
At various times beginning in January 2014, Pruco breached its fiduciary duty to its advisory clients by: (a) failing to conduct stated monitoring of client accounts to determine whether the wrap fee programs continued to be suitable for clients; (b) charging certain fees on some clients contrary to its disclosures; (c) recommending that clients purchase and hold certain mutual funds and mutual fund share classes that paid Pruco fees pursuant to Rule 12b-1 under the Investment Company Act of 1940 (“12b-1”) without disclosing the conflict of interest arising therefrom; (d) failing to disclose that it receivedrevenue sharing payments on client investments pursuant to an agreement with its clearing firm (“Clearing Firm”), which also allowed Pruco to avoid paying certain transaction fees for its clients’purchases of mutual funds; For more info visit https://www.sec.gov/litigation/admin/2020/34-90790.pdf