Assets under management Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Private Funds
Private funds reported by Cibc Private Wealth Advisors, Inc..
Employee Growth by Quarter
Quarterly points use the latest ADV filing or SEC roster snapshot available in each quarter.
Historical AUM and employee figures reflect available SEC Form ADV filings under this CRD. Filing gaps may reflect registration status changes, dormant periods, state registration periods, firm restructuring, or other reporting changes. Rialytix does not interpolate missing periods.
Ownership
Reported direct and indirect ownership ranges
Reported ownership ranges
Highlighted bands show the percentage range reported in Form ADV.
Bars represent the reported range at that individual ownership step, not an estimated percentage of the advisory firm. Indirect relationships may refer to intermediate entities rather than directly to Cibc Private Wealth Advisors, Inc...
Reported ownership and control details
Form ADV · Filing date 2026-06-22 · Schedules A and B
| # | Owner / person & role | Interest in entity | Reported interest | Control person | Title / status acquired | Source |
|---|---|---|---|---|---|---|
| 1 | JOHN SHEEHAN MARKWALTERCHAIRMAN OF THE BOARD, CHIEF EXECUTIVE OFFICERIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | CHAIRMAN OF THE BOARD, CHIEF EXECUTIVE OFFICER03/2004 | Schedule APDF page 61 |
| 2 | CIBC PRIVATE WEALTH GROUP LLCSOLE SHAREHOLDERDomestic entity | CIBC PRIVATE WEALTH ADVISORS, INC. | 75% or moreCode E | Yes | SOLE SHAREHOLDER03/2004 | Schedule APDF page 61 |
| 3 | GREGORY BRENT CAMPBELLGENERAL COUNSEL & ASST SECRETARY, DIRECTORIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | GENERAL COUNSEL & ASST SECRETARY, DIRECTOR08/2022 | Schedule APDF page 61 |
| 4 | Paul CareyCHIEF FINANCIAL OFFICERIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | CHIEF FINANCIAL OFFICER02/2019 | Schedule APDF page 61 |
| 5 | PHILIP WAYNE CECILSECRETARYIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | SECRETARY02/2021 | Schedule APDF page 61 |
| 6 | DIANA KIFARKIS VASQUEZDIRECTORIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | DIRECTOR11/2023 | Schedule APDF page 61 |
| 7 | Kishore SettyPRESIDENTIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | PRESIDENT11/2023 | Schedule APDF page 61 |
| 8 | Brian DELMANCHIEF COMPLIANCE OFFICERIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | CHIEF COMPLIANCE OFFICER11/2024 | Schedule APDF page 61 |
| 9 | Gary PzegeoCHIEF INVESTMENT OFFICERIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | CHIEF INVESTMENT OFFICER02/2025 | Schedule APDF page 61 |
| 10 | Trevor C ChambersDIRECTORIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | DIRECTOR05/2025 | Schedule APDF page 61 |
| 11 | DANIEL ERIC FELDMANDIRECTORIndividual | CIBC PRIVATE WEALTH ADVISORS, INC. | Less than 5%Code NA | Yes | DIRECTOR05/2025 | Schedule APDF page 61 |
| 12 | CANADIAN IMPERIAL BANK OF COMMERCE100% SHAREHOLDERForeign entity | CIBC BANCORP USA, INC. | 75% or moreCode E | Yes | 100% SHAREHOLDER08/2008 | Schedule BPDF page 62 |
| 13 | CIBC BANCORP USA, INC.100% SHAREHOLDERDomestic entity | CIBC PRIVATE WEALTH GROUP LLC | 75% or moreCode E | Yes | 100% SHAREHOLDER12/2013 | Schedule BPDF page 62 |
Less than 5% may include zero. Code F identifies a role without specifying a percentage. Reported interests may overlap and may not include every owner. Total indirect ownership is not calculated.
Compliance & Disclosures
Filing dated 6/22/2026 5:13:46 PM
Responses were selected by the RIA in its filing. Questions are shortened for readability; “you” refers to the reporting firm, and some questions also cover advisory affiliates.
