ERC721

According to the SEC's order, Merrill Lynch failed to disclose its conflicts of interest when recommending that clients use directed brokerage to pay hard dollar fees, whereby the clients directed their money managers to execute trades through Merrill Lynch. These clients received credit for a portion of the commissions generated by these trades against the hard dollar fee owed for the advisory services provided by Merrill Lynch Consulting Services. Consequently, Merrill Lynch and its investment adviser representatives could and often did receive significantly higher revenue if clients chose to use Merrill Lynch directed brokerage services. The SEC's order finds that Merrill Lynch also failed to disclose a similar conflict of interest in recommending that clients use Merrill Lynch's transition management desk. In addition, the SEC finds that Merrill Lynch made misleading statements to the clients served by its Ponte Vedra South, Fla. office regarding the process used to identify new money managers to present to its clients.

Name

394

Owner

0x535e9D69758B9CB3dfBDB3691808487619eAA30A

ID#394

Rarity

X-LO:93%

Parent Company

Bank of America

X-HI:10%

Company

Merrill Lynch, Pierce, Fenner & Smith, Inc.

EX:MAX

Violation

Mortgage Abuses

EX:5%

Penalty

$1,000,000.00

EX:2%

Year

2009