SEI INVESTMENTS DISTRIBUTION CO. · SEI INVESTMENTS DISTRIBUTION CO. Section Title Report Summary...

BrokerCheck Report

SEI INVESTMENTS DISTRIBUTION CO.

Section Title

Report Summary

Firm History

CRD# 10690

1

8

Firm Profile 2 - 7

Page(s)

Firm Operations 9 - 25

Disclosure Events 26

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SEI INVESTMENTS DISTRIBUTIONCO.

CRD# 10690

SEC# 8-27897

Main Office Location

ONE FREEDOM VALLEY DRIVEOAKS, PA 19456Regulated by FINRA Philadelphia Office

Mailing Address

ONE FREEDOM VALLEY DRIVEOAKS, PA 19456

Business Telephone Number

610-676-1000

Report Summary for this Firm

This report summary provides an overview of the brokerage firm. Additional information for this firm can be foundin the detailed report.

Disclosure Events

Brokerage firms are required to disclose certaincriminal matters, regulatory actions, civil judicialproceedings and financial matters in which the firm orone of its control affiliates has been involved.

Are there events disclosed about this firm? Yes

The following types of disclosures have beenreported:

Type Count

Regulatory Event 3

Firm Profile

This firm is classified as a corporation.

This firm was formed in Pennsylvania on07/20/1981.

Its fiscal year ends in December.

Firm History

Information relating to the brokerage firm's historysuch as other business names and successions(e.g., mergers, acquisitions) can be found in thedetailed report.

Firm Operations

Is this brokerage firm currently suspended with anyregulator? No

This firm conducts 9 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm has referral or financial arrangements withother brokers or dealers.

This firm is registered with:

• the SEC• 1 Self-Regulatory Organization• 53 U.S. states and territories

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This firm is classified as a corporation.

This firm was formed in Pennsylvania on 07/20/1981.

CRD#

This section provides the brokerage firm's full legal name, "Doing Business As" name, business and mailingaddresses, telephone number, and any alternate name by which the firm conducts business and where such name isused.

Firm Profile

Firm Names and Locations

Its fiscal year ends in December.

SEI INVESTMENTS DISTRIBUTION CO.

SEC#

10690

8-27897

Main Office Location

Mailing Address

Business Telephone Number

Doing business as SEI INVESTMENTS DISTRIBUTION CO.

610-676-1000

Regulated by FINRA Philadelphia Office








This section provides information relating to all direct owners and executive officers of the brokerage firm.

Direct Owners and Executive Officers

Firm Profile

Position

Percentage of Ownership

Is this a public reportingcompany?

Position Start Date

Does this owner direct themanagement or policies ofthe firm?

SEI INVESTMENTS COMPANY

SHAREHOLDER

75% or more

Yes

Domestic Entity

07/1981

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


BARR, KEVIN PATRICK

DIRECTOR, PRESIDENT, CEO

Less than 5%

No

Individual

11/2003

Yes

4704748



Position


Position Start Date

CAMPISI, JENNIFER HICKMAN

CHIEF COMPLIANCE OFFICER, ASST SECRETARY

Less than 5%

Individual

02/2019

5299753








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

No

Position



Position Start Date


CHOU, MAXINE J

TREASURER, CFO, COO

Less than 5%

No

Individual

11/2003

Yes

832004



Position



Position Start Date


DORAN, WILLIAM M

DIRECTOR

Less than 5%

No

Individual

12/2003

Yes

1476724



KLAUDER, PAUL FRANCIS

2474240








Firm Profile

Position



Position Start Date


DIRECTOR

Less than 5%

No

Individual

04/2016

Yes

2474240


Position



Position Start Date


MUNCH, JOHN CHARLES

SECRETARY, GENERAL COUNSEL

Less than 5%

No

Individual

11/2003

No

4739576



Position


Position Start Date


WITHROW, WAYNE MONTGOMERY

DIRECTOR

Less than 5%

Individual

11/2003

Yes

2082355









Firm Profile



No

Yes






This section provides information relating to any indirect owners of the brokerage firm.

Indirect Owners

Firm Profile

No information reported.






Firm History

This section provides information relating to any successions (e.g., mergers, acquisitions) involving the firm.

No information reported.






Firm Operations

RegistrationsThis section provides information about the regulators (Securities and Exchange Commission (SEC), self-regulatoryorganizations (SROs), and U.S. states and territories) with which the brokerage firm is currently registered andlicensed, the date the license became effective, and certain information about the firm's SEC registration.

This firm is currently registered with the SEC, 1 SRO and 53 U.S. states and territories.

SEC Registration Questions

This firm is registered with the SEC as:

A broker-dealer:

A broker-dealer and government securities broker or dealer:

A government securities broker or dealer only:

This firm has ceased activity as a government securities broker or dealer:

Yes

Yes

No

No

Federal Regulator Status Date Effective

SEC Approved 06/25/1982

Self-Regulatory Organization Status Date Effective

FINRA Approved 08/31/1982






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 11/04/1982

Alaska Approved 10/04/1983

Arizona Approved 01/06/1984

Arkansas Approved 07/19/1983

California Approved 08/24/1982

Colorado Approved 02/01/1983

Connecticut Approved 11/12/1982

Delaware Approved 07/19/1982

District of Columbia Approved 11/11/1982

Florida Approved 04/27/1983

Georgia Approved 11/24/1982

Hawaii Approved 08/27/1984

Idaho Approved 06/13/1983

Illinois Approved 09/28/1982

Indiana Approved 10/25/1982

Iowa Approved 07/14/1983

Kansas Approved 10/05/1982

Kentucky Approved 10/19/1982

Louisiana Approved 04/20/1983

Maine Approved 02/14/1984

Maryland Approved 10/15/1982

Massachusetts Approved 07/23/1982

Michigan Approved 02/03/1983

Minnesota Approved 09/09/1982

Mississippi Approved 10/25/1982

Missouri Approved 07/18/1983

Montana Approved 04/25/1983

Nebraska Approved 12/10/1982

Nevada Approved 07/19/1983

New Hampshire Approved 02/02/1983

New Jersey Approved 07/15/1983

New Mexico Approved 10/01/1982

New York Approved 09/01/1982

U.S. States &Territories

Status Date Effective

North Carolina Approved 04/21/1983

North Dakota Approved 09/26/1983

Ohio Approved 02/05/1996

Oklahoma Approved 09/23/1982

Oregon Approved 10/27/1982

Pennsylvania Approved 07/19/1982

Puerto Rico Approved 11/02/1990

Rhode Island Approved 02/01/1983

South Carolina Approved 05/30/1983

South Dakota Approved 08/04/1983

Tennessee Approved 10/20/1982

Texas Approved 07/25/1983

Utah Approved 06/07/1983

Vermont Approved 02/13/1984

Virgin Islands Approved 06/10/2005

Virginia Approved 01/06/1983

Washington Approved 04/20/1983

West Virginia Approved 09/28/1982

Wisconsin Approved 02/24/1983

Wyoming Approved 11/23/1982






Firm Operations

Types of BusinessThis section provides the types of business, including non-securities business, the brokerage firm is engaged in orexpects to be engaged in.

Other Types of Business

This firm does not effect transactions in commodities, commodity futures, or commodity options.This firm does not engage in other non-securities business.

Non-Securities Business Description:

This firm currently conducts 9 types of businesses.

Types of Business

Broker or dealer retailing corporate equity securities over-the-counter

Broker or dealer selling corporate debt securities

Mutual fund underwriter or sponsor

U S. government securities broker

Municipal securities dealer

Municipal securities broker

Put and call broker or dealer or option writer

Non-exchange member arranging for transactions in listed securities by exchange member

Other - 1-SIDCO PROVIDES BROKERAGE AND RESEARCH SERVICES TO INSTITUTIONAL CLIENTS UNDERSOFT DOLLAR ARRANGEMENTS. 2-SIDCO PROVIDES DIRECTED BROKERAGE SERVICES WHICH ENABLEPLAN SPONSORS TO RECAPTURE A PORTION OF COMMISSION EXPENSES. 3-SIDCO ACTS AS ATECHNOLOGY SERVICE PROVIDER TO FACILITATE INSTIT CLIENT TRANSACTIONS IN EQUITIES & FIXEDINCOME SECURITIES & RECEIVES COMPENSATION BASED ON DOLLAR AMOUNT PER TRADE.






Firm Operations

Clearing Arrangements

This firm does not hold or maintain funds or securities or provide clearing services for other broker-dealer(s).

Introducing Arrangements

This firm does refer or introduce customers to other brokers and dealers.

Name: VIRTU AMERICAS LLC

Business Address: ONE LIBERTY PLAZA, 165 BROADWAYNEW YORK, NY 10006

CRD #: 149823

Effective Date: 06/01/2020

Description: SEI INVESTMENTS DISTRIBUTION CO WILL OPERATE UNDER A FULLYDISCLOSED CLEARING AGREEMENT WITH VIRTU AMERICAS LLC

Name: VIRTU AMERICAS LLC

Business Address: ONE LIBERTY PLAZA, 165 BROADWAYNEW YORK, NY 10006

CRD #: 149823


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO") WILL OPERATE UNDERA COMMISSION SHARING AGREEMENT WITH VIRTU AMERIACS LLC INWHICH SIDCO WILL RECEIVE A PORTION OF COMMISSION GENERATEDFROM INSTITUTIONAL CUSTOMERS REFERRED TO THEM.

Name: CANTOR FITZGERALD & CO.

Business Address: 110 E. 59TH STREET, 5TH FLOORNEW YORK, NY 10022

CRD #: 134


Description: SEI INVESTMENTS DISTRIBUTION CO (SIDCO) WILL OPERATE UNDER AFULLY DISCLOSED CLEARING AGREEMENT WITH CANTOR FITZGERALD& CO.

Name: CANTOR FITZGERALD & CO.


CRD #: 134






Firm Operations





Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO") WILL OPERATE UNDERA COMMISSION SHARING AGREEMENT WITH CANTOR FITZGERALD &CO IN WHICH SIDCO WILL RECEIVE A PORTION OF COMMISSIONGENERATED FROM INSTITUTIONAL CUSTOMERS INTRODUCED TOCANTOR FITZGERALD & CO.

