Defendant Name:
Bradesco Global Advisors Inc.
Defendant Type:
Subsidiary of Public Company
Public Company Parent:
Banco Bradesco S.A.
SIC Code:
6021
CUSIP:
05946040
Document Reference:
IA-6589
Document Details
Legal Case Name
In the Matter of Bradesco Global Advisors Inc.
Document Name
Order Instituting Administrative and Cease-and-Desist Proceedings, Pursuant to 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
Document Date
12-Apr-2024
Document Format
Administrative Proceeding
Allegation Type
Investment Advisers/Investment Companies
Document Summary
On April 12, 2024, the SEC instituted settled administrative and cease-and-desist proceedings against Bradesco Global Advisors, stating: "This matter involves failures by Bradesco, a registered investment adviser, to comply with amendments to Advisers Act Rule 206(4)-1 that the Commission adopted in December 2020 (the “Amended Marketing Rule”). From November 4, 2022, the compliance deadline for the Amended Marketing Rule, through June 8, 2023 (the “Relevant Period”), Bradesco advertised hypothetical performance on its public website without adopting and implementing policies and procedures reasonably designed to ensure that the hypothetical performance was relevant to the likely financial situation and investment objectives of the intended audience. As a result, Bradesco violated Section 206(4) of the Advisers Act and Rule 206(4)-1(d) thereunder."
Disgorgement & Penalty Information
Resolutions
Cease and Desist Order
Censured
Other Compliance Related Undertaking
Remedial Acts or Efforts Before the Resolution
Monetary Penalties:
Civil Penalty
Individual:
$20,000.00
Shared: