Defendant Name: National Asset Management, Inc.

Defendant Type: Subsidiary of Public Company
Public Company Parent: National Holdings Corporation
SIC Code: 6211
CUSIP: 63637520

Initial Case Details

Legal Case Name In the Matter of National Asset Management, Inc.
First Document Date 26-Oct-2015
Initial Filing Format Administrative Action
File Number 3-16925
Allegation Type Investment Advisers/Investment Companies

Violations Alleged

Other
• Sections 204, 204A, 206(3), 206(4), 207 Advisers Act; Rules 204-1, 204-3, 204A-1, 206(4)-7(a) and b Advisers Act

Resolutions

First Resolution Date 26-Oct-2015
Headline Total Penalty and Disgorgement $200,000

Related Documents:

34-76264 26-Oct-2015 Administrative Proceeding
Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to Section 15(b)(6) of the Securities Exchange Act of 1934 and Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
On October 26, 2015, the SEC instituted settled cease-and-desist proceedings against National Asset Management, Inc. ("NAM"). The SEC stated: "These proceedings arise out of several disclosure and compliance-related violations during 2008 through 2012 by Commission-registered investment adviser National Asset Management, Inc. First, NAM failed to disclose to its advisory clients in writing or obtain their consent to over 21,000 securities trades executed in a principal capacity by NAM’s affiliated broker-dealers. Second, NAM failed to report in its Commission filings and timely disclose to its clients the disciplinary histories of several of its associated persons. Third, NAM did not enforce its code of ethics when its CEO, several directors, and many of its employees failed to submit hundreds of required reports on their personal securities trading to NAM. Finally, NAM failed to adopt and implement compliance policies and procedures reasonably designed to prevent violations of certain provisions of the Advisers Act and the rules thereunder, and failed to conduct a required annual review of its compliance policies and procedures."