Compliance Solutions for Investment Advisers

Category Archives: Brokerage Practices

Soft Dollar Disclosures

One part of Item 12 (Brokerage) in the ADV Part 2A that advisers tend to miss when disclosing their soft dollar activities: You must describe the types of products and services you or any of your related persons acquired with client brokerage commission (or markups or markdowns) within your last fiscal year. Note: This description

Soft Dollar Violations

Back to the SEC administrative action against J.S. Oliver Capital Management and its President, Ian Mausner. Not only were they involved in a Cherry-Picking scheme (see my January 28, 2015 post), but the SEC has alleged that they also misused soft dollars. The SEC also charged Douglas F. Drennan, a portfolio manager at J.S. Oliver, for his