Name: INDUSTRIAL AND COMMERCIAL BANK OF CHINA FINANCIAL SERVICESLLC

Business Address: 1633 BROADWAYNEW YORK, NY 10019

CRD #: 131487


Description: SEI INVESTMENTS DISTRIBUTION CO WILL OPERATE UNDER A FULLYDISCLOSED CLEARING AGREEMENT WITH INDUSTRIAL ANDCOMMERCIAL BANK OF CHINA FINANCIAL SERVICES LLC.

Name: JONESTRADING

Business Address: 32133 W. LINDERO CANYON RDSUITE 208WESTLAKE VILLAGE, CA 91361

CRD #: 6888


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO") WILL OPERATE UNDERA COMMISSION SHARING AGREEMENT WITH JONESTRADINGINSTITUTIONAL SERVICES LLC IN WHICH SIDCO WILL RECEIVE APORTION OF COMMISSION GENERATED FROM INSTITUTIONALCUSTOMERS INTRODUCED TO JONESTRADING INSTITUTIONALSERVICES LLC.

Name: MACQUARIE CAPITAL (USA) INC.

Business Address: 125 WEST 55TH STREETLEVEL 22NEW YORK, NY 10019

CRD #: 36368






Firm Operations


This firm does refer or introduce customers to other brokers and dealers.Business Address: 125 WEST 55TH STREETLEVEL 22NEW YORK, NY 10019


Description: SEI INVESTMENTS DISTRIBUTION CO ("SIDCO") WILL OPERATE UNDERA COMMISSION SHARING ARRANGEMENT WITH MACQUARIE CAPITAL(USA) INC. IN WHICH SIDCO WILL RECEIVE A PORTION OF COMMISSIONGENERATED FROM INSTITUTIONAL CUSTOMERS INTRODUCED TOMACQUARIE CAPITAL.

Name: MID ATLANTIC CAPITAL CORPORATION

Business Address: 1251 WATERFRONT PLACE, SUITE 510PITTSBURGH, PA 15222-2435

CRD #: 10674


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO")WILL OPERATE UNDERA FULLY DISCLOSED CLEARING AGREEMENT WITH MID ATLANTICCAPITAL CORP AND NATIONAL FINANCIAL SERVICES WHEREACCOUNTS OF SIDCO ARE INTRODUCED TO NATIONAL FINANCIALTHROUGH MID ATLANTIC CAPITAL.

Name: CITIGROUP GLOBAL MARKETS INC.

Business Address: 390 GREENWICH STREET, 3RD FLOORNEW YORK, NY 10013

CRD #: 7059


Description: SEI INVESTMENTS DISTRIBUTION CO (SIDCO) WILL OPERATE UNDER AFULLY DISCLOSED CLEARING AGREEMENT WITH CITIGROUP GLOBALMARKETS INC.

Name: J.P. MORGAN SECURITIES LLC

Business Address: 383 MADISON AVENUENEW YORK, NY 10179

CRD #: 79


Description: SEI INVESTMENTS DISTRIBUTION CO. WILL OPERATE UNDER ANINTRODUCING BROKER AGREEMENT WITH J.P. MORGAN SECURITIESLLC






Firm Operations



Description: SEI INVESTMENTS DISTRIBUTION CO. WILL OPERATE UNDER ANINTRODUCING BROKER AGREEMENT WITH J.P. MORGAN SECURITIESLLC

Name: INSTINET, LLC

Business Address: 1095 AVENUE OF THE AMERICASNEW YORK, NY 10036

CRD #: 7897


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO") WILL OPERATE UNDERA COMMISSION SHARING AGREEMENT WITH INSTINET, LLC IN WHICHSIDCO WILL RECEIVE A PORTION OF COMMISSION GENERATED FROMINSTITUTIONAL CUSTOMERS INTRODUCED TO INSTINET, LLC.

Name: BOFA SECURITIES, INC.

Business Address: ONE BRYANT PARKNEW YORK, NY 10036

CRD #: 283942


Description: SEI INVESTMENTS DISTRIBUTION CO (SIDCO) WILL OPERATE UNDER AFULLY DISCLOSED INTRODUCTION AGREEMENT WITH BOFASECURITIES, INC. (FORMERLY MERRILL LYNCH, PIERCE, FENNER &SMITH INCORPORATED) FOR INSTITUTIONAL ACCOUNTS.(ARRANGEMENT WAS FORMERLY WITH SMITH NEW COURT INC.)

Name: HSBC SECURITIES (USA) INC.

Business Address: 452 FIFTH AVENUENEW YORK, NY 10018

CRD #: 19585


Description: SEI INVESTMENTS DISTRIBUTION CO (SIDCO) WILL OPERATE UNDER ACOMMISSION SHARING AGREEMENT WITH HSBC EFFECTIVE 05/01/2007IN WHICH SIDCO WILL RECEIVE A PORTION OF COMMISSIONGENERATED FROM INSTITUTIONAL CUSTOMERS INTRODUCED BYSIDCO TO HSBC.






Firm Operations



Name: BOFA SECURITIES, INC.

Business Address: ONE BRYANT PARKNEW YORK, NY 10036

CRD #: 283942


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDCO") WILL OPERATE UNDERA FULLY DISCLOSED CLEARING AGREEMENT WITH BOFA SECURITIES,INC. (FORMERLY MERRILL LYNCH, PIERCE, FENNER & SMITHINCORPORATED) (BROADCORT CAPITAL CORPORATION DIVISION).

Name: PERSHING LLC

Business Address: ONE PERSHING PLAZAJERSEY CITY, NJ 07339

CRD #: 7560


Description: SEI INVESTMENTS DISTRIBUTION CO. ("SIDC") WILL OPERATE UNDER AFULLY DISCLOSED CLEARING AGREEMENT WITH PERSHING LLC.






Firm Operations

Industry Arrangements

This firm does have books or records maintained by a third party.

This firm does not have accounts, funds, or securities maintained by a third party.

This firm does not have customer accounts, funds, or securities maintained by a third party.

This firm does not have individuals who control its management or policies through agreement.

This firm does not have individuals who wholly or partly finance the firm's business.

Control Persons/Financing

Name: SMARSH, INC.

Business Address: 921 SW WASHINGTON ST, STE 540PORTLAND, OR 97205


Description: SMARSH, INC. PROVIDES ELECTRONIC COMMUNICATION ARCHIVINGFOR EMAIL AND INSTANT MESSAGES FROM REPRESENTATIVES OF SEIINVESTMENTS DISTRIBUTION CO PURSUANT TO SEC RULE 17A-4EFFECTIVE 5/1/2013.

Name: IRON MOUNTAIN INFORMATION MANAGEMENT, INC.

Business Address: 745 ATLANTIC AVENUEBOSTON, MA 02111


Description: SEI INVESTMENTS DISTRIBUTION CO. WILL MAINTAIN AND PRESERVESOME OF ITS BOOKS AND RECORDS PURSUANT TO SEC RULES 17A-3AND 17A-4 IN PAPER FORMAT AT IRON MOUNTAIN INFORMATIONMANAGEMENT, INC.






Firm Operations

Organization AffiliatesThis section provides information on control relationships the firm has with other firms in the securities, investmentadvisory, or banking business.

This firm is, directly or indirectly:

· in control of· controlled by· or under common control withthe following partnerships, corporations, or other organizations engaged in the securities or investmentadvisory business.

Yes

No

No

02/23/2017


SEI TRUST COMPANY is under common control with the firm.

SEI TRUST COMPANY IS A WHOLLY-OWNED SUBSIDIARY OF SEIINVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

No

02/22/2017


SEI INVESTMENTS COMPANY controls the firm.

SEI INVESTMENTS COMPANY OWNS SEI INVESTMENTS DISTRIBUTION CODescription:



Country:

Foreign Entity:

Effective Date:

Business Address:

ELIZABETH HOUSE LES RUETTES BRAYES1ST AND 2ND FLOORSST. PETER PORT, GUERNSEY GY1 1EW GK

SEI INVESTMENTS - GUERNSEY LIMITED is under common control with the firm.

Business Address:






Firm Operations

Organization Affiliates (continued)

No

Yes

GUERNSEY

Yes

12/02/2016

ELIZABETH HOUSE LES RUETTES BRAYES1ST AND 2ND FLOORSST. PETER PORT, GUERNSEY GY1 1EW GK

SEI INVESTMENTS - GUERNSEY LIMITED IS A SUBSIDIARY OF SEIEUROPEAN SERVICES LIMITED, WHICH IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

No

12/02/2016

3521 SILVERSIDE ROAD, CONCORD PLAZAQUILLEN BUILDING, SUITE 2G1WILMINGTON, DE 19810

SEI INVESTMENTS GLOBAL FUNDS SERVICES is under common control with the firm.

SEI INVESTMENTS GLOBAL FUNDS SERVICES IS A SUBSIDIARY OF SIMCSUBSIDIARY, LLC, WHICH IS A SUBSIDIARY OF SEI INVESTMENTSMANAGEMENT CORPORATION, WHICH IS A SUBSIDIARY OF SIMCHOLDINGS, LLC, WHICH IS A WHOLLY-OWNED SUBSIDIARY OF SEIINVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

12/02/2016


SEI INSTITUTIONAL TRANSFER AGENT, INC. is under common control with the firm.

Effective Date:

Business Address:






Firm Operations


No

Yes

No

SEI INSTITUTIONAL TRANSFER AGENT, INC. IS A SUBSIDIARY OF SEIINVESTMENTS MANAGEMENT CORPORATION, WHICH IS A SUBSIDIARY OFSEI SIMC HOLDINGS, LLC, WHICH IS A WHOLLY-OWNED SUBSIDIARY OF SEIINVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Yes

Yes

CANADA

Yes

06/26/2017

130 KING STREET WESTSUITE 2810TORONTO, CANADA M5X 1E3

SEI INVESTMENTS CANADA COMPANY is under common control with the firm.

SEI INVESTMENTS CANADA COMPANY IS OWNED BY SEI ADVANCEDCAPITAL MANAGEMENT, INC. AND SEI PRIMUS HOLDING CORPORATION,WHICH ARE WHOLLY-OWNED SUBSIDIARIES OF SEI INVESTMENTSCOMPANY AND UNDER COMMON OWNERSHIP WITH APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

IRELAND

Yes

02/22/2017

UPPER HATCH STREETSTYNE HOUSEDUBLIN 2, IRELAND

SEI INVESTMENTS DEPOSITORY & CUSTODIAL SERVICES (IRELAND) LIMITED is under common control withthe firm.



