Defendant Name:
Bolton Securities Corporation
Defendant Type:
Other
Document Reference:
complaint_19-cv-40143
Document Details
Legal Case Name
SEC v. Bolton Securities Corporation d/b/a Bolton Global Asset Management
Document Name
Amended Complaint
Document Date
07-Feb-2020
Document Format
Civil Proceeding
Case Number
19-cv-40143
Federal District Court
Massachusetts, District of Massachusetts
Allegation Type
Investment Advisers/Investment Companies
Document Summary
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."
