-04 | regulatory | WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, REGISTRANT AND ADVISORY AFFILIATE CONSENTED TO UNDERTAKINGS AND SANCTIONS BASED ON THE REGULATOR'S DETERMINATIONS THAT REGISTRANT AND ADVISORY AFFILIATE VIOLATED N.H. RSA 421-B:5-502(A)(2) AND THAT REGISTRANT VIOLATED N.H. RSA 421-B:3-302(C). SPECIFICALL… | Final | $800K |
| 2022-03-04 | regulatory | WITHOUT ADMITTING OR DENYING THE FACTS OR VIOLATIONS, REGISTRANT AND ADVISORY AFFILIATE CONSENTED TO THE ENTRY OF A DIVISION ORDER STATING THAT REGISTRANT'S AND ADVISORY AFFILIATE'S ACTS AND PRACTICES CONSTITUTED VIOLATIONS OF MASS. GEN. LAWS SECTION 102(2), 950 CODE MASS. REGS. 14.402(B)(13)(L), AN… | Final | $750K |
| 2022-03-04 | regulatory | WITHOUT ADMITTING OR DENYING THE FINDINGS, REGISTRANT AND ADVISORY AFFILIATE CONSENTED TO THE ENTRY OF AN SEC ORDER FINDING THAT REGISTRANT VIOLATED AND ADVISORY AFFILIATE CAUSED THE VIOLATION OF SECTIONS 206(2) AND 206(4)OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-8 THEREUNDER. SPECIFICA… | Final | $800K |