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


No

SEI INVESTMENTS DEPOSITORY & CUSTODIAL SERVICES (IRELAND)LIMITED IS A SUBSIDIARY OF SEI INVESTMENTS GLOBAL, LIMITED, WHICHIS A SUBSIDIARY OF SEI GLOBAL INVESTMENTS CORPORATION, WHICH ISA WHOLLY-OWNED SUBSIDIARY OF SEI INVESTMENTS COMPANY ANDUNDER COMMON OWNERSHIP WITH APPLICANT.

Description:


No

Yes

IRELAND

Yes

12/02/2016


SEI INVESTMENTS - GLOBAL FUND SERVICES LIMITED is under common control with the firm.

SEI INVESTMENTS - GLOBAL FUND SERVICES LIMITED IS A SUBSIDIARY OFSEI INVESTMENTS GLOBAL LIMITED, WHICH IS A SUBSIDIARY OF SEIGLOBAL INVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNEDSUBSIDIARY OF SEI INVESTMENTS COMPANY AND UNDER COMMONOWNERSHIP WITH APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

IRELAND

Yes

12/02/2016


SEI INVESTMENTS GLOBAL, LIMITED is under common control with the firm.

SEI INVESTMENTS GLOBAL LIMITED IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations

Organization Affiliates (continued)SEI INVESTMENTS GLOBAL LIMITED IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

No

Yes

SOUTH AFRICA

Yes

12/02/2016

3 MELROSE BOULEVARD1ST FLOOR, MELROSE ARCH, 2196JOHANNESBURG, SOUTH AFRICA

SEI INVESTMENTS (SOUTH AFRICA) (PTY) LIMITED is under common control with the firm.

SEI INVESTMENTS (SOUTH AFRICA) LIMITED IS A SUBSIDIARY OF SEIGLOBAL HOLDINGS (CAYMAN) INC., WHICH IS A SUBSIDIARY OF SEIGLOBAL INVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNEDSUBSIDIARY OF SEI INVESTMENTS COMPANY AND UNDER COMMONOWNERSHIP WITH APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

Yes

CAYMAN ISLANDS

Yes

12/02/2016

SOUTH CHURCH STREETPO BOX 30464 HARBOUR PLACEGRAND CAYMAN, CAYMAN ISLANDS

SEI INVESTMENTS GLOBAL (CAYMAN), LIMITED is under common control with the firm.

SEI INVESTMENTS GLOBAL (CAYMAN) LIMITED IS A SUBSIDIARY OF SEIGLOBAL INVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNEDSUBSIDIARY OF SEI INVESTMENTS COMPANY AND UNDER COMMONOWNERSHIP WITH APPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

14-18 FINSBURY SQUAREALPHABETA 1ST FLOORLONDON, UNITED KINGDOM EC2A 1BR

SEI GLOBAL NOMINEE LIMITED is under common control with the firm.

Business Address:






Firm Operations


No

Yes

UNITED KINGDOM

Yes

12/02/2016

14-18 FINSBURY SQUAREALPHABETA 1ST FLOORLONDON, UNITED KINGDOM EC2A 1BR

SEI GLOBAL NOMINEE LIMITED IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

Yes

HONG KONG

Yes

12/02/2016

3 JACKSON ROADTHE HONG KONG CLUB BUILDING, SUITE 904CENTRAL, HONG KONG

SEI INVESTMENTS (ASIA) LIMITED is under common control with the firm.

SEI INVESTMENTS (ASIA) LIMITED IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

No

12/02/2016


LSV ASSET MANAGEMENT is under common control with the firm.

Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


Yes

No

A PERCENTAGE OF LSV ASSET MANAGEMENT IS OWNED BY SEI FUNDS,INC. WHICH IS A WHOLLY-OWNED SUBSIDIARY OF SEI INVESTMENTSCOMPANY AND UNDER COMMON OWNERSHIP WITH APPLICANT.

Description:



No

Yes

No

12/02/2016


SEI PRIVATE TRUST COMPANY is under common control with the firm.

SEI PRIVATE TRUST COMPANY IS A WHOLLY-OWNED SUBSIDIARY OF SEIINVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

Yes

No

UNITED KINGDOM

Yes

11/26/2013

14-18 FINSBURY SQUAREALPHABETA 1ST FLOORLONDON, UK EC2A 1BR

SEI INVESTMENTS (EUROPE) LIMITED is under common control with the firm.

SEI INVESTMENTS (EUROPE) LIMITED IS A SUBSIDIARY OF SEI GLOBALINVESTMENTS CORPORATION, WHICH IS A WHOLLY-OWNED SUBSIDIARYOF SEI INVESTMENTS COMPANY AND UNDER COMMON OWNERSHIP WITHAPPLICANT.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:






Firm Operations


Yes

No

No

08/31/1982


105146

SEI INVESTMENTS MANAGEMENT CORP is under common control with the firm.

SEI INVESTMENTS MANAGEMENT CORPORATION (SIMC) IS A WHOLLY-OWNED SUBSIDIARY OF SIMC HOLDINGS, LLC, WHICH IS A WHOLLY-OWNED SUBSIDIARY OF SEI INVESTMENTS COMPANY AND UNDERCOMMON OWNERSHIP WITH APPLICANT. SIMC IS AN SEC REGISTEREDINVESTMENT ADVISOR.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

This firm is not directly or indirectly, controlled by the following:

· bank holding company· national bank· state member bank of the Federal Reserve System· state non-member bank· savings bank or association· credit union· or foreign bank






Disclosure Events

All firms registered to sell securities or provide investment advice are required to disclose regulatory actions, criminal orcivil judicial proceedings, and certain financial matters in which the firm or one of its control affiliates has been involved.For your convenience, below is a matrix of the number and status of disclosure events involving this brokerage firm orone of its control affiliates. Further information regarding these events can be found in the subsequent pages of thisreport.

Final On AppealPending

Regulatory Event 0 3 0






Disclosure Event Details

What you should know about reported disclosure events:

1. BrokerCheck provides details for any disclosure event that was reported in CRD. It also includessummary information regarding FINRA arbitration awards in cases where the brokerage firm wasnamed as a respondent.

2. Certain thresholds must be met before an event is reported to CRD, for example: o A law enforcement agency must file formal charges before a brokerage firm is required to disclose a

particular criminal event.3. Disclosure events in BrokerCheck reports come from different sources:

o Disclosure events for this brokerage firm were reported by the firm and/or regulators. When the firmand a regulator report information for the same event, both versions of the event will appear in theBrokerCheck report. The different versions will be separated by a solid line with the reporting sourcelabeled.

4. There are different statuses and dispositions for disclosure events: o A disclosure event may have a status of pending, on appeal, or final.

§ A "pending" event involves allegations that have not been proven or formally adjudicated.§ An event that is "on appeal" involves allegations that have been adjudicated but are currently

being appealed.§ A "final" event has been concluded and its resolution is not subject to change.

o A final event generally has a disposition of adjudicated, settled or otherwise resolved.§ An "adjudicated" matter includes a disposition by (1) a court of law in a criminal or civil matter,

or (2) an administrative panel in an action brought by a regulator that is contested by the partycharged with some alleged wrongdoing.

§ A "settled" matter generally involves an agreement by the parties to resolve the matter.Please note that firms may choose to settle customer disputes or regulatory matters forbusiness or other reasons.

§ A "resolved" matter usually involves no payment to the customer and no finding ofwrongdoing on the part of the individual broker. Such matters generally involve customerdisputes.

5. You may wish to contact the brokerage firm to obtain further information regarding any of thedisclosure events contained in this BrokerCheck report.

Regulatory - Final

This type of disclosure event involves (1) a final, formal proceeding initiated by a regulatory authority (e.g., a statesecurities agency, self-regulatory organization, federal regulator such as the U.S. Securities and Exchange Commission,foreign financial regulatory body) for a violation of investment-related rules or regulations; or (2) a revocation orsuspension of the authority of a brokerage firm or its control affiliate to act as an attorney, accountant or federalcontractor.

Disclosure 1 of 3

Reporting Source: Regulator

Allegations: SECURITIES EXCHANGE ACT RULE 17A-4, FINRA RULES 2010, 4511: THEFIRM FAILED TO MAINTAIN AND PRESERVE CERTAIN BUSINESS-RELATEDELECTRONIC COMMUNICATIONS, EMAILS THAT WERE SENT TO AND FROMSEVERAL OF ITS REGISTERED REPRESENTATIVES. AS A RESULT OF ANINTERNAL SOFTWARE MALFUNCTION, THE EMAIL FOR THOSEREPRESENTATIVES, WHICH WAS TRANSMITTED THROUGH A DIFFERENTEXCHANGE SERVER THAN THE ONE USED FOR THE FIRM'S OTHERPERSONNEL, WAS NOT DELIVERED TO ITS THIRD-PARTY ARCHIVALSYSTEM. ALTHOUGH THE FIRM WAS ABLE TO RECOVER SOME OF THEBUSINESS-RELATED EMAILS SENT OR RECEIVED BY THEREPRESENTATIVES DURING THAT PERIOD, IT WAS UNABLE TO RECOVERMOST OF THOSE MESSAGES. IN ADDITION, THE FIRM FAILED TO MAINTAINAND PRESERVE CERTAIN BUSINESS-RELATED INSTANT MESSAGESTRANSMITTED BETWEEN THE FIRM'S EMPLOYEES AND/OR TRANSMITTEDBETWEEN THE FIRM'S EMPLOYEES AND EMPLOYEES OF ITS AFFILIATES.THE FIRM PROHIBITED USE OF INSTANT MESSAGING WITH EXTERNALPARTIES. AS A RESULT OF ANOTHER INTERNAL SOFTWARE MALFUNCTION,THE FIRM FAILED TO ARCHIVE THE INSTANT MESSAGES. THE FIRM WASSUBSEQUENTLY UNABLE TO RECOVER ALL OF THE INSTANT MESSAGESTRANSMITTED DURING THE PERIOD. AT THE TIMES RELEVANT, EXCHANGEACT RULE 17A-4 REQUIRED THAT MEMBER FIRMS MAINTAIN ANDPRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS (THE FIRSTTWO YEARS IN AN EASILY ACCESSIBLE PLACE), ELECTRONICCOMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER. IN NOTICES TO MEMBERS, FINRA PROVIDED MEMBER FIRMSINFORMATION AND GUIDANCE REGARDING THEIR SUPERVISORY ANDRECORDKEEPING OBLIGATIONS AS TO ELECTRONIC COMMUNICATIONS,INCLUDING EMAIL AND INSTANT MESSAGING. FINRA MEMBERS AREREQUIRED TO COMPLY WITH EXCHANGE ACT RULE 17A-4.

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Other Sanction(s)/ReliefSought:

N/A

Date Initiated: 04/12/2013

Docket/Case Number: 2012030611301

Principal Product Type: No Product

Other Product Type(s):

Allegations: SECURITIES EXCHANGE ACT RULE 17A-4, FINRA RULES 2010, 4511: THEFIRM FAILED TO MAINTAIN AND PRESERVE CERTAIN BUSINESS-RELATEDELECTRONIC COMMUNICATIONS, EMAILS THAT WERE SENT TO AND FROMSEVERAL OF ITS REGISTERED REPRESENTATIVES. AS A RESULT OF ANINTERNAL SOFTWARE MALFUNCTION, THE EMAIL FOR THOSEREPRESENTATIVES, WHICH WAS TRANSMITTED THROUGH A DIFFERENTEXCHANGE SERVER THAN THE ONE USED FOR THE FIRM'S OTHERPERSONNEL, WAS NOT DELIVERED TO ITS THIRD-PARTY ARCHIVALSYSTEM. ALTHOUGH THE FIRM WAS ABLE TO RECOVER SOME OF THEBUSINESS-RELATED EMAILS SENT OR RECEIVED BY THEREPRESENTATIVES DURING THAT PERIOD, IT WAS UNABLE TO RECOVERMOST OF THOSE MESSAGES. IN ADDITION, THE FIRM FAILED TO MAINTAINAND PRESERVE CERTAIN BUSINESS-RELATED INSTANT MESSAGESTRANSMITTED BETWEEN THE FIRM'S EMPLOYEES AND/OR TRANSMITTEDBETWEEN THE FIRM'S EMPLOYEES AND EMPLOYEES OF ITS AFFILIATES.THE FIRM PROHIBITED USE OF INSTANT MESSAGING WITH EXTERNALPARTIES. AS A RESULT OF ANOTHER INTERNAL SOFTWARE MALFUNCTION,THE FIRM FAILED TO ARCHIVE THE INSTANT MESSAGES. THE FIRM WASSUBSEQUENTLY UNABLE TO RECOVER ALL OF THE INSTANT MESSAGESTRANSMITTED DURING THE PERIOD. AT THE TIMES RELEVANT, EXCHANGEACT RULE 17A-4 REQUIRED THAT MEMBER FIRMS MAINTAIN ANDPRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS (THE FIRSTTWO YEARS IN AN EASILY ACCESSIBLE PLACE), ELECTRONICCOMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER. IN NOTICES TO MEMBERS, FINRA PROVIDED MEMBER FIRMSINFORMATION AND GUIDANCE REGARDING THEIR SUPERVISORY ANDRECORDKEEPING OBLIGATIONS AS TO ELECTRONIC COMMUNICATIONS,INCLUDING EMAIL AND INSTANT MESSAGING. FINRA MEMBERS AREREQUIRED TO COMPLY WITH EXCHANGE ACT RULE 17A-4.

Resolution Date: 04/12/2013

Resolution:

Does the order constitute afinal order based onviolations of any laws orregulations that prohibitfraudulent, manipulative, ordeceptive conduct?

No

Acceptance, Waiver & Consent(AWC)





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2012030611301


Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $100,000.

FINE PAID IN FULL ON APRIL 22, 2013


No

Sanctions Ordered: CensureMonetary/Fine $100,000.00

iReporting Source: Firm

Allegations: SECURITIES EXCHANGE ACT RULE 17A-4, FINRA RULES 2010, 4511: THEFIRM FAILED TO MAINTAIN AND PRESERVE CERTAIN BUSINESS-RELATEDELECTRONIC COMMUNICATIONS, EMAILS THAT WERE SENT TO AND FROMSEVERAL OF ITS REGISTERED REPRESENTATIVES. AS A RESULT OF ANINTERNAL SOFTWARE MALFUNCTION, THE EMAIL FOR THOSEREPRESENTATIVES, WHICH WAS TRANSMITTED THROUGH A DIFFERENTEXCHANGE SERVER THAN THE ONE USED FOR THE FIRM'S OTHERPERSONNEL, WAS NOT DELIVERED TO ITS THIRD-PARTY ARCHIVALSYSTEM. ALTHOUGH THE FIRM WAS ABLE TO RECOVER SOME OF THEBUSINESS-RELATED EMAILS SENT OR RECEIVED BY THEREPRESENTATIVES DURING THAT PERIOD, IT WAS UNABLE TO RECOVERMOST OF THOSE MESSAGES. IN ADDITION, THE FIRM FAILED TO MAINTAINAND PRESERVE CERTAIN BUSINESS-RELATED INSTANT MESSAGESTRANSMITTED BETWEEN THE FIRM'S EMPLOYEES AND/OR TRANSMITTEDBETWEEN THE FIRM'S EMPLOYEES AND EMPLOYEES OF ITS AFFILIATES.THE FIRM PROHIBITED USE OF INSTANT MESSAGING WITH EXTERNALPARTIES. AS A RESULT OF ANOTHER INTERNAL SOFTWARE MALFUNCTION,THE FIRM FAILED TO ARCHIVE THE INSTANT MESSAGES. THE FIRM WASSUBSEQUENTLY UNABLE TO RECOVER ALL OF THE INSTANT MESSAGESTRANSMITTED DURING THE PERIOD. AT THE TIMES RELEVANT, EXCHANGEACT RULE 17A-4 REQUIRED THAT MEMBER FIRMS MAINTAIN ANDPRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS (THE FIRSTTWO YEARS IN AN EASILY ACCESSIBLE PLACE), ELECTRONICCOMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER.







Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure


MONETARY FINE $100,000.00


Docket/Case Number: AWC NO. 2012030611301



SECURITIES EXCHANGE ACT RULE 17A-4, FINRA RULES 2010, 4511: THEFIRM FAILED TO MAINTAIN AND PRESERVE CERTAIN BUSINESS-RELATEDELECTRONIC COMMUNICATIONS, EMAILS THAT WERE SENT TO AND FROMSEVERAL OF ITS REGISTERED REPRESENTATIVES. AS A RESULT OF ANINTERNAL SOFTWARE MALFUNCTION, THE EMAIL FOR THOSEREPRESENTATIVES, WHICH WAS TRANSMITTED THROUGH A DIFFERENTEXCHANGE SERVER THAN THE ONE USED FOR THE FIRM'S OTHERPERSONNEL, WAS NOT DELIVERED TO ITS THIRD-PARTY ARCHIVALSYSTEM. ALTHOUGH THE FIRM WAS ABLE TO RECOVER SOME OF THEBUSINESS-RELATED EMAILS SENT OR RECEIVED BY THEREPRESENTATIVES DURING THAT PERIOD, IT WAS UNABLE TO RECOVERMOST OF THOSE MESSAGES. IN ADDITION, THE FIRM FAILED TO MAINTAINAND PRESERVE CERTAIN BUSINESS-RELATED INSTANT MESSAGESTRANSMITTED BETWEEN THE FIRM'S EMPLOYEES AND/OR TRANSMITTEDBETWEEN THE FIRM'S EMPLOYEES AND EMPLOYEES OF ITS AFFILIATES.THE FIRM PROHIBITED USE OF INSTANT MESSAGING WITH EXTERNALPARTIES. AS A RESULT OF ANOTHER INTERNAL SOFTWARE MALFUNCTION,THE FIRM FAILED TO ARCHIVE THE INSTANT MESSAGES. THE FIRM WASSUBSEQUENTLY UNABLE TO RECOVER ALL OF THE INSTANT MESSAGESTRANSMITTED DURING THE PERIOD. AT THE TIMES RELEVANT, EXCHANGEACT RULE 17A-4 REQUIRED THAT MEMBER FIRMS MAINTAIN ANDPRESERVE, FOR A PERIOD OF NOT LESS THAN THREE YEARS (THE FIRSTTWO YEARS IN AN EASILY ACCESSIBLE PLACE), ELECTRONICCOMMUNICATIONS RELATING TO THE FIRM'S BUSINESS AS A BROKER-DEALER.


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDING, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $100,000. THE FINE WASPAID IN FULL ON APRIL 22,2013.

Firm Statement THE FIRM WAS CENSURED AND FINED $100,000. THE FINE WAS PAID INFULL ON APRIL 22,2013.



