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The CFTC settled charges against an investment bank that failed to disclose certain conflicts of interest to clients. Specifically, the bank failed to disclose its preference for investing client funds in certain commodity pools or exempt pools, namely hedge funds and mutual funds managed and operated by an affiliate and subsidiary of the bank. The CFTC required the bank to pay a $40 million civil monetary penalty, to disgorge $60 million and to cease and desist from further violations.