- incorrectly classifying one funding fund as decrease danger than it truly was
- permitting some purchasers to be positioned into unsuitable investments
- putting itself in a battle of curiosity with sure purchasers, and
- failing to keep up adequate and present “know your consumer” data, suitability data, due diligence and analysis, conflicts, private buying and selling and danger administration.
Fieldhouse had phrases and circumstances imposed on it following the examination which included hiring an unbiased compliance monitor for one yr. These phrases and circumstances aimed to deal with the deficiencies recognized and had been eliminated as soon as they had been remedied.
The agency’s former CEO and chief compliance officer (CCO), William Douglas Sereda, additionally acknowledged his failures in enough efficiency of CCO and supreme designated particular person (UDP) duties and agreed to pay $25,000 in settlement. Sereda additionally agreed to not search registration as a CCO or UDP of a registrant within the subsequent 5 years.
A former FCMI portfolio supervisor agreed a separate settlement with the BCSC in 2023 and paid $60,000 to the fee for steering purchasers into an unsuitable funding. Sixteen of Todd David MacSween’s purchasers invested roughly $4.3 million in one of many agency’s funding funds, the Class M World Macro Core Fund, regardless of the fund being too dangerous for every of them and unsuitable for his or her wants, goals and private and monetary circumstances.
