Fines & Wines
Fines & Wines is a podcast by TRADEliance - a consulting firm for firms in the U.S. financial industry focused on Trading Operations and Compliance issues. Listen in as Jesy and Kat discuss their take on some of the recent disciplinary actions shaping the financial industry over a glass of fine wine. Though these episodes are intended to be casual, and a fun take on discussing regulation, our consultants are serious when it comes to helping you out. www.tradeliance.com
Fines & Wines
So an Asset Manager Prices Some Bonds
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TRADEliance
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Season 1
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Episode 10
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
SEC Statement on Investment Company Cross Trading
