Defendant Name:
Lockwood Advisors, Incorporated
Defendant Type:
Subsidiary of Public Company
Public Company Parent:
Bank of New York Mellon Corporation
SIC Code:
6022
CUSIP:
06405810
Document Reference:
IA-4984
Document Details
Legal Case Name
In the Matter of Lockwood Advisors, Incorporated
Document Name
Order Instituting Cease-and-Desist Proceedings Pursuant to Section 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing a Cease- and-Desist Order
Document Date
14-Aug-2018
Document Format
Administrative Proceeding
Allegation Type
Investment Advisers/Investment Companies
Document Summary
According to the SEC, "This matter arises from Lockwood's failure to adopt and implement policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its assessment, oversight, and disclosure of the trading away practices of the third-party portfolio management firms in its wrap programs. More specifically, as described below, from at least 2008, and continuing on an ongoing basis to the present, Lockwood's policies and procedures failed to require that material information about trading away (i) would be obtained and considered by Lockwood prior to making the third-party portfolio management firms available to clients in its wrap programs and/or (ii) would be disclosed to clients directly or through their third-party registered investment advisers."
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
Cooperation Before the Resolution
Remedial Acts or Efforts Before the Resolution
Monetary Penalties:
Civil Penalty
Individual:
Shared:
$200,000.00