AFelonies2 No
In the past ten years, have you or any advisory affiliate:
- A1Been convicted of or pleaded guilty or no contest to a felony?No
- A2Been charged with a felony?No
BMisdemeanors2 No
In the past ten years, have you or any advisory affiliate:
- B1Been convicted of or pleaded guilty or no contest to a misdemeanor involving investments, an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion?No
- B2Been charged with a misdemeanor of the kind listed above?No
CSEC or CFTC actions3 Yes2 No
Has the SEC or CFTC ever:
- C1Found you or an advisory affiliate made a false statement or omission?No
- C2Found you or an advisory affiliate violated SEC or CFTC regulations or statutes?Yes
- C3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- C4Entered an order against you or an advisory affiliate in connection with investment-related activity?Yes
- C5Imposed a civil money penalty on you or an advisory affiliate, or ordered you or an advisory affiliate to cease and desist from any activity?Yes
DOther regulatory actions5 No
Has any other federal regulatory agency, state regulatory agency, or foreign financial regulatory authority ever:
- D1Found you or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?No
- D2Found you or an advisory affiliate violated investment-related regulations or statutes?No
- D3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- D4In the past ten years, entered an order against you or an advisory affiliate in connection with investment-related activity?No
- D5Denied, suspended, or revoked your or an advisory affiliate’s registration or license, or otherwise prevented association with an investment-related business or restricted activities?No
ESelf-regulatory organization actions1 Yes3 No
Has a self-regulatory organization or commodities exchange ever:
- E1Found you or an advisory affiliate made a false statement or omission?No
- E2Found you or an advisory affiliate violated its rules, other than a violation designated as a minor rule violation under an SEC-approved plan?Yes
- E3Found you or an advisory affiliate caused an investment-related business to have its authorization to do business denied, suspended, revoked, or restricted?No
- E4Disciplined you or an advisory affiliate by expulsion, suspension, barring association with other members, or otherwise restricting activities?No
FProfessional authorizations1 No
- FHas an authorization to act as an attorney, accountant, or federal contractor granted to you or an advisory affiliate ever been revoked or suspended?No
GPending regulatory proceedings1 No
- GAre you or any advisory affiliate now the subject of a regulatory proceeding that could result in a “Yes” answer to any part of C, D, or E?No
HCivil judicial actions and proceedings2 Yes2 No
(1) Court actions
Has a domestic or foreign court:
- H(1)(a)In the past ten years, enjoined you or an advisory affiliate in connection with investment-related activity?No
- H(1)(b)Found that you or an advisory affiliate violated investment-related statutes or regulations?No
- H(1)(c)Dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or an advisory affiliate by a state or foreign financial regulatory authority?Yes
(2) Pending civil proceedings
- H(2)Are you or any advisory affiliate now the subject of a civil proceeding that could result in a “Yes” answer to any part of H(1)?Yes
Additional DRP filings 8 source blocks
Verbatim excerpts from supporting DRP filings, which may concern the firm or advisory affiliates. Amounts retain their filed labels; no total or attribution is inferred.
regulatory · block 1CIBC WORLD MARKETS CORP.PDF pages 62–64
- Advisory affiliate name — filed text
- CIBC WORLD MARKETS CORP.
- Regulator name — filed text
- CHICAGO BOARD OF OPTIONS, INC.
- Monetary/Fine Amount — filed text
- $ 100,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE CBOE DETERMINED THAT ON OR ABOUT 6/1/16, CIBC WORLD MARKETS CORP. ("CIBC") (1) THROUGH AN ASSOCIATED PERSON ENGAGED IN AN ANTICIPATORY HEDGING TRANSACTION (2) FAILED TO KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING, AND EXECUTION OF CUSTOMER ORDERS IN SPX AND XSP AS WELL AS FOR CIBC'S RELATED FIRM TRANSACTIONS (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9 AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1, 4.2, 4.24, 6.9 AND 15.1; SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER.
Other filed details
Description of allegations — filed text
THE CHICAGO BOARD OF OPTIONS, INC. ("CBOE") DETERMINED THAT ON OR ABOUT JUNE 1, 2016, CIBC WORLD MARKETS CORP. ("CIBC") BY AND THROUGH ITS ASSOCIATED PERSON, ACCEPTED A CUSTOMER HELD ORDER TO SELL SPX AND XSP AUGUST PUT OPTIONS AND IN TURN (1) ENGAGED IN ANTICIPATORY HEDGING TRANSACTIONS IN RELATED INSTRUMENTS; (2) FAILED TO MAKE, KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING AND EXECUTION OF CIBC CUSTOMER ORDERS, AS WELL AS CIBC'S RELATED FIRM TRANSACTIONS; (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DEISGNED TO PREVENT AND DETECT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9; AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1 AND 6.9.