Disclosure 2 of 3

i


Allegations: FINRA RULE 2010, NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B),2210(D)(2)(B), 3010: THE FIRM REVIEWED AND APPROVED ADVERTISINGAND SALES LITERATURE FOR EXCHANGE TRADED FUNDS (ETFS)OFFERED BY ONE OF THE WORLD'S LARGEST ETF PROVIDERS THAT DIDNOT COMPLY WITH THE CONTENT STANDARDS OF NASD RULE 2210.DURING THE PERIOD JANUARY 1, 2005, THROUGH OCTOBER 20, 2009, THEFIRM WAS THE DISTRIBUTOR OF THE ETFS. THE ETFS' INVESTMENTADVISER (A COMPANY NOT AFFILIATED WITH THE FIRM) PREPARED THEADVERTISING AND SALES LITERATURE AND SENT IT TO THE FIRM. AS THEDISTRIBUTOR OF THE ETFS, THE FIRM WAS RESPONSIBLE FORREVIEWING AND APPROVING THESE MATERIALS IN ACCORDANCE WITHTHE REQUIREMENTS OF NASD RULE 2210. ACCORDINGLY, REGISTEREDPRINCIPALS OF THE FIRM REVIEWED AND APPROVED ALL THE ETFADVERTISING AND SALES LITERATURE PRIOR TO USE. THE WEBSITES,FUND FACT SHEETS, AND OTHER PIECES OF ADVERTISING AND SALESLITERATURE FOR THE ETFS THAT THE FIRM REVIEWED AND APPROVEDINCLUDED PERFORMANCE HISTORY FOR THE ETFS' CORRESPONDINGINDEXES. IN NUMEROUS INSTANCES, THE INDEX PROVIDERS CREATEDTHE CORRESPONDING INDEXES SHORTLY BEFORE THE INVESTMENTADVISER LAUNCHED THE ETFS AND THE FIRM BEGAN DISTRIBUTINGTHEM. THE ADVERTISING AND SALES LITERATURE DEPICTED THEPERFORMANCE HISTORY OF CERTAIN INDEXES WITHOUT DISCLOSINGTHAT IT INCLUDED BACK-TESTED INDEX PERFORMANCE, WHICH WASCALCULATED BY THE INDEX PROVIDERS USING HISTORICAL DATA FROMTIME PERIODS PREDATING THE INDEX CREATION DATE. IN ALL INSTANCESWHERE ETF ADVERTISING OR SALES LITERATURE CONTAINED BACK-TESTED INDEX PERFORMANCE, NEITHER THAT FACT NOR THE FACT THATTHE INDEX PROVIDER CALCULATED THE BACK-TESTED INDEXPERFORMANCE WAS DISCLOSED. THE FIRM REVIEWED AND APPROVEDNUMEROUS WEB-PAGES, FUND FACT SHEETS, AND OTHER PIECES OFADVERTISING AND SALES LITERATURE FOR THE ETFS THAT CONTAINEDUNDISCLOSED AND UN-SOURCED BACK-TESTED INDEX PERFORMANCEFOR OVER FOUR YEARS AND NINE MONTHS; BUT THEREAFTER, THE FIRMHAD REMOVED ALL INSTANCES OF BACK-TESTED INDEX PERFORMANCEFROM ALL OF THE ETF ADVERTISING AND SALES LITERATURE. THEUNDISCLOSED INCLUSION OF BACK-TESTED INDEX PERFORMANCEHISTORY WAS UNWARRANTED BECAUSE IT PURPORTED TO INDICATETHAT THE INDEX HAD A PERFORMANCE HISTORY THAT WAS LONGERTHAN THE ACTUAL EXISTENCE OF THE INDEX. MOREOVER, THEINCLUSION OF UNDISCLOSED BACK-TESTED INDEX PERFORMANCEHISTORY AND THE FAILURE TO IDENTIFY THE SOURCE OF THAT BACK-TESTED INDEX PERFORMANCE HISTORY DID NOT PROVIDE POTENTIALINVESTORS A SOUND BASIS FOR EVALUATING THE INDEX PERFORMANCEHISTORY PRESENTED IN THE ETF ADVERTISING AND SALES LITERATURE.THE FIRM'S REGISTERED PRINCIPALS REVIEWED AND APPROVED SEVENPRESENTATIONS RELATING TO CERTAIN HEDGE FUNDS AND PRIVATEEQUITY FUNDS THAT DID NOT COMPLY WITH THE CONTENT STANDARDSOF NASD RULE 2210. THE FIRM ACTED AS THE DISTRIBUTOR ORPLACEMENT AGENT FOR THE FUNDS, AND FOUR OF THE SEVENPRESENTATIONS WERE PREPARED AND/OR PRESENTED BY AT LEAST ONEPERSON REGISTERED WITH THE FIRM. THE FIRM FAILED TO IMPLEMENTEFFECTIVE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE CONTENT STANDARDS OF NASD RULE2210. THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.THE FIRM'S PROCEDURES FAILED TO CAUSE THE REGISTEREDPRINCIPALS REVIEWING HEDGE FUND COMMUNICATIONS TO REVIEWSUCH COMMUNICATIONS FOR COMPLIANCE WITH CONTENT STANDARDS.THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.







FINRA RULE 2010, NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B),2210(D)(2)(B), 3010: THE FIRM REVIEWED AND APPROVED ADVERTISINGAND SALES LITERATURE FOR EXCHANGE TRADED FUNDS (ETFS)OFFERED BY ONE OF THE WORLD'S LARGEST ETF PROVIDERS THAT DIDNOT COMPLY WITH THE CONTENT STANDARDS OF NASD RULE 2210.DURING THE PERIOD JANUARY 1, 2005, THROUGH OCTOBER 20, 2009, THEFIRM WAS THE DISTRIBUTOR OF THE ETFS. THE ETFS' INVESTMENTADVISER (A COMPANY NOT AFFILIATED WITH THE FIRM) PREPARED THEADVERTISING AND SALES LITERATURE AND SENT IT TO THE FIRM. AS THEDISTRIBUTOR OF THE ETFS, THE FIRM WAS RESPONSIBLE FORREVIEWING AND APPROVING THESE MATERIALS IN ACCORDANCE WITHTHE REQUIREMENTS OF NASD RULE 2210. ACCORDINGLY, REGISTEREDPRINCIPALS OF THE FIRM REVIEWED AND APPROVED ALL THE ETFADVERTISING AND SALES LITERATURE PRIOR TO USE. THE WEBSITES,FUND FACT SHEETS, AND OTHER PIECES OF ADVERTISING AND SALESLITERATURE FOR THE ETFS THAT THE FIRM REVIEWED AND APPROVEDINCLUDED PERFORMANCE HISTORY FOR THE ETFS' CORRESPONDINGINDEXES. IN NUMEROUS INSTANCES, THE INDEX PROVIDERS CREATEDTHE CORRESPONDING INDEXES SHORTLY BEFORE THE INVESTMENTADVISER LAUNCHED THE ETFS AND THE FIRM BEGAN DISTRIBUTINGTHEM. THE ADVERTISING AND SALES LITERATURE DEPICTED THEPERFORMANCE HISTORY OF CERTAIN INDEXES WITHOUT DISCLOSINGTHAT IT INCLUDED BACK-TESTED INDEX PERFORMANCE, WHICH WASCALCULATED BY THE INDEX PROVIDERS USING HISTORICAL DATA FROMTIME PERIODS PREDATING THE INDEX CREATION DATE. IN ALL INSTANCESWHERE ETF ADVERTISING OR SALES LITERATURE CONTAINED BACK-TESTED INDEX PERFORMANCE, NEITHER THAT FACT NOR THE FACT THATTHE INDEX PROVIDER CALCULATED THE BACK-TESTED INDEXPERFORMANCE WAS DISCLOSED. THE FIRM REVIEWED AND APPROVEDNUMEROUS WEB-PAGES, FUND FACT SHEETS, AND OTHER PIECES OFADVERTISING AND SALES LITERATURE FOR THE ETFS THAT CONTAINEDUNDISCLOSED AND UN-SOURCED BACK-TESTED INDEX PERFORMANCEFOR OVER FOUR YEARS AND NINE MONTHS; BUT THEREAFTER, THE FIRMHAD REMOVED ALL INSTANCES OF BACK-TESTED INDEX PERFORMANCEFROM ALL OF THE ETF ADVERTISING AND SALES LITERATURE. THEUNDISCLOSED INCLUSION OF BACK-TESTED INDEX PERFORMANCEHISTORY WAS UNWARRANTED BECAUSE IT PURPORTED TO INDICATETHAT THE INDEX HAD A PERFORMANCE HISTORY THAT WAS LONGERTHAN THE ACTUAL EXISTENCE OF THE INDEX. MOREOVER, THEINCLUSION OF UNDISCLOSED BACK-TESTED INDEX PERFORMANCEHISTORY AND THE FAILURE TO IDENTIFY THE SOURCE OF THAT BACK-TESTED INDEX PERFORMANCE HISTORY DID NOT PROVIDE POTENTIALINVESTORS A SOUND BASIS FOR EVALUATING THE INDEX PERFORMANCEHISTORY PRESENTED IN THE ETF ADVERTISING AND SALES LITERATURE.THE FIRM'S REGISTERED PRINCIPALS REVIEWED AND APPROVED SEVENPRESENTATIONS RELATING TO CERTAIN HEDGE FUNDS AND PRIVATEEQUITY FUNDS THAT DID NOT COMPLY WITH THE CONTENT STANDARDSOF NASD RULE 2210. THE FIRM ACTED AS THE DISTRIBUTOR ORPLACEMENT AGENT FOR THE FUNDS, AND FOUR OF THE SEVENPRESENTATIONS WERE PREPARED AND/OR PRESENTED BY AT LEAST ONEPERSON REGISTERED WITH THE FIRM. THE FIRM FAILED TO IMPLEMENTEFFECTIVE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE CONTENT STANDARDS OF NASD RULE2210. THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.THE FIRM'S PROCEDURES FAILED TO CAUSE THE REGISTEREDPRINCIPALS REVIEWING HEDGE FUND COMMUNICATIONS TO REVIEWSUCH COMMUNICATIONS FOR COMPLIANCE WITH CONTENT STANDARDS.THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.






Initiated By: FINRA


Other


N/A


Docket/Case Number: 2009018186201

Principal Product Type: Other

Other Product Type(s): EXCHANGE TRADED FUNDS



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE THE FIRM IS CENSURED AND FINED $225,000. FINE PAID INFULL ON MARCH 16, 2012.


