The respondent entered into a settlement agreement with Staff of the Commission regarding its failure to provide timely delivery of summary disclosure documents to investors who purchased exchange traded fund securities.
The failure was inadvertent and caused by a software programming error, with no evidence of investor losses or financial benefit to the respondent.
The Commission approved the settlement agreement, finding it in the public interest, and ordered a $700,000 administrative penalty, $35,000 in costs, and the implementation of enhanced control and supervision procedures.
