Defendant Name: Key Investment Services LLC

Defendant Type: Subsidiary of Public Company

Document Reference: 2024-18_ 3-21849

Document Details

Legal Case Name In the Matter of Key Investment Services LLC, and KeyBanc Capital Markets Inc.
Document Name Sixteen Firms to Pay More Than $81 Million Combined to Settle Charges for Widespread Recordkeeping Failures
Document Date 09-Feb-2024
Document Format Administrative Proceeding
File Number 3-21849
Allegation Type Broker Dealer
Document Summary On February 9, 2024, the SEC "announced charges against five broker-dealers, seven dually registered broker-dealers and investment advisers, and four affiliated investment advisers for widespread and longstanding failures by the firms and their employees to maintain and preserve electronic communications."

Disgorgement & Penalty Information

Resolutions
Cease and Desist Order
Censured
Compliance Related Independent Consultant
Other Compliance Related Undertaking
Monetary Penalties:

Civil Penalty

Individual:     Shared:     $10,000,000.00
Shared with: KeyBanc Capital Markets Inc.

Related Documents:

34-99500 09-Feb-2024 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 February 9, 2024, the SEC instituted administrative and cease-and-desist proceedings against Key Investment Services LLC and KeyBanc Capital Markets Inc., stating: "From at least January 2019, KIS and KBCM employees sent and received offchannel communications that related to the broker-dealer businesses operated by KIS and KBCM, and with respect to KIS’s investment advisory businesses related to recommendations made or proposed to be made and advice given or proposed to be given. Respondents did not maintain or preserve the substantial majority of these written communications. Respondents’ failures were firm-wide and involved employees at various levels of authority. As a result, KIS and KBCM violated Section 17(a) of the Exchange Act and Rule 17a-4(b)(4) thereunder and KIS violated Section 204 of the Advisers Act and Rule 204-2(a)(7) thereunder."

Other Defendants in Action:

KeyBanc Capital Markets Inc.