No




Allegations: FINRA RULE 2010, NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B),2210(D)(2)(B), 3010: THE FIRM REVIEWED AND APPROVED ADVERTISINGAND SALES LITERATURE FOR EXCHANGE TRADED FUNDS (ETFS)OFFERED BY ONE OF THE WORLD'S LARGEST ETF PROVIDERS THAT DIDNOT COMPLY WITH THE CONTENT STANDARDS OF NASD RULE 2210.DURING THE PERIOD JANUARY 1, 2005, THROUGH OCTOBER 20, 2009, THEFIRM WAS THE DISTRIBUTOR OF THE ETFS. THE ETFS' INVESTMENTADVISER (A COMPANY NOT AFFILIATED WITH THE FIRM) PREPARED THEADVERTISING AND SALES LITERATURE AND SENT IT TO THE FIRM. AS THEDISTRIBUTOR OF THE ETFS, THE FIRM WAS RESPONSIBLE FORREVIEWING AND APPROVING THESE MATERIALS IN ACCORDANCE WITHTHE REQUIREMENTS OF NASD RULE 2210. ACCORDINGLY, REGISTEREDPRINCIPALS OF THE FIRM REVIEWED AND APPROVED ALL THE ETFADVERTISING AND SALES LITERATURE PRIOR TO USE. THE WEBSITES,FUND FACT SHEETS, AND OTHER PIECES OF ADVERTISING AND SALESLITERATURE FOR THE ETFS THAT THE FIRM REVIEWED AND APPROVEDINCLUDED PERFORMANCE HISTORY FOR THE ETFS' CORRESPONDINGINDEXES. IN NUMEROUS INSTANCES, THE INDEX PROVIDERS CREATEDTHE CORRESPONDING INDEXES SHORTLY BEFORE THE INVESTMENTADVISER LAUNCHED THE ETFS AND THE FIRM BEGAN DISTRIBUTINGTHEM. THE ADVERTISING AND SALES LITERATURE DEPICTED THEPERFORMANCE HISTORY OF CERTAIN INDEXES WITHOUT DISCLOSINGTHAT IT INCLUDED BACK-TESTED INDEX PERFORMANCE, WHICH WASCALCULATED BY THE INDEX PROVIDERS USING HISTORICAL DATA FROMTIME PERIODS PREDATING THE INDEX CREATION DATE. IN ALL INSTANCESWHERE ETF ADVERTISING OR SALES LITERATURE CONTAINED BACK-TESTED INDEX PERFORMANCE, NEITHER THAT FACT NOR THE FACT THATTHE INDEX PROVIDER CALCULATED THE BACK-TESTED INDEXPERFORMANCE WAS DISCLOSED. THE FIRM REVIEWED AND APPROVEDNUMEROUS WEB-PAGES, FUND FACT SHEETS, AND OTHER PIECES OFADVERTISING AND SALES LITERATURE FOR THE ETFS THAT CONTAINEDUNDISCLOSED AND UN-SOURCED BACK-TESTED INDEX PERFORMANCEFOR OVER FOUR YEARS AND NINE MONTHS; BUT THEREAFTER, THE FIRMHAD REMOVED ALL INSTANCES OF BACK-TESTED INDEX PERFORMANCEFROM ALL OF THE ETF ADVERTISING AND SALES LITERATURE. THEUNDISCLOSED INCLUSION OF BACK-TESTED INDEX PERFORMANCEHISTORY WAS UNWARRANTED BECAUSE IT PURPORTED TO INDICATETHAT THE INDEX HAD A PERFORMANCE HISTORY THAT WAS LONGERTHAN THE ACTUAL EXISTENCE OF THE INDEX. MOREOVER, THEINCLUSION OF UNDISCLOSED BACK-TESTED INDEX PERFORMANCEHISTORY AND THE FAILURE TO IDENTIFY THE SOURCE OF THAT BACK-TESTED INDEX PERFORMANCE HISTORY DID NOT PROVIDE POTENTIALINVESTORS A SOUND BASIS FOR EVALUATING THE INDEX PERFORMANCEHISTORY PRESENTED IN THE ETF ADVERTISING AND SALES LITERATURE.THE FIRM'S REGISTERED PRINCIPALS REVIEWED AND APPROVED SEVENPRESENTATIONS RELATING TO CERTAIN HEDGE FUNDS AND PRIVATEEQUITY FUNDS THAT DID NOT COMPLY WITH THE CONTENT STANDARDSOF NASD RULE 2210. THE FIRM ACTED AS THE DISTRIBUTOR ORPLACEMENT AGENT FOR THE FUNDS, AND FOUR OF THE SEVENPRESENTATIONS WERE PREPARED AND/OR PRESENTED BY AT LEAST ONEPERSON REGISTERED WITH THE FIRM. THE FIRM FAILED TO IMPLEMENTEFFECTIVE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE CONTENT STANDARDS OF NASD RULE2210. THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.THE FIRM'S PROCEDURES FAILED TO CAUSE THE REGISTEREDPRINCIPALS REVIEWING HEDGE FUND COMMUNICATIONS TO REVIEWSUCH COMMUNICATIONS FOR COMPLIANCE WITH CONTENT STANDARDS.THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2009018186201

www.finra.org/brokercheck User GuidanceFINRA RULE 2010, NASD RULES 2110, 2210(D)(1)(A), 2210(D)(1)(B),2210(D)(2)(B), 3010: THE FIRM REVIEWED AND APPROVED ADVERTISINGAND SALES LITERATURE FOR EXCHANGE TRADED FUNDS (ETFS)OFFERED BY ONE OF THE WORLD'S LARGEST ETF PROVIDERS THAT DIDNOT COMPLY WITH THE CONTENT STANDARDS OF NASD RULE 2210.DURING THE PERIOD JANUARY 1, 2005, THROUGH OCTOBER 20, 2009, THEFIRM WAS THE DISTRIBUTOR OF THE ETFS. THE ETFS' INVESTMENTADVISER (A COMPANY NOT AFFILIATED WITH THE FIRM) PREPARED THEADVERTISING AND SALES LITERATURE AND SENT IT TO THE FIRM. AS THEDISTRIBUTOR OF THE ETFS, THE FIRM WAS RESPONSIBLE FORREVIEWING AND APPROVING THESE MATERIALS IN ACCORDANCE WITHTHE REQUIREMENTS OF NASD RULE 2210. ACCORDINGLY, REGISTEREDPRINCIPALS OF THE FIRM REVIEWED AND APPROVED ALL THE ETFADVERTISING AND SALES LITERATURE PRIOR TO USE. THE WEBSITES,FUND FACT SHEETS, AND OTHER PIECES OF ADVERTISING AND SALESLITERATURE FOR THE ETFS THAT THE FIRM REVIEWED AND APPROVEDINCLUDED PERFORMANCE HISTORY FOR THE ETFS' CORRESPONDINGINDEXES. IN NUMEROUS INSTANCES, THE INDEX PROVIDERS CREATEDTHE CORRESPONDING INDEXES SHORTLY BEFORE THE INVESTMENTADVISER LAUNCHED THE ETFS AND THE FIRM BEGAN DISTRIBUTINGTHEM. THE ADVERTISING AND SALES LITERATURE DEPICTED THEPERFORMANCE HISTORY OF CERTAIN INDEXES WITHOUT DISCLOSINGTHAT IT INCLUDED BACK-TESTED INDEX PERFORMANCE, WHICH WASCALCULATED BY THE INDEX PROVIDERS USING HISTORICAL DATA FROMTIME PERIODS PREDATING THE INDEX CREATION DATE. IN ALL INSTANCESWHERE ETF ADVERTISING OR SALES LITERATURE CONTAINED BACK-TESTED INDEX PERFORMANCE, NEITHER THAT FACT NOR THE FACT THATTHE INDEX PROVIDER CALCULATED THE BACK-TESTED INDEXPERFORMANCE WAS DISCLOSED. THE FIRM REVIEWED AND APPROVEDNUMEROUS WEB-PAGES, FUND FACT SHEETS, AND OTHER PIECES OFADVERTISING AND SALES LITERATURE FOR THE ETFS THAT CONTAINEDUNDISCLOSED AND UN-SOURCED BACK-TESTED INDEX PERFORMANCEFOR OVER FOUR YEARS AND NINE MONTHS; BUT THEREAFTER, THE FIRMHAD REMOVED ALL INSTANCES OF BACK-TESTED INDEX PERFORMANCEFROM ALL OF THE ETF ADVERTISING AND SALES LITERATURE. THEUNDISCLOSED INCLUSION OF BACK-TESTED INDEX PERFORMANCEHISTORY WAS UNWARRANTED BECAUSE IT PURPORTED TO INDICATETHAT THE INDEX HAD A PERFORMANCE HISTORY THAT WAS LONGERTHAN THE ACTUAL EXISTENCE OF THE INDEX. MOREOVER, THEINCLUSION OF UNDISCLOSED BACK-TESTED INDEX PERFORMANCEHISTORY AND THE FAILURE TO IDENTIFY THE SOURCE OF THAT BACK-TESTED INDEX PERFORMANCE HISTORY DID NOT PROVIDE POTENTIALINVESTORS A SOUND BASIS FOR EVALUATING THE INDEX PERFORMANCEHISTORY PRESENTED IN THE ETF ADVERTISING AND SALES LITERATURE.THE FIRM'S REGISTERED PRINCIPALS REVIEWED AND APPROVED SEVENPRESENTATIONS RELATING TO CERTAIN HEDGE FUNDS AND PRIVATEEQUITY FUNDS THAT DID NOT COMPLY WITH THE CONTENT STANDARDSOF NASD RULE 2210. THE FIRM ACTED AS THE DISTRIBUTOR ORPLACEMENT AGENT FOR THE FUNDS, AND FOUR OF THE SEVENPRESENTATIONS WERE PREPARED AND/OR PRESENTED BY AT LEAST ONEPERSON REGISTERED WITH THE FIRM. THE FIRM FAILED TO IMPLEMENTEFFECTIVE SUPERVISORY PROCEDURES REASONABLY DESIGNED TOACHIEVE COMPLIANCE WITH THE CONTENT STANDARDS OF NASD RULE2210. THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.THE FIRM'S PROCEDURES FAILED TO CAUSE THE REGISTEREDPRINCIPALS REVIEWING HEDGE FUND COMMUNICATIONS TO REVIEWSUCH COMMUNICATIONS FOR COMPLIANCE WITH CONTENT STANDARDS.THE FIRM FAILED TO IMPLEMENT EFFECTIVE SUPERVISORYPROCEDURES RELATING TO THE SUPERVISION OF THE REGISTEREDPRINCIPALS WHO REVIEWED THE ADVERTISING AND SALES LITERATURE.






Initiated By: FINANCIAL INDUSTRY REGULATORY AUTHORITY


Censure


MONETARY/FINE $225,000.00


Docket/Case Number: AWC NO. 2009018186201

Principal Product Type: Other

Other Product Type(s): EXCHANGE TRADED FUNDS



Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS ANDTHEREFORE, THE FIRM WAS CENSURED AND FINED $225,000. THE FINEWAS PAID IN FULL ON MARCH 16, 2012.