Sanction detail — filed text
FINE OF $100,000
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
630
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
CIBC WORLD MARKETS CORP.
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CHICAGO BOARD OF OPTIONS, INC.
2.
Principal Sanction:
Censure
Other Sanctions:
MONETARY FINE $100,000
3.
Date Initiated (MM/DD/YYYY):
05/06/2019
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
20160502034
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Options
Other Product Types:
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE CHICAGO BOARD OF OPTIONS, INC. ("CBOE") DETERMINED THAT ON OR ABOUT JUNE 1, 2016, CIBC WORLD MARKETS CORP. ("CIBC") BY AND
THROUGH ITS ASSOCIATED PERSON, ACCEPTED A CUSTOMER HELD ORDER TO SELL SPX AND XSP AUGUST PUT OPTIONS AND IN TURN (1) ENGAGED IN
ANTICIPATORY HEDGING TRANSACTIONS IN RELATED INSTRUMENTS; (2) FAILED TO MAKE, KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND
RECORDS ASSOCIATED WITH THE RECEIPT, ROUTING AND EXECUTION OF CIBC CUSTOMER ORDERS, AS WELL AS CIBC'S RELATED FIRM
TRANSACTIONS; (3) FAILED TO ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DEISGNED TO PREVENT AND DETECT
VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9; AND (4) FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE
WITH EXCHANGE RULES 4.1 AND 6.9.
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
06/07/2019
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 100,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
FINE OF $100,000
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
THE CBOE DETERMINED THAT ON OR ABOUT 6/1/16, CIBC WORLD MARKETS CORP. ("CIBC") (1) THROUGH AN ASSOCIATED PERSON ENGAGED IN AN
ANTICIPATORY HEDGING TRANSACTION (2) FAILED TO KEEP CURRENT AND PRESERVE ACCURATE BOOKS AND RECORDS ASSOCIATED WITH THE
RECEIPT, ROUTING, AND EXECUTION OF CUSTOMER ORDERS IN SPX AND XSP AS WELL AS FOR CIBC'S RELATED FIRM TRANSACTIONS (3) FAILED TO
ESTABLISH, IMPLEMENT AND ENFORCE WSPS THAT WERE REASONABLY DESIGNED TO PREVENT VIOLATIONS OF EXCHANGE RULES 4.1 AND 6.9 AND (4)
FAILED TO SUPERVISE THE ACTIVITY OF ITS ASSOCIATED PERSON TO ASSURE COMPLIANCE WITH EXCHANGE RULES 4.1, 4.2, 4.24, 6.9 AND 15.1;
SECTION 17(A) OF THE EXCHANGE ACT AND RULE 17A-3 THEREUNDER.regulatory · block 2CIBC WORLD MARKETS CORP.PDF pages 64–66
- Advisory affiliate name — filed text
- CIBC WORLD MARKETS CORP.
- Regulator name — filed text
- NASDAQ PHLX, LLC
- Monetary/Fine Amount — filed text
- $ 33,333.33
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
CIBC WAS SUBJECT TO CENSURE AND A MONETARY FINE OF $33,333.33
Other filed details
Description of allegations — filed text
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PHLX RULE 760. CIBC ALSO VIOLATED PHLX RULE 748 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT: (I)REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PRHOIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.
Sanction detail — filed text
FINE OF $33,333.33
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 630 This advisory affiliate is a Firm an Individual Registered: Yes No Name: CIBC WORLD MARKETS CORP. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDAQ PHLX, LLC 2. Principal Sanction: Censure Other Sanctions: FINE 3. Date Initiated (MM/DD/YYYY): 10/28/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053128902 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE PHLX AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND PHLX RULE 760. CIBC ALSO VIOLATED PHLX RULE 748 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF THE APPLICABLE FEDERAL SECURITIES LAWS AND PHLX RULES THAT: (I)REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PRHOIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 10/28/2019 Exact Explanation p If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 33,333.33 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FINE OF $33,333.33 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). CIBC WAS SUBJECT TO CENSURE AND A MONETARY FINE OF $33,333.33
regulatory · block 3CIBC WORLD MARKETS CORP.PDF pages 66–68
- Advisory affiliate name — filed text
- CIBC WORLD MARKETS CORP.
