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 this time period, Defendant offered its research analysts and securities research coverage in order to assist in gaining investment banking business and receive investment banking fees. It also received payments from other investment banks to cover their investment banking clients, and made payments to other securities firms primarily for research coverage for its investment banking clients. In addition, Defendant compensated its research analysts based in part upon their contributions to Defendant's investment banking business. These relationships and activities constituted substantial conflicts of interest for Defendant's research analysts."