Firm Statement THE FIRM WAS CENSURED AND FINED $225,000. THE FINE WAS PAID INFULL ON MARCH 16, 2012.



Disclosure 3 of 3

i







Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION


Cease and Desist


CIVIL MONEY PENALTY


Docket/Case Number: 3-11548



Allegations: SEC ADMINISTRATIVE RELEASE NO. 50017, DATED JULY 14, 2004; THESECURITIES AND EXCHANGE COMMISSION ("COMMISSION" OR "SEC")DEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST THAT PUBLICADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS BE, ANDHEREBY ARE, INSTITUTED PURSUANT TO SECTIONS 15(B) AND 21C OF THESECURITIES EXCHANGE ACT OF 1934 ("EXCHANGE ACT") AGAINST SEIINVESTMENTS DISTRIBUTION COMPANY ("SIDCO" OR "FIRM"). EXAMINERSCONCLUDED THAT SIDCO INCORRECTLY HAD CALCULATED ANDREPORTED ITS NET CAPITAL. IN PARTICULAR, SIDCO'S FAILURE TOREFLECT A BALANCE OF OVER $94 MILLION IN AN ACCOUNT ESTABLISHEDUNDER RULE 15C3-3(K)(2)(I), USED FOR SIDCO'S REPURCHASEAGREEMENT PROGRAM AS BOTH AN ALLOWABLE ASSET AND AS ANAGGREGATE INDEBTEDNESS LIABILITY AT MONTH END FEBRUARY 28,2003, RESULTED IN AN INCREASE IN SIDCO'S MINIMUM REQUIRED NETCAPITAL OF $6,267,444, WHICH CAUSED THE COMPANY TO FALL BELOWITS 120% MINIMUM NET CAPITAL REQUIREMENT FOR THAT MONTH. SIDCOFAILED TO TIMELY NOTIFY THE SEC OF THIS NET CAPITAL DEFICIENCY ASREQUIRED BY RULE 17A-11(C)(3) OF THE EXCHANGE ACT. IN ADDITION,SIDCO REPORTED NET CAPITAL OF MORE THAN $8 MILLION, WHEN BASEDUPON ITS BOOKS AND RECORDS AT THAT TIME IT SHOULD HAVEREPORTED NEGATIVE NET CAPITAL OF $53 MILLION. SIDCO FAILED TOMAKE AND KEEP CURRENT ACCURATE BOOKS AND RECORDSREFLECTING ALL ASSETS AND LIABILITIES FROM AT LEAST SEPTEMBER2002 THROUGH FEBRUARY 2003. THE ACCOUNTS NOT INCLUDED INSIDCO'S RECORDS CONSISTED OF TWO ACCOUNTS FOR THE EXCLUSIVEBENEFIT OF CUSTOMERS, AT LEAST ELEVEN ERROR ACCOUNTS, AND ATLEAST EIGHT CLEARING ACCOUNTS. SIDCO DID NOT NOTIFY THE SEC OFITS FAILURE TO MAKE AND KEEP CURRENT BOOKS AND RECORDS ASREQUIRED BY RULE 17A-11(D) OF THE EXCHANGE ACT. SIDCO MATERIALLYMISSTATED ITS NET CAPITAL IN CERTAIN MONTHLY FOCUS REPORTSFILED WITH THE SEC FROM AT LEAST SEPTEMBER 2002 THROUGHFEBRUARY 2003.








CIVIL MONEY PENALTY


Resolution:

Other Sanctions Ordered: UNDERTAKINGS

Sanction Details: IT IS ORDERED THAT PURSUANT TO SECTION 15(B) OF THE EXCHANGEACT, SEI INVESTMENTS DISTRIBUTION COMPANY IS HEREBY CENSURED.PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, SIDCO SHALL CEASEAND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 15(C)(3) AND 17(A) OF THE EXCHANGEACT AND RULES 15C3-1, 15C3-3, 17A-3, 17A-5 AND 17A-11 THEREUNDER.SIDCO SHALL, WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY IN THE AMOUNT OF $375,000. SIDCO SHALLCOMPLY WITH THE FOLLOWING UNDERTAKINGS: SIDCO SHALL CONTINUETO EMPLOY A FIRM ("FIRM") (A) TO CONDUCT A REVIEW OF AND MAKEFINDINGS REGARDING SIDCO'S INTERNAL CONTROLS, POLICIES,PRACTICES, PROCEDURES, ORGANIZATIONAL STRUCTURE, ANDSTAFFING DESIGNED TO DETECT AND PREVENT THE TYPES OFVIOLATIONS OF RULES DESCRIBED IN THIS ORDER; (B) TO CONDUCT AREVIEW OF ANY INTERNAL CONTROLS, POLICIES, PRACTICES ANDPROCEDURES THAT SIDCO HAS ADOPTED AND IMPLEMENTED SINCE THEACTIVITIES DESCRIBED IN THIS ORDER, TO DETERMINE WHETHER AND TOWHAT EXTENT THERE IS A NEED FOR ADDITIONAL OR AMENDED POLICIESAND PROCEDURES DESIGNED TO DETECT AND PREVENT SUCHVIOLATIONS; AND (C) TO MAKE FINDINGS REGARDING ANY ADDITIONALINTERNAL CONTROLS, POLICIES, OR PROCEDURES WHICH THE FIRMBELIEVES ARE NECESSARY TO PROVIDE ASSURANCE THAT SIDCO CANDETECT AND PREVENT THE TYPES OF VIOLATIONS OF THE RULESDESCRIBED IN THIS ORDER. SIDCO SHALL PROMPTLY PROVIDE THE FIRMWITH ANY AND ALL REQUESTED DOCUMENTS AND OTHER INFORMATIONPERTAINING TO SIDCO'S BROKERAGE OPERATIONS. NO LATER THANTHREE MONTHS FROM THE DATE OF THIS ORDER, SIDCO SHALL REQUIRETHE FIRM TO SUBMIT ITS REPORT, IN WRITING, TO SIDCO, WITH A COPYTO THE STAFF, DETAILING FINDINGS REGARDING SIDCO'S INTERNALCONTROLS, POLICIES, PRACTICES, PROCEDURES, ORGANIZATIONALSTRUCTURE, AND STAFF AND ITS RECOMMENDATIONS, IF ANY, FORREVISED OR ADDITIONAL MEASURES DESIGNED TO DETECT ANDPREVENT THE TYPES OF VIOLATIONS OF THE RULES DESCRIBED IN THISORDER.


No

Sanctions Ordered: CensureMonetary/Fine $375,000.00Cease and Desist/Injunction

Order






IT IS ORDERED THAT PURSUANT TO SECTION 15(B) OF THE EXCHANGEACT, SEI INVESTMENTS DISTRIBUTION COMPANY IS HEREBY CENSURED.PURSUANT TO SECTION 21C OF THE EXCHANGE ACT, SIDCO SHALL CEASEAND DESIST FROM COMMITTING OR CAUSING ANY VIOLATIONS AND ANYFUTURE VIOLATIONS OF SECTIONS 15(C)(3) AND 17(A) OF THE EXCHANGEACT AND RULES 15C3-1, 15C3-3, 17A-3, 17A-5 AND 17A-11 THEREUNDER.SIDCO SHALL, WITHIN TEN DAYS OF THE ENTRY OF THIS ORDER, PAY ACIVIL MONEY PENALTY IN THE AMOUNT OF $375,000. SIDCO SHALLCOMPLY WITH THE FOLLOWING UNDERTAKINGS: SIDCO SHALL CONTINUETO EMPLOY A FIRM ("FIRM") (A) TO CONDUCT A REVIEW OF AND MAKEFINDINGS REGARDING SIDCO'S INTERNAL CONTROLS, POLICIES,PRACTICES, PROCEDURES, ORGANIZATIONAL STRUCTURE, ANDSTAFFING DESIGNED TO DETECT AND PREVENT THE TYPES OFVIOLATIONS OF RULES DESCRIBED IN THIS ORDER; (B) TO CONDUCT AREVIEW OF ANY INTERNAL CONTROLS, POLICIES, PRACTICES ANDPROCEDURES THAT SIDCO HAS ADOPTED AND IMPLEMENTED SINCE THEACTIVITIES DESCRIBED IN THIS ORDER, TO DETERMINE WHETHER AND TOWHAT EXTENT THERE IS A NEED FOR ADDITIONAL OR AMENDED POLICIESAND PROCEDURES DESIGNED TO DETECT AND PREVENT SUCHVIOLATIONS; AND (C) TO MAKE FINDINGS REGARDING ANY ADDITIONALINTERNAL CONTROLS, POLICIES, OR PROCEDURES WHICH THE FIRMBELIEVES ARE NECESSARY TO PROVIDE ASSURANCE THAT SIDCO CANDETECT AND PREVENT THE TYPES OF VIOLATIONS OF THE RULESDESCRIBED IN THIS ORDER. SIDCO SHALL PROMPTLY PROVIDE THE FIRMWITH ANY AND ALL REQUESTED DOCUMENTS AND OTHER INFORMATIONPERTAINING TO SIDCO'S BROKERAGE OPERATIONS. NO LATER THANTHREE MONTHS FROM THE DATE OF THIS ORDER, SIDCO SHALL REQUIRETHE FIRM TO SUBMIT ITS REPORT, IN WRITING, TO SIDCO, WITH A COPYTO THE STAFF, DETAILING FINDINGS REGARDING SIDCO'S INTERNALCONTROLS, POLICIES, PRACTICES, PROCEDURES, ORGANIZATIONALSTRUCTURE, AND STAFF AND ITS RECOMMENDATIONS, IF ANY, FORREVISED OR ADDITIONAL MEASURES DESIGNED TO DETECT ANDPREVENT THE TYPES OF VIOLATIONS OF THE RULES DESCRIBED IN THISORDER.

