Rbc Rochdale, Llc

Allegations: THE OCC FOUND THAT THE BANK ENGAGED IN UNSAFE OR UNSOUND PRACTICES, INCLUDING ITS FAILURE TO ESTABLISH EFFECTIVE RISK MANAGEMENT AND INTERNAL CONTROLS. THIS FAILURE ALSO RESULTED IN NONCOMPLIANCE WITH 12 CFR PART 30, APPENDIX D, "OCC GUIDELINES ESTABLISHING HEIGHTENED STANDARDS FOR CERTAIN LARGE INSURED NATIONAL BANKS, INSURED FEDERAL SAVINGS ASSOCIATIONS, AND INSURED FEDERAL BRANCHES." THE BANK ALSO VIOLATED THE BANK SECRECY ACT (BSA) AND 12 CFR PART 9 - FIDUCIARY ACTIVITIES OF NATIONAL BANKS. Status: Final Sanction Detail: CITY NATIONAL BANK PAID THE PENALTY TO THE U.S. TREASURY. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE BANK CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE AND DESIST ORDER.

Allegations: ROYAL BANK OF CANADA IS ALLEGED TO HAVE VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITION WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITIONS WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER; THEREFORE THE FIRM IS FINED $35,000,000.00 AND IS PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY ENTERING INTO OR CONFIRMING THE EXECUTION OF A TRANSACTION THAT IS, IS OF THE CHARACTER OF, OR IS COMMONLY KNOWN TO THE TRADE AS A WASH SALE, OR IS A FICTITIOUS SALE. THE FIRM IS ALSO PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY EXECUTING ANY NONCOMPETITIVE TRANSACTION. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE SANCTIONS AND TO THE ENTRY OF FINDINGS THAT IT VIOLATED SECTION 4C(A) OF THE COMMODITY EXCHANGE ACT, AND COMMISSION REGULATION 1.38(A), BY KNOWINGLY ENTERING INTO PURCHASES AND SALES OF SINGLE STOCK FUTURES AND NARROW-BASED INDEX FUTURES CONTRACTS OPPOSITE ITS SUBSIDIARIES WITH THE EXPRESS OR IMPLIED UNDERSTANDING THAT THE POSITIONS WOULD BE OFFSET OR DELIVERED OPPOSITE EACH OTHER; THEREFORE THE FIRM IS FINED $35,000,000.00 AND IS PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY ENTERING INTO OR CONFIRMING THE EXECUTION OF A TRANSACTION THAT IS, IS OF THE CHARACTER OF, OR IS COMMONLY KNOWN TO THE TRADE AS A WASH SALE, OR IS A FICTITIOUS SALE. THE FIRM IS ALSO PERMANENTLY RESTRAINED, ENJOINED, AND PROHIBITED FROM DIRECTLY OR INDIRECTLY EXECUTING ANY NONCOMPETITIVE TRANSACTION.

Allegations: FAILURE TO MAKE AND KEEP BOOKS, RECORDS, AND ACCOUNTS, WHICH, IN REASONABLE DETAIL, ACCURATELY AND FAIRLY REFLECT THE TRANSACTIONS AND DISPOSITIONS OF THE ASSETS OF THE ISSUER. FAILURE TO DEVISE AND MAINTAIN A SYSTEM OF INTERNAL ACCOUNT CONTROLS SUFFICIENT TO PROVIDE REASONABLE ASSURANCE THAT TRANSACTIONS ARE RECORDED TO PERMIT PREPARATION OF FINANCIAL STATEMENTS IN CONFORMITY WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES. Status: Final Sanction Detail: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE-AND-DESIST ORDER Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTED TO THE ENTRY OF THE ORDER INSTITUTING CEASE-AND-DESIST PROCEEDINGS AND IMPOSING A CEASE-AND-DESIST ORDER

Allegations: THE SEC ALLEGED THAT FROM 2016 THROUGH 2019, CITY NATIONAL ROCHDALE DID NOT ADEQUATELY DISCLOSE THAT, WHERE IT WAS NOT PRUDENT OR POSSIBLE TO INVEST A CLIENT'S ASSETS IN THE INDIVIDUAL SECURITIES AND BONDS THAT COMPRISE CITY NATIONAL ROCHDALE'S INTERNALLY DEVELOPED MODEL PORTFOLIOS, CITY NATIONAL ROCHDALE WOULD INVEST THE CLIENT'S ASSETS IN CITY NATIONAL ROCHDALE'S PROPRIETARY MUTUAL FUNDS - WHICH ARE DESIGNED TO TRACK THE RESPECTIVE ASSET CLASS ALLOCATIONS USED IN CITY NATIONAL ROCHDALE'S MODEL PORTFOLIOS. CITY NATIONAL ROCHDALE AND ITS AFFILIATES RECEIVED FEES FROM SUCH INVESTMENTS. THE SEC FURTHER ALLEGED THAT FROM 2016 UNTIL JANUARY 2019, CITY NATIONAL ROCHDALE RECEIVED 12B-1 FEES FROM CERTAIN CLIENTS, SUCH AS THOSE WHO INVEST WITH CITY NATIONAL ROCHDALE THROUGH THEIR THIRD-PARTY FINANCIAL ADVISORS, WITHOUT ADEQUATELY DISCLOSING TO SUCH CLIENTS THAT A LOWER-COST SHARE CLASS WAS AVAILABLE TO THEM. THE SEC ALSO ALLEGED THAT CITY NATIONAL ROCHDALE FAILED TO IMPLEMENT POLICIES AND PROCEDURES REASONABLY DESIGNED TO DETECT AND PREVENT CONFLICTS OF INTEREST. Status: Final Sanction Detail: DISGORGEMENT OF $22,013,612, PLUS PREJUDGMENT INTEREST OF $2,848,192. THE DISGORGEMENT, PENALTY, AND PREJUDGMENT INTEREST AMOUNTS, COLLECTIVELY TOTALING $30,361,804, WERE PAID INTO A FAIR FUND ESCROW ACCOUNT ON MARCH 10, 2022. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, CITY NATIONAL ROCHDALE CONSENTED TO THE ENTRY OF AN ORDER FINDING THAT CITY NATIONAL ROCHDALE VIOLATED SECTIONS 206(2) AND 206(4) OF THE INVESTMENT ADVISERS ACT OF 1940 AND RULE 206(4)-7 THEREUNDER (THE "ORDER"). UNDER THE TERMS OF THE ORDER, CITY NATIONAL ROCHDALE WAS CENSURED AND AGREED TO PAY A TOTAL OF $30.4 MILLION IN DISGORGEMENT, PREJUDGMENT INTEREST, AND CIVIL PENALTY, AND TO USE THOSE MONIES TO ESTABLISH A FAIR FUND TO REPAY AFFECTED CLIENTS. CITY NATIONAL ROCHDALE HAS ENHANCED ITS DISCLOSURES REGARDING POTENTIAL CONFLICTS OF INTEREST AND, AS PART OF THE ORDER, IS RETAINING AN INDEPENDENT COMPLIANCE CONSULTANT TO REVIEW ITS POLICIES AND PROCEDURES REGARDING THE USE OF PROPRIETARY MUTUAL FUNDS.