SEC Rule 206(2)

The defendants allegedly defrauded investors and client funds in connection with investments in pre-IPO shares while charging millions in undisclosed fees.

After reviewing a recent case, Janaya Moscony offers lessons learned and explains why this matters for advisers.

Penalties imposed over potentially misleading information on non-waivable legal rights.

"The Cash Flow King" was ordered to pay disgorgement of $2,967,535 and prejudgment interest thereon of $340,396 to the SEC, which was deemed satisfied by the restitution ordered in the DOJ's parallel criminal case.

Recent cases highlight the SEC's continuing focus on how financial incentives influence employee recommendations.

Vanguard and Empower allegedly created conflicts of interest by incentivizing advisers to steer clients toward fee-based services, minus the requisite disclosure.

After reviewing the case, Janaya Moscony offers compliance tips on disclosures and robust fee practices.

The SEC has recently closed three very different but equally brazen fraud cases, each a window into a distinct form of financial misconduct.