So an Asset Manager Prices Some Bonds

04/13/23 • 17 min

Totals in Fines: Disgorgement: $11,000,000 + Prejudgment Interest $3,375,072, Firm Civil Penalty: $4,400,000, and Adviser Civil Penalty: $600,000

Jesy is drinking wine in the laundry room 😊
Rules
- Investment Advisers Act Rule 206-2
- Investment Company Act Section 17(A)1 and 17(A)2
Investment Adviser Act uses anti-fraud for Best Execution
The Asset Management Company was pricing the bond trades, not the broker dealers
Asset Manager prices the executions, executions impact the evaluated pricing model, Net Asset Value (NAV) is calculated with the evaluated price, Asset Manager is paid a % of the NAV
Good opportunity for both Broker Dealers and Investment Advisers to review their Best Execution and Fair Pricing practices

04/13/23 • 17 min

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