Trust Advisory Group Ltd

Allegations: ON JUNE 7, 2022, THE FIRM, WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE ENTRY OF THE U.S. SECURITIES AND EXCHANGE COMMISSION'S 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 (THE "ORDER"), ADMINISTRATIVE PROCEEDING FILE NO. 3-20890. THE ORDER FOUND THAT TAG BREACHED ITS FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH ITS AFFILIATED BROKER-DEALER'S RECEIPT OF REVENUE RESULTING FROM ADVISORY CLIENTS' ASSETS IN CASH SWEEP PRODUCTS. FROM DECEMBER 2015 TO MARCH 2022, TAG'S AFFILIATED BROKER DEALER, AGES FINANCIAL SERVICES, LTD. RECEIVED REVENUE SHARING PAYMENTS FROM ITS CLEARING BROKER FOR TAG'S CLIENTS' ASSETS IN CASH SWEEP PRODUCTS, INCLUDING MONEY MARKET MUTUAL FUNDS AND FDIC-INSURED BANK DEPOSIT ACCOUNTS. THE ORDER FOUND THAT TAG FAILED TO PROVIDE FULL AND FAIR DISCLOSURE OF THIS REVENUE SHARING AND THE RESULTING CONFLICTS OF INTEREST. ADDITIONALLY, THE ORDER FOUND THAT TAG FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER RELATED TO ITS DISCLOSURE OF CASH SWEEP REVENUE SHARING AND THE ASSOCIATED CONFLICTS OF INTEREST. AS A RESULT OF THIS CONDUCT, THE ORDER FOUND THAT TRUST ADVISORY GROUP WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)- 7 THEREUNDER. ACCORDING TO THE ORDER, TAG AGREED TO PAY DISGORGEMENT, PREJUDGMENT INTEREST AND A CIVIL PENALTY TOTALING $214,460.07. Status: Final Sanction Detail: DISGORGEMENT OF $148,255.15 AND PREJUDGMENT INTEREST OF $16,204.92. CIVIL PENALTY OF $50,000.00. Summary: ON JUNE 7, 2022, THE FIRM, WITHOUT ADMITTING OR DENYING THE FINDINGS, CONSENTED TO THE ENTRY OF THE U.S. SECURITIES AND EXCHANGE COMMISSION'S 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 (THE "ORDER"), ADMINISTRATIVE PROCEEDING FILE NO. 3-20890. THE ORDER FOUND THAT TAG BREACHED ITS FIDUCIARY DUTY TO ITS ADVISORY CLIENTS IN CONNECTION WITH ITS AFFILIATED BROKER-DEALER'S RECEIPT OF REVENUE RESULTING FROM ADVISORY CLIENTS' ASSETS IN CASH SWEEP PRODUCTS. FROM DECEMBER 2015 TO MARCH 2022, TAG'S AFFILIATED BROKER DEALER, AGES FINANCIAL SERVICES, LTD. RECEIVED REVENUE SHARING PAYMENTS FROM ITS CLEARING BROKER FOR TAG'S CLIENTS' ASSETS IN CASH SWEEP PRODUCTS, INCLUDING MONEY MARKET MUTUAL FUNDS AND FDIC-INSURED BANK DEPOSIT ACCOUNTS. THE ORDER FOUND THAT TAG FAILED TO PROVIDE FULL AND FAIR DISCLOSURE OF THIS REVENUE SHARING AND THE RESULTING CONFLICTS OF INTEREST. ADDITIONALLY, THE ORDER FOUND THAT TAG FAILED TO ADOPT AND IMPLEMENT WRITTEN COMPLIANCE POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER RELATED TO ITS DISCLOSURE OF CASH SWEEP REVENUE SHARING AND THE ASSOCIATED CONFLICTS OF INTEREST. AS A RESULT OF THIS CONDUCT, THE ORDER FOUND THAT TRUST ADVISORY GROUP WILLFULLY VIOLATED SECTIONS 206(2) AND 206(4) OF THE ADVISERS ACT AND RULE 206(4)- 7 THEREUNDER. ACCORDING TO THE ORDER, TAG AGREED TO PAY DISGORGEMENT, PREJUDGMENT INTEREST AND A CIVIL PENALTY TOTALING $214,460.07.