"The infrastructure fee is not, and has never been, charged for Fidelity’s services to any plan and is not paid by participants or plans"
The "nebulous nature of such principles allows great latitude to investment advisers”
ESG is hotter than ever, and regulators have noticed the trend
The changes bring the act in line with the RBIC Advisers Relief Act of 2018
Justices wondered if disgorgement goes to harmed investors or lands in the Treasury
The NFA encourages members to review their BCPs and to include the prospect of a pandemic in their plans
compliance staff failed to create P&Ps to ensure that reps were being monitored when placing clients in inverse ETFs
“Congress has never given the SEC authority to seek and obtain an order of disgorgement from a district court”
The client “hit rock bottom” after being told of Boggs’ alleged fraud
The "SEC had sent prior warnings to Defendants about problems in their advertising and disclosures and also warning that it would consider ‘recidivist behavior’"