In re JSK Associates, Inc.

SEC Release No. IA-3175

March 14, 2011

The SEC published a settled administrative action against an investment advisor relating to (1) the firm's failure to disclose to advisory clients certain financial benefits that its affiliated broker-dealer received; (2) the firm's failure to provide prior written disclosure to clients that it would engage in fixed income transactions on a riskless principal basis (i.e. rather than as agent); and (3) for failing to adopt and implement policies and procedures designed to prevent violations of the Advisers Act and for failing to maintain and enforce a code of ethics satisfying Rule 204A-1 under the Advisers Act.

Cross References

IAA §§ 203(e), (f), (k)

IAA Rule 204A-1