- Regulator name — filed text
- NASDQ ISE, LLC (ISE)
- Monetary/Fine Amount — filed text
- $ 33,333.33
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
CIBC WORLD MARKETS CORP (CIBC) WAS SUBJECT TO CENSURE AND A FINE OF $33,333.33.
Other filed details
Description of allegations — filed text
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ISE RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT: (I) REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING.
Sanction detail — filed text
$33,333.33
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 630 This advisory affiliate is a Firm an Individual Registered: Yes No Name: CIBC WORLD MARKETS CORP. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDQ ISE, LLC (ISE) 2. Principal Sanction: Censure Other Sanctions: FINE 3. Date Initiated (MM/DD/YYYY): 02/13/2017 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053128903 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONAL SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(1) OF THE SECURITIES EXCHANGE ACT OF 1934 AND ISE RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH, AND TO DETECT AND PREVENT VIOLATION OF APPLICABLE FEDERAL SECURITIES LAWS AND ISE RULES THAT: (I) REQUIRE ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS; AND (II) PROHIBIT FRONT-RUNNING AND ANTICIPATORY HEDGING. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 10/28/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 33,333.33 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: $33,333.33 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). CIBC WORLD MARKETS CORP (CIBC) WAS SUBJECT TO CENSURE AND A FINE OF $33,333.33.
regulatory · block 4CIBC WORLD MARKETS CORP.PDF pages 68–70
- Advisory affiliate name — filed text
- CIBC WORLD MARKETS CORP.
- Regulator name — filed text
- NASDAQ ACRA, INC.
- Monetary/Fine Amount — filed text
- $ 33,333.33
- How was matter resolved — filed text
- Acceptance, Waiver & Consent(AWC)
Action status / disposition — filed text
WITHOUT ADMITTING OR DENYING THE FINDINGS, CIBC CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS THAT THE FIRM FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE EXCHANGE FOR EXECUTION.
Other filed details
Description of allegations — filed text
FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONS SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH AND TO DETECT AND PREVENT VIOLATIONS OF THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE RULE THAT REQUIRE: ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS AND PROHIBIT FRONT- RUNNING AND ANTICIPATORY HEDGING.
Sanction detail — filed text
FINED $33,333.33
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 630 This advisory affiliate is a Firm an Individual Registered: Yes No Name: CIBC WORLD MARKETS CORP. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) NASDAQ ACRA, INC. 2. Principal Sanction: Censure Other Sanctions: MONETARY FINE OF $33,333.33 3. Date Initiated (MM/DD/YYYY): 10/28/2019 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: 2017053128901 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): FROM FEBRUARY 2017 THROUGH OCTOBER 2017, CIBC WORLD MARKETS CORP (CIBC) FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND ORDER TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE ISE AND VARIOUS OTHER NATIONS SECURITIES EXCHANGES FOR EXECUTION IN VIOLATION OF RULE 17A-3(A)(6)(I) OF THE SECURITIES EXCHANGE ACT OF 1934 AND RULE 1400. CIBC ALSO VIOLATED ISE RULE 401 BY FAILING TO ESTABLISH, MAINTAIN AND ENFORCE WRITTEN SUPERVISORY PROCEDURES AND A SYSTEM OF SUPERVISION THAT WERE REASONABLY DESIGNED TO ASSURE COMPLIANCE WITH AND TO DETECT AND PREVENT VIOLATIONS OF THE APPLICABLE FEDERAL SECURITIES LAWS AND NYSE RULE THAT REQUIRE: ACCURATE DOCUMENTATION OF THE ORDER RECEIPT AND TRANSMISSION TIMES OF OPTIONS ORDERS AND PROHIBIT FRONT- RUNNING AND ANTICIPATORY HEDGING. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Acceptance, Waiver & Consent(AWC) 11. Resolution Date (MM/DD/YYYY): 10/28/2019 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 33,333.33 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: FINED $33,333.33 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). WITHOUT ADMITTING OR DENYING THE FINDINGS, CIBC CONSENTED TO THE SANCTIONS AND THE ENTRY OF THE FINDINGS THAT THE FIRM FAILED TO ACCURATELY RECORD THE ORDER RECEIPT AND TRANSMISSION TIMES OF MANUAL OPTIONS ORDERS IT HAD ROUTED TO THE EXCHANGE FOR EXECUTION.
regulatory · block 5CIBC WORLD MARKETS CORP.PDF pages 70–71
- Advisory affiliate name — filed text
- CIBC WORLD MARKETS CORP.
