Defendant Name: Bradesco Global Advisors Inc.

Defendant Type: Subsidiary of Public Company
Public Company Parent: Banco Bradesco S.A.
SIC Code: 6021
CUSIP: 05946040

Initial Case Details

Legal Case Name In the Matter of Bradesco Global Advisors Inc.
First Document Date 12-Apr-2024
Initial Filing Format Administrative Action
File Number 3-21912
Allegation Type Investment Advisers/Investment Companies

Violations Alleged

Other
• Section 206(4) Advisers Act; Rule 206(4)-1(d) Advisers Act

Resolutions

First Resolution Date 12-Apr-2024

Related Documents:

IA-6589 12-Apr-2024 Administrative Proceeding
Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to 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 April 12, 2024, the SEC instituted settled administrative and cease-and-desist proceedings against Bradesco Global Advisors, stating: "This matter involves failures by Bradesco, a registered investment adviser, to comply with amendments to Advisers Act Rule 206(4)-1 that the Commission adopted in December 2020 (the “Amended Marketing Rule”). From November 4, 2022, the compliance deadline for the Amended Marketing Rule, through June 8, 2023 (the “Relevant Period”), Bradesco advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant to the likely financial situation and investment objectives of the intended audience. As a result, Bradesco violated Section 206(4) of the Advisers Act and Rule 206(4)-1(d) thereunder."
2024-46_3-21912 12-Apr-2024 Press Release--Administrative Proceeding
SEC Charges Five Investment Advisers for Marketing Rule Violations
On April 12, 2024, the SEC "announced settled charges against five registered investment advisers for Marketing Rule violations. All five firms have agreed to settle the SEC's charges and to pay $200,000 in combined penalties."