- Cadaret, Grant & Co.,fined $800 and required to retain independent consultant.
- Consultant to conduct comprehensive review of adequacy of policy, procedures.
- Review staffing, training relating to the rule violations identified in enforcement.
- Failed to establish a reasonably-designed supervisory system in business areas.
- Deficiencies stemmed from failure of resources paid to supervision of personnel.
- Failed to ensure representatives’ variable annuity recommendations are suitable.
- Did not provide guidance to compliance personnel, how to review blotter trades
to detect potential violations on suitability for clients, or provide follow-up steps.