- Regulator name — filed text
- CBOE EXCHANGE INC
- Monetary/Fine Amount — filed text
- $ 80,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
THE FIRM WAS CENSURED AND FINED $80,000
Other filed details
Description of allegations — filed text
CIBC WORLD MARKETS CORP VIOLATED CBOE RULES 4.2, 5.12, 8.1, 8.2 AND OCC BY LAWS ARTICLE VI SECTION I IN THAT THEY IMPROPERLY USED THE OCC ADJUSTMENT PROCESS. THE FIRM ALSO VIOLATED CBOE RULE 8.16 IN THAT THEY DID NOT ESTABLISH SUFFICIENT SUPERVISORY PROCEDURES REGARDING ITS USE OF THE OCC ADJUSTMENT PROCESS. THE FIRM HAD IN PLACE PROCEDURES REGARDING ITS ACCOMMODATION ACCOUNT, WHICH IT USED AS PART OF THE ADJUSTMENT PROCESS. HOWEVER, THOSE PROCEDURES WERE NOT CONSISTENT WITH INTERPRETATIONS AND POLICIES .01(A) TO OCC BYLAWS ARTICLE VI, SECTION I, SINCE THEY PERMITTED ADJUSTMENTS, AFTER SUPERVISORY REVIEW AND SIGN-OFF, FOR PURPOSES OTHER THAN TO CORRECT BONA FIDE ERRORS IN TRADES THAT WERE PREVIOUSLY SUMMITTED TO THE OCC.
Sanction detail — filed text
CENSURE AND MONETARY FINE OF $80,000
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 630 This advisory affiliate is a Firm an Individual Registered: Yes No Name: CIBC WORLD MARKETS CORP. (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) CBOE EXCHANGE INC 2. Principal Sanction: Censure Other Sanctions: MONETARY FINE $80,000 3. Date Initiated (MM/DD/YYYY): 05/04/2023 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: STAR NO 20200660058/FILE NO URE-31-01 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: Options Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): CIBC WORLD MARKETS CORP VIOLATED CBOE RULES 4.2, 5.12, 8.1, 8.2 AND OCC BY LAWS ARTICLE VI SECTION I IN THAT THEY IMPROPERLY USED THE OCC ADJUSTMENT PROCESS. THE FIRM ALSO VIOLATED CBOE RULE 8.16 IN THAT THEY DID NOT ESTABLISH SUFFICIENT SUPERVISORY PROCEDURES REGARDING ITS USE OF THE OCC ADJUSTMENT PROCESS. THE FIRM HAD IN PLACE PROCEDURES REGARDING ITS ACCOMMODATION ACCOUNT, WHICH IT USED AS PART OF THE ADJUSTMENT PROCESS. HOWEVER, THOSE PROCEDURES WERE NOT CONSISTENT WITH INTERPRETATIONS AND POLICIES .01(A) TO OCC BYLAWS ARTICLE VI, SECTION I, SINCE THEY PERMITTED ADJUSTMENTS, AFTER SUPERVISORY REVIEW AND SIGN-OFF, FOR PURPOSES OTHER THAN TO CORRECT BONA FIDE ERRORS IN TRADES THAT WERE PREVIOUSLY SUMMITTED TO THE OCC. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Consent 11. Resolution Date (MM/DD/YYYY): 05/08/2023 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 80,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: CENSURE AND MONETARY FINE OF $80,000 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). THE FIRM WAS CENSURED AND FINED $80,000
regulatory · block 6PDF pages 72–73
- Regulator name — filed text
- UNITED STATES SECURITIES AND EXCHANGE COMMISSION
- Monetary/Fine Amount — filed text
- $ 12,000,000.00
- How was matter resolved — filed text
- Decision & Order of Offer of Settlement
Action status / disposition — filed text
ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
Other filed details
Description of allegations — filed text
ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
Sanction detail — filed text
A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS.
