On June 15, 2015, the SEC instituted settled administrative and cease-and-desist proceedings against SFX Financial Advisory Management Enterprises, Inc. ("SFX") and Eugene S. Mason. According to the SEC: "From 2006 through 2011, Brian Ourand ('Ourand'), while SFX's Vice President and President, misappropriated at least $670,000 in assets from three client accounts. During this time, SFX failed to supervise Ourand and also committed compliance failures. In particular, SFX failed to adopt policies and procedures reasonably designed to prevent the misappropriation of client assets, failed to implement the policies it did have, violated the custody rule, and falsely stated in its Form ADV that it reviewed client accounts used for bill-paying services. SFX also failed to conduct its annual compliance review in 2011. Mason, SFX's Chief Compliance Officer ('CCO'), caused SFX's failure to implement its compliance policies, conduct an annual review and is responsible for a material misstatement in a Form ADV filing."