Defendant Name: Tudor, Pickering, Holt & Co. Securities LLC

Defendant Type: Subsidiary of Public Company

Document Reference: 2023-212_3-21769

Document Details

Legal Case Name In the Matter of Perella Weinberg Partners LP; Tudor, Pickering, Holt & Co. Securities LLC; and Parella Weinberg Partners Capital Management
Document Name SEC Charges 10 Firms with Widespread Recordkeeping Failures
Document Date 29-Sep-2023
Document Format Administrative Proceeding
File Number 3-21769
Allegation Type Broker Dealer
Document Summary On September 29, 2023, the SEC "announced charges against five broker-dealers, three dually registered broker-dealers and investment advisers, and two affiliated investment advisers for widespread and longstanding failures to maintain and preserve electronic communications. The firms admitted the facts set forth in their respective SEC orders and acknowledged that their conduct violated recordkeeping provisions of the federal securities laws. The firms agreed to pay combined penalties of $79 million as outlined below and have begun implementing improvements to their compliance policies and procedures to address these violations."

Disgorgement & Penalty Information

Resolutions
Cease and Desist Order
Censured
Compliance Related Independent Consultant
Self Reporting to SEC
Monetary Penalties:

Civil Penalty

Individual:     Shared:     $2,500,000.00
Shared with: Perella Weinberg Partners LP; Perella Weinberg Partners Capital Management

Related Documents:

34-98632 29-Sep-2023 Administrative Proceeding
Order Instituting Administrative and Cease-And-Desist Proceedings, Pursuant to Sections 15(b) and 21C of the Securities Exchange Act of 1934 and Sections 203(e) and 203(k) of the Investment Advisers Act of 1940, Making Findings, and Imposing Remedial Sanctions and a Cease-and-Desist Order
On September 29, 2023, the SEC instituted settled administrative and cease-and-desist proceedings against Perella Weinberg Partners LP, Tudor, Pickering, Holt & Co. Securities LLC, and Parella Weinberg Partners Capital Management, stating: "These proceedings arise out of Perella's identification--and self-report--of widespread and longstanding failures of certain Perella employees throughout the firms, including at senior levels, to adhere to certain of these essential requirements and Perella's own policies. Using their personal devices, these employees communicated both internally and externally by personal text messages or WhatsApp ("off-channel communications")."