Epstein Index›Documents›EFTA00237111
💨IMPACT LEVEL 1 — MEH

Epstein File EFTA00237111: Large_file_1mb_plus, Solicitation and Construction (DS9)

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The document excerpt references a 2009 violation of Sections 6(c) and 6(d) of the Commodities Exchange Act and Section 4.7(b)(3)(i), with a $50,000 penalty mentioned. The specific parties, detailed violations, and full context are not fully visible in the excerpt provided.

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PersonKeyword
Excerpt 1
y: 2009 violated Sections 6(c) and from violating $50,000 6(d) of Commodities Regulation Exchange Act and did not 4.7(b)(3)(i) and file with the National Currently, our principal business, in terms of
Excerpt 2
Under those agreements, we share fees with, or receive fees from, our affiliates for the referral or **solicitation** of investors in our funds.
Excerpt 3
process, which begins with an analysis of: the manager's investment philosophy and strategy, investment process, quality and depth of research, portfolio **construction**

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