Regulator Statement IN ANTICIPATION OF THE INSTITUTION OF THESE PROCEEDINGS, SEIINVESTMENTS DISTRIBUTION COMPANY HAS SUBMITTED AN OFFER OFSETTLEMENT ("OFFER"), WHICH THE SEC HAS DETERMINED TO ACCEPTWITHOUT ADMITTING OR DENYING THE FINDINGS, SEI INVESTMENTSDISTRIBUTION COMPANY CONSENT TO THE ENTRY OF THIS ORDER ANDCEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, AND IMPOSINGREMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TOSECTIONS 15(B) AND 21C OF THE SECURITIES EXCHANGE ACT OF 1934("ORDER"). SIDCO WILLFULLY VIOLATED SECTION 17(A) OF THEEXCHANGE ACT AND RULE 17A-3 THEREUNDER, WHICH REQUIRE THATBROKER-DEALERS REGISTERED WITH THE SEC MAKE AND KEEP FORPRESCRIBED PERIODS SUCH RECORDS, FURNISH SUCH COPIESTHEREOF, AND MAKE AND DISSEMINATE SUCH REPORTS AS THE SEC HASPRESCRIBED AS NECESSARY OR APPROPRIATE IN THE PUBLIC INTEREST,OR FOR THE PROTECTION OF INVESTORS. SIDCO WILLFULLY VIOLATEDSECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-5 THEREUNDER,WHICH REQUIRE THAT BROKER-DEALERS REGISTERED WITH THE SECFILE WITH REGULATORS PERIODIC UNAUDITED FINANCIAL REPORTS, ORFOCUS REPORTS, AS WELL AS AN ANNUAL AUDITED REPORT THATINCLUDES A STATEMENT OF FINANCIAL CONDITION, STATEMENT OFINCOME, AND A STATEMENT OF CHANGES IN FINANCIAL POSITION. SIDCOWILLFULLY VIOLATED SECTION 17(A) AND RULE 17A-5 THEREUNDER BYFILING INACCURATE FOCUS REPORTS FROM AT LEAST SEPTEMBER 2002THROUGH FEBRUARY 2003, AND BY FILING INACCURATE AUDITEDFINANCIAL STATEMENTS FOR THE YEAR ENDED DECEMBER 31, 2002.SIDCO WILLFULLY VIOLATED SECTION 17(A) OF THE EXCHANGE ACT ANDRULE 17A-11(B)(1) THEREUNDER, WHICH REQUIRE BROKER-DEALERSREGISTERED WITH THE SEC WHOSE NET CAPITAL DECLINES BELOW THEMINIMUM AMOUNT REQUIRED TO GIVE NOTICE TO THE SEC OF SUCHDEFICIENCY THAT SAME DAY. IN VIEW OF THE FOREGOING, THE SECDEEMS IT APPROPRIATE AND IN THE PUBLIC INTEREST TO IMPOSE THESANCTIONS SPECIFIED IN THE OFFER OF RESPONDENTS SIDCO.


Allegations: DURING AN EXAMINATION OF SEI INVESTMENTS DISTRIBUTION CO.(SIDCO) IN MID 2003, THE PHILADELPHIA REGIONAL OFFICE OF THESECURITIES AND EXCHANGE COMMISSION (SEC) IDENTIFIED VIOLATIONSIN EARLY 2003 AND IN PRIOR PERIODS OF CERTAIN PROVISIONS OF THESECURITIES EXCHANGE ACT OF 1934 (ACT), INCLUDING VIOLATIONS OFTHE ACT'S NET CAPITAL, CUSTOMER PROTECTION, REPORTING ANDBOOKS AND RECORDS PROVISIONS. THESE VIOLATIONS RESULTED INPART FROM AMOUNTS ATTRIBUTABLE TO A SIDCO AFFILIATE BEINGCOMMINGLED IN A SIDCO ACCOUNT ESTABLISHED PURSUANT TO THECUSTOMER PROTECTION PROVISIONS OF RULE 15C3-3(K)(2)(I). ON JULY14, 2004, THE SEC ACCEPTED SIDCO'S OFFER OF SETTLEMENT COVERINGTHESE DEFICIENCIES, PURSUANT TO WHICH SIDCO HAS BEENCENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING ORCAUSING VIOLATIONS OF THE APPLICABLE PROVISIONS OF THE ACT ANDRULES THEREUNDER AND PAY A CIVIL MONETARY PENALTY OF $375,000.IN ADDITION, SIDCO HAS AGREED TO CONTINUE TO RETAIN DELOITTE ANDTOUCHE, LLP TO CONDUCT A REVIEW AND MAKE FINDING ANDRECOMMENDATIONS TO SIDCO, WITH A COPY TO THE SEC, REGARDINGSIDCO'S INTERNAL CONTROLS, POLICIES, PROCEDURES,ORGANIZATIONAL STRUCTURE AND STAFFING AND TO REVIEW SIDCO'SIMPLEMENTATION OF ANY SUCH RECOMMENDATIONS WITHIN 30 DAYSAFTER THE FIRST AND SECOND ANNIVERSARY OF THE DATE OF SIDCO'SACKNOWLEDGEMENT TO THE SEC OF ITS IMPLEMENTATION OF SUCHRECOMMENDATIONS.

PURSUANT TO A SEPARATE SETTLEMENT WITH THE SEC, SEIINVESTMENTS COMPANY HAS AGREED TO CEASE AND DESIST FROMCAUSING SIDCO'S NOTED VIOLATIONS.







Initiated By: SECURITIES AND EXCHANGE COMMISSION


Cease and Desist


CENSURE, CIVIL AND ADMINISTRATIVE PENALTY/FINE, UNDERTAKING.


Docket/Case Number: FILE NO. 3-11548



Allegations: DURING AN EXAMINATION OF SEI INVESTMENTS DISTRIBUTION CO.(SIDCO) IN MID 2003, THE PHILADELPHIA REGIONAL OFFICE OF THESECURITIES AND EXCHANGE COMMISSION (SEC) IDENTIFIED VIOLATIONSIN EARLY 2003 AND IN PRIOR PERIODS OF CERTAIN PROVISIONS OF THESECURITIES EXCHANGE ACT OF 1934 (ACT), INCLUDING VIOLATIONS OFTHE ACT'S NET CAPITAL, CUSTOMER PROTECTION, REPORTING ANDBOOKS AND RECORDS PROVISIONS. THESE VIOLATIONS RESULTED INPART FROM AMOUNTS ATTRIBUTABLE TO A SIDCO AFFILIATE BEINGCOMMINGLED IN A SIDCO ACCOUNT ESTABLISHED PURSUANT TO THECUSTOMER PROTECTION PROVISIONS OF RULE 15C3-3(K)(2)(I). ON JULY14, 2004, THE SEC ACCEPTED SIDCO'S OFFER OF SETTLEMENT COVERINGTHESE DEFICIENCIES, PURSUANT TO WHICH SIDCO HAS BEENCENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING ORCAUSING VIOLATIONS OF THE APPLICABLE PROVISIONS OF THE ACT ANDRULES THEREUNDER AND PAY A CIVIL MONETARY PENALTY OF $375,000.IN ADDITION, SIDCO HAS AGREED TO CONTINUE TO RETAIN DELOITTE ANDTOUCHE, LLP TO CONDUCT A REVIEW AND MAKE FINDING ANDRECOMMENDATIONS TO SIDCO, WITH A COPY TO THE SEC, REGARDINGSIDCO'S INTERNAL CONTROLS, POLICIES, PROCEDURES,ORGANIZATIONAL STRUCTURE AND STAFFING AND TO REVIEW SIDCO'SIMPLEMENTATION OF ANY SUCH RECOMMENDATIONS WITHIN 30 DAYSAFTER THE FIRST AND SECOND ANNIVERSARY OF THE DATE OF SIDCO'SACKNOWLEDGEMENT TO THE SEC OF ITS IMPLEMENTATION OF SUCHRECOMMENDATIONS.



Resolution:

Sanctions Ordered: CensureMonetary/Fine $375,000.00Cease and Desist/Injunction

Decision & Order of Offer of Settlement






Other Sanctions Ordered: UNDERTAKING.

Sanction Details: APPLICANT - $375,000

Firm Statement DURING AN EXAMINATION OF SEI INVESTMENTS DISTRIBUTION CO.(SIDCO) IN MID 2003, THE PHILADELPHIA REGIONAL OFFICE OF THESECURITIES AND EXCHANGE COMMISSION (SEC) IDENTIFIED VIOLATIONSIN EARLY 2003 AND IN PRIOR PERIODS OF CERTAIN PROVISIONS OF THESECURITIES EXCHANGE ACT OF 1934 (ACT), INCLUDING VIOLATIONS OFTHE ACT'S NET CAPITAL, CUSTOMER PROTECTION, REPORTING ANDBOOKS AND RECORDS PROVISIONS. THESE VIOLATIONS RESULTED INPART FROM AMOUNTS ATTRIBUTABLE TO A SIDCO AFFILIATE BEINGCOMMINGLED IN A SIDCO ACCOUNT ESTABLISHED PURSUANT TO THECUSTOMER PROTECTION PROVISIONS OF RULE 15C3-3(K)(2)(I). ON JULY14, 2004, THE SEC ACCEPTED SIDCO'S OFFER OF SETTLEMENT COVERINGTHESE DEFICIENCIES, PURSUANT TO WHICH SIDCO HAS BEENCENSURED, ORDERED TO CEASE AND DESIST FROM COMMITTING ORCAUSING VIOLATIONS OF THE APPLICABLE PROVISIONS OF THE ACT ANDRULES THEREUNDER AND PAY A CIVIL MONETARY PENALTY OF $375,000.IN ADDITION, SIDCO HAS AGREED TO CONTINUE TO RETAIN DELOITTE ANDTOUCHE, LLP TO CONDUCT A REVIEW AND MAKE FINDING ANDRECOMMENDATIONS TO SIDCO, WITH A COPY TO THE SEC, REGARDINGSIDCO'S INTERNAL CONTROLS, POLICIES, PROCEDURES,ORGANIZATIONAL STRUCTURE AND STAFFING AND TO REVIEW SIDCO'SIMPLEMENTATION OF ANY SUCH RECOMMENDATIONS WITHIN 30 DAYSAFTER THE FIRST AND SECOND ANNIVERSARY OF THE DATE OF SIDCO'SACKNOWLEDGEMENT TO THE SEC OF ITS IMPLEMENTATION OF SUCHRECOMMENDATIONS.


CensureMonetary/Fine $375,000.00Cease and Desist/Injunction






End of Report

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