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F. or 11.G. of Form ADV. Regulatory Action Check item(s) being responded to: 11.C(1) 11.C(2) 11.C(3) 11.C(4) 11.C(5) 11.D(1) 11.D(2) 11.D(3) 11.D(4) 11.D(5) 11.E(1) 11.E(2) 11.E(3) 11.E(4) 11.F. 11.G. Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE No Information Filed This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Regulatory Action initiated by: SEC Other Federal State SRO Foreign (Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) UNITED STATES SECURITIES AND EXCHANGE COMMISSION 2. Principal Sanction: Cease and Desist Other Sanctions: 3. Date Initiated (MM/DD/YYYY): 09/24/2024 Exact Explanation If not exact, provide explanation: 4. Docket/Case Number: FILE NO 3-22160 5. Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable): 6. Principal Product Type: No Product Other Product Types: 7. Describe the allegations related to this regulatory action (your response must fit within the space provided): ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS. 8. Current Status? Pending On Appeal Final 9. If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed: If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only. 10. How was matter resolved: Decision & Order of Offer of Settlement 11. Resolution Date (MM/DD/YYYY): 09/24/2024 Exact Explanation If not exact, provide explanation: 12. Resolution Detail: A. Were any of the following Sanctions Ordered (check all appropriate items)? Monetary/Fine Amount: $ 12,000,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions Ordered: THE SETTLEMENT IMPOSES A CEASE-AND-DESIST ORDER WHICH REQUIRES CIBC PRIVATE WEALTH ADVISORS, INC., IN ADDITION TO THE PAYMENT OF A MONETARY PENALTY TO COMPLY WITH UNDERTAKINGS INCLUDING RETENTION OF AN INDEPENDENT COMPLIANCE CONSULTANT Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. 13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within the space provided). ON SEPTEMBER 24, 2024, THE SECURITIES AND EXCHANGE COMMISSION (SEC) ANNOUNCED A JOINT SETTLEMENT WITH CIBC PRIVATE WEALTH ADVISORS, INC. AND CIBC WORLD MARKETS CORP. (COLLECTIVELY FOR PURPOSES OF THIS PARAGRAPH, CIBC) IN WHICH CIBC AGREED TO PAY A CIVIL MONEY PENALTY IN THE AMOUNT OF $12,000,000 FOR FAILURE TO MAINTAIN AND PRESERVE ELECTRONIC COMMUNICATIONS IN VIOLATION OF RECORDKEEPING PROVISIONS OF THE FEDERAL SECURITIES LAWS. IN DETERMINING TO ACCEPT CIBC'S SETTLEMENT OFFER, THE SEC CONSIDERED CIBC'S' COOPERATION AS WELL AS REMEDIAL STEPS THAT CIBC UNDERTOOK BOTH BEFORE AND AFTER BEING APPROACHED BY THE SEC STAFF. PRIOR TO THIS SETTLEMENT, CIBC ENHANCED ITS POLICIES AND PROCEDURES, INCREASED TRAINING AND COMPLIANCE REMINDERS CONCERNING THE USE OF APPROVED COMMUNICATIONS METHODS, ENHANCED ITS SURVEILLANCE PROCESSES, AND IMPLEMENTED SIGNIFICANT CHANGES TO THE TECHNOLOGY AVAILABLE TO PERSONNEL. AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO RETAIN AN INDEPENDENT COMPLIANCE CONSULTANT TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION ACTIVITIES TO COMPLY WITH SEC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
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regulatory · block 7CANADIAN IMPERIAL BANK OF COMMERCE (CIBC)PDF pages 73–75
- Advisory affiliate name — filed text
- CANADIAN IMPERIAL BANK OF COMMERCE (CIBC)
- Regulator name — filed text
- CFTC
- Monetary/Fine Amount — filed text
- $ 30,000,000.00
- How was matter resolved — filed text
- Consent
Action status / disposition — filed text
DURING THE RELEVANT PERIOD, AS A RESULT OF THE WIDESPREAD EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS, CIBC FAILED TO MAINTAIN COMMISSION-REQUIRED TRANSACTION RECORDS AND PRE-EXECUTION COMMUNICATIONS. BY THIS CONDUCT, CIBC VIOLATED SECTIONS 4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE ACT AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1). BY FAILING TO KEEP ALL COMMISSION- REQUIRED RECORDS IN SUCH A MANNER AS TO MAKE THEM "READILY ACCESSIBLE," CIBC VIOLATED REGULATION 1.31. CIBC FAILED TO SUPERVISE ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY DURING THE RELEVANT PERIOD. CIBC FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM TO ENSURE THAT EMPLOYEES DID NOT UTILIZE UNAPPROVED METHODS TO ENGAGE IN COMMUNICATIONS RELATING TO FIRM BUSINESS, INCLUDING THE SWAP DEALER BUSINESS. CIBC'S FAILURE TO SUPERVISE IS DEMONSTRATED BY ITS FAILURE TO DETECT, PREVENT, AND REMEDIATE REPEATED VIOLATIONS OF THE COMMISSION'S RECORDKEEPING REQUIREMENTS AND FIRM POLICIES AND PROCEDURES. SUPERVISORY PERSONNEL FAILED TO ENSURE THAT EMPLOYEES COMPLIED WITH CIBC'S COMMISSION RECORDKEEPING OBLIGATIONS AND FIRM COMMUNICATIONS POLICIES AND IN SOME INSTANCES, THEMSELVES VIOLATED THE POLICIES. THESE SUPERVISION FAILURES ALSO RESULTED IN THE FAILURE TO KEEP AND MAINTAIN COMMISSION-REQUIRED RECORDS AND THE FAILURE TO MAINTAIN THE RECORDS IN SUCH A MANNER AS TO MAKE THEM READILY AVAILABLE. BY THIS CONDUCT, CIBC FAILED TO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS, IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE ACT AND REGULATION 23.602(A).
