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Another ten focused on investment advisers who negligently relied on certain information furnished by another adviser regarding the performance of an index recommended to clients. Finally, the PCAOB entered into a cooperation agreement with a German regulator. 3-17503 (August 25, 2016); In the Matter of BB&T Securities, LLC, Adm. Neither Orinda nor ATS told IM of the revised side agreement. The advisory agreements with each AST fund advised by Orinda incorrectly stated that the sub-advisory agreements could be terminated at any time and did not disclose the side agreement. This action arises out of EB-5 transactions – an immigration program in which a foreign national invests a specified sum – here 0,000 – creating jobs in the U. The funds are typically invested in limited partnership shares which are securities. Lawler is alleged to have effectuated transactions in EB-5 securities, including recommending one or more EB-5 investment officers to his clients and serving as a liaison. S.; resolved with a consent to a cease and desist order based on Exchange Act Section 15(a) and the payment of disgorgement of ,500 and prejudgment interest and a penalty of ,000). 3-17421 (August 24, 2016) is one of 71 settled proceedings filed by the Commission under its Municipalities Continuing Disclose Cooperation Initiative.