Common use of Disciplinary Information Clause in Contracts

Disciplinary Information. ‌ On September 18, 2018, the SEC instituted a settled order against the firm and Xxxxx X. Xxxxxxx, the firm’s president. Creative Planning distributed hundreds of radio advertisements that contained prohibited client testimonials. The radio station DJ had become a client of the firm and, on air, discussed his and his wife’s satisfaction with our services and with their advisor. Creative should have been aware of these testimonials and stopped them. Creative and Mallouk failed to enforce the firm’s code of ethics with regard to the radio advertisements and the reporting and review of certain securities accounts in which the firm’s president had a beneficial interest. Creative failed to keep true and accurate books and records and failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Creative consented to a cease-and-desist order, a censure, and a civil penalty of $200,000 and Mallouk consented to a cease-and- desist order and a civil penalty of $50,000.

Disciplinary Information. ‌ On September 18, 2018, the SEC instituted a settled order against the firm and Xxxxx X. Xxxxxxx, the firm’s president. Creative Planning distributed hundreds of radio advertisements that contained prohibited client testimonials. The radio station DJ had become a client of the firm and, on air, discussed his and his wife’s satisfaction with our services and with their advisor. Creative should have been aware of these testimonials and stopped them. Creative and Mallouk failed to enforce the firm’s code of ethics with regard to the radio advertisements and the reporting and review of certain securities accounts in which the firm’s president had a beneficial interest. Creative failed to keep true and accurate books and records and failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Creative consented to a cease-and-desist order, a censure, and a civil penalty of $200,000 and Mallouk consented to a cease-and- and-desist order and a civil penalty of $50,000.

Disciplinary Information. ‌ On September 18, 2018, the SEC instituted a settled order against the firm and Xxxxx X. Xxxxxxx, the firm’s president. Creative Planning distributed hundreds of radio advertisements that contained prohibited client testimonials. The radio station DJ had become a client of the firm and, on air, discussed his and his wife’s satisfaction with our services and with their advisor. Creative should have been aware of these testimonials and stopped them. Creative and Mallouk failed to enforce the firm’s code of ethics with regard to the radio advertisements and the reporting and review of certain securities accounts in which the firm’s president had a beneficial interest. Creative failed to keep true and accurate books and records and failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. Creative consented to a cease-and-desist order, a censure, and a civil penalty of $200,000 and Mallouk consented to a cease-and- and-desist order and a civil penalty of $50,000.