Defendant Name: Bolton Securities Corporation

Defendant Type: Other

Initial Case Details

Legal Case Name SEC v. Bolton Securities Corporation d/b/a/ Bolton Global Asset Management
First Document Date 04-Nov-2019
Initial Filing Format Civil Proceeding
Case Number 19-cv-40143
Allegation Type Investment Advisers/Investment Companies
Federal District Court Massachusetts, District of Massachusetts

Violations Alleged

Sections 206(2), 206(3), 206(4) Advisers Act; Rule 206(4)-7 Advisers Act


First Resolution Date 25-Feb-2021
Headline Total Penalty and Disgorgement

See Related Documents

Related Documents:

comp24660 04-Nov-2019 Complaint
On November 4, 2019, the SEC filed a complaint against Bolton Securities Corporation. The SEC stated: "Bolton Securities . . . violated federal law by (i) failing to tell clients about material conflicts of interest it had in advising clients to invest in or to hold mutual fund shares that paid Bolton Securities' affiliated broker-dealer substantial amounts of fees, and (ii) engaging in principal trading with clients through its affiliated broker-dealer--which was under common control with Bolton Securities--without giving the clients proper disclosure or obtaining required consent."
LR-24660 06-Nov-2019 Litigation Release
SEC Charges Investment Adviser for Failing to Disclose Conflicts
The SEC stated that: "[It] charged Bolton Securities Corporation d/b/a Bolton Global Asset Management, a registered investment adviser and broker-dealer based in Bolton, Massachusetts, with failing to disclose material conflicts of interest related to mutual fund 12b-1 fees and principal trading compensation generated from client investments."
complaint_19-cv-40143 07-Feb-2020 Complaint
Amended Complaint
The Commission stated: "By virtue of its failures to disclose material conflicts of interest . . . Bolton Securities negligently breached its fiduciary duty to its advisory clients in violation of Section 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"). Further, by knowingly engaging in fixed income trades through the principal trading account of an affiliated broker-dealer that was under common control, with insufficient prior disclosure to, and no consent obtained from, its advisory clients, Bolton Securities violated Section 206(3) of the Advisers Act. Finally, by failing to adopt and to implement written policies and procedures reasonably designed to ensure that Bolton Securities disclosed the conflicts of interest and obtained the required informed client consent prior to engaging in principal trading, Bolton Securities violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder."
court_doc39_19-cv-40143 25-Feb-2021 Court Docket Document
Final Judgment
On February 25, 2021, the Court issued a final judgment against Defendant Bolton Securities Corporation stating: "Defendant . . . consented to entry of this Final Judgment without admitting or denying the allegations of the Amended Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment."