Pay $500,000. Get Censured.
Independent Financial Group was a dually registered broker-dealer and investment adviser. It had investment discretion over at least $100 million in reportable securities under Rule 13f and met the definition of “institutional investment manager” under section 13(f).
The firm reached that threshold in December 2021. That triggers the requirement of filing Form 13F to disclose its holdings. Independent Financial Group did not do so. This continued.
“Throughout this time, Respondent’s Chief Compliance Officers recommended that Respondent comply with Section 13(f) of the Exchange Act by filing Forms 13F, however, no Forms 13F were filed until May 2026.”
Ignore your CCOs, pay the fine.
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