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Lessons Learned From SEC Cases for September 2018

September 11, 2018

Lockwood Advisors has become yet another casualty in the SEC’s Office of Compliance Inspections and Examination’s (OCIE) focus on wrap programs. Not surprisingly, in this case, the SEC found that Lockwood violated the Compliance Program Rule (Rule 206(4)-7 of the Advisers Act) for failing to perform due diligence on portfolio managers in its wrap programs regarding their “trading away” practices. Click here for more information.