Rosedale Advisory Firm Fined for Role in NCAA Player Referral Bribery Scheme
From the desk of Jim Eccleston at Eccleston Law
The Securities and Exchange Commission (SEC) has finalized a cease-and-desist proceeding against Rosedale, a former SEC-registered investment adviser, for violations of the Investment Advisers Act of 1940. According to the SEC, Rosedale perpetrated a multi-year bribery scheme involving its making undisclosed payments to sports agents and others to steer NCAA athletes toward Rosedale’s advisory services.
From March 2015 through October 2017, Munish Sood, who owned at least 95% of Rosedale and served as its CEO and Chief Investment Officer, orchestrated payments exceeding $96,000 to influence college basketball players to retain Rosedale as their investment adviser once they turned professional. These payments were not disclosed to the athletes before they entered advisory agreements—conduct that violated Sections 206(1), 206(2), 206(4), and Rule 206(4)-3 of the Advisers Act.
Though Rosedale ultimately secured at least five former NCAA athletes as clients through this scheme, the SEC found no evidence of quantifiable harm to those clients or any unjust enrichment by the firm. Accordingly, the SEC believed that a mere fine of $97,523 was an appropriate sanction and deterrence.Eccleston Law LLC represents investors and financial advisors nationwide in securities, employment, transition, regulatory, and disciplinary matters.
Eccleston Law LLC represents investors and financial advisors nationwide in securities, employment, transition, regulatory, and disciplinary matters.
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