Other filed details
Description of allegations — filed text
THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST SEPTEMBER 2018 TO THE PRESENT ("RELEVANT PERIOD"), CANADIAN IMPERIAL BANK OF COMMERCE ("CIBC") VIOLATED, AS SET FORTH BELOW, SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3), AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS ("REGULATIONS") 1.31, 23.201(A),23.202(A)(1) AND (B)(1), AND 23.602(A), 17 C.F.R. §§ 1.31, 23.201(A), 23.202(A)(1), (B) (1), AND 23.602(A) (2023).
Sanction detail — filed text
FINE OF $30 MILLION
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A. The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name).
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
This advisory affiliate is
a Firm
an Individual
Registered:
Yes
No
Name:
CANADIAN IMPERIAL BANK OF
COMMERCE (CIBC)
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances:
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
Yes
No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1. Regulatory Action initiated by:
SEC
Other Federal
State
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO)
CFTC
2.
Principal Sanction:
Cease and Desist
Other Sanctions:
AS PART OF THE SETTLEMENT, CIBC HAS UNDERTAKEN TO CONDUCT A COMPREHENSIVE REVIEW AND ASSESSMENT OF CIBC'S REMEDIATION
ACTIVITIES TO COMPLY WITH CFTC RECORDKEEPING REQUIREMENTS TO PRESERVE ELECTRONIC COMMUNICATIONS.
3.
Date Initiated (MM/DD/YYYY):
09/24/2024
Exact
Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
24-28
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types:
SWAPS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
THE COMMODITY FUTURES TRADING COMMISSION ("COMMISSION") HAS REASON TO BELIEVE THAT FROM AT LEAST SEPTEMBER 2018 TO THE PRESENT
("RELEVANT PERIOD"), CANADIAN IMPERIAL BANK OF COMMERCE ("CIBC") VIOLATED, AS SET FORTH BELOW, SECTIONS 4S(F)(1)(C), 4S(G)(1) AND (3),
AND 4S(H)(1)(B) OF THE COMMODITY EXCHANGE ACT ("ACT"), 7 U.S.C. §§ 6S(F)(1)(C), 6S(G)(1), (3), 6S(H)(1)(B), AND COMMISSION REGULATIONS
("REGULATIONS") 1.31, 23.201(A),23.202(A)(1) AND (B)(1), AND 23.602(A), 17 C.F.R. §§ 1.31, 23.201(A), 23.202(A)(1), (B) (1), AND 23.602(A) (2023).
8.
Current Status?
Pending
On Appeal
Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Consent
11. Resolution Date (MM/DD/YYYY):
09/24/2024
Exact
Explanation
If not exact, provide explanation:
12. Resolution Detail:
A. Were any of the following Sanctions Ordered (check all appropriate items)?
Monetary/Fine Amount: $ 30,000,000.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
FINE OF $30 MILLION
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
DURING THE RELEVANT PERIOD, AS A RESULT OF THE WIDESPREAD EMPLOYEE USE OF UNAPPROVED COMMUNICATION METHODS, CIBC FAILED TO
MAINTAIN COMMISSION-REQUIRED TRANSACTION RECORDS AND PRE-EXECUTION COMMUNICATIONS. BY THIS CONDUCT, CIBC VIOLATED SECTIONS
4