• SEC charges 11 investment managers with failing to report major shareholding.
• Two of the firms were also charged with failing to report large trader transactions.

Involved Parties

• Orders filed against Ashton Thomas Private Wealth, LLC, Azzad Asset Management, Inc., Bulltick Wealth Management, LLC, and Dixon Mitchell Investment Counsel Inc.
• Also orders against Financial Synergies Wealth Advisors, Inc., Focus Financial Network, Inc., Mason Investment Advisory Services, Inc., and TD Private Client Wealth LLC.
• Nationale-Nederlanden S.A., Traphagen Investment Advisors, LLC, and NEPC, LLC.

Alleged Violations

• Failed to file Forms 13F that were required for major shareholding due to handling over $100mn in securities.
• Two of the entities, Nationale-Nederlanden Powszechne Towarzystwo Emerytalne S.A. and NEPC, LLC, were also charged with failing to file Form 13H for large traders.
• Firms accused of violating SEA section 13(f)(1) (15 USC 78m(f)(1)) and Rule 13f-1 thereunder (17 CFR 240.13f-1) by failing to file Forms 13F by designated timeline.
• All 11 firms agreed to settle charges.; 9 will pay over $3.4mn combined penalties.

Enforcement

• The institutional investment managers charged and their respective penalties are:
• Azzad Asset Management, Inc., Financial Synergies Wealth Advisors, Inc., and Traphagen Investment Advisors, LLC all individually fined a penalty of $225,000.
• Focus Financial Network, Inc. and TD Private Client Wealth, LLC penalties of $475,000.
• Bulltick Wealth Management, LLC - $175,000; Ashton Thomas Private Wealth, LLC - $375,000; Mason Investment Advisory Services, Inc - $525,000; NEPC, LLC -$725,000
• Dixon Mitchell Investment Counsel, Inc. and Nationale-Nederlanden were given no financial penalty because they self-reported the violations and cooperated with SEC.
• NEPC, LLC was not ordered to pay a civil penalty for its failure to file Form 13H because it self-reported violations and cooperated with the SEC’s investigations.