According to the SEC: "Defendant engaged in acts and practices that created and/or maintained inappropriate influence by investment banking over research analysts, thereby creating conflicts of interest for its research analysts. Defendant failed to manage these conflicts in an adequate manner. During the relevant period, Defendant encouraged its research analysts to participate in investment banking activities, and used this participation as a factor to evaluate analysts and determine their compensation. The Research Department of Defendant coordinated the decision to initiate and maintain research coverage on certain companies with Defendant's Investment Banking Department, and coverage decisions were influenced by investment banking interests."