- 2016
- $41,500
Respondent firm was charged with failures to: (1) properly conduct principal transactions; (2) accurately disclose its practices regarding principal transactions; and (3) implement compliance policies and procedures regarding principal transactions and best execution. Medley, Jr. was the firm’s Chief Investment Officer, responsible for overseeing its investment advisory business during the relevant time. This proceeding followed multiple deficiency letters. Respondents were ordered to cease-and-desist and fined. The firm was also censured.
