The Banksters

0x3…6f4

ERC721

This matter involves LMWW’s processing of mutual fund orders in violation of Rule 22c-1(a) under the Investment Company Act, and failure to make and keep certain books and records in violation of Section 17(a)(1) of the Exchange Act. From at least September 1, 2002, through October 19, 2003, LMWW’s flawed mutual fund order processing system enabled LMWW registered representatives to process more than 18,000 mutual fund orders after 4:00 p.m. and receive the current day’s net asset value (“NAV”) without regard for the time the orders were placed. Hundreds of these orders were either received by LMWW after 4:00 p.m. or were the result of discretionary investment decisions made by LMWW registered representatives after 4:00 p.m. 2. Legg Mason had minimal written procedures governing the timing and pricing of mutual fund orders and, instead, relied almost exclusively on its mutual fund order entry system to block any orders from being processed after 4:00 p.m. ET, regardless of their time of receipt. In September 2003, LMWW discovered, however, that its system had been failing to block certain trades processed by LMWW registered representatives after 4:00 p.m. ET and that the problem existed since 1997. Although the violative trading was not the result of any improper agreements between LMWW personnel and their customers, this practice had the potential to affect shareholders in the mutual funds sold by LMWW. Shareholders in the mutual funds could have been harmed through dilution of their share values if personnel attempted to capitalize on post-market information by processing mutual fund orders after hours based on stale prices.

Name

369

Owner

0xc7c694d0366CaC79f31cb4e2A817eEDd9D71045a

ID#369

Rarity

LO:52%