On November 4, 2019, the SEC filed a complaint against Bolton Securities Corporation. The SEC stated: "Bolton Securities . . . violated federal law by (i) failing to tell clients about material conflicts of interest it had in advising clients to invest in or to hold mutual fund shares that paid Bolton Securities' affiliated broker-dealer substantial amounts of fees, and (ii) engaging in principal trading with clients through its affiliated broker-dealer--which was under common control with Bolton Securities--without giving the clients proper disclosure or obtaining required consent."

The Commission stated: "By virtue of its failures to disclose material conflicts of interest . . . Bolton Securities negligently breached its fiduciary duty to its advisory clients in violation of Section 206(2) of the Investment Advisers Act of 1940 ("Advisers Act"). Further, by knowingly engaging in fixed income trades through the principal trading account of an affiliated broker-dealer that was under common control, with insufficient prior disclosure to, and no consent obtained from, its advisory clients, Bolton Securities violated Section 206(3) of the Advisers Act. Finally, by failing to adopt and to implement written policies and procedures reasonably designed to ensure that Bolton Securities disclosed the conflicts of interest and obtained the required informed client consent prior to engaging in principal trading, Bolton Securities violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder."

On February 25, 2021, the Court issued a final judgment against Defendant Bolton Securities Corporation stating: "Defendant . . . consented to entry of this Final Judgment without admitting or denying the allegations of the Amended Complaint (except as to jurisdiction); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment."