Investment Adviser Ordered to Cease-and-Desist from Violations of Securities Laws

This matter concerned alleged disclosure and best execution violations by the respondent investment adviser. The SEC found that respondent failed to make proper disclosures to certain clients whose accounts were held by full service broker-dealers (some of whom were referred by registered representatives of the full service b-d’s), and that these clients paid higher commissions than the firm’s other clients. During approximately a year-and-a-half period, the higher paying clients paid $0.35 per share, as opposed to a commission rate of $0.08 per share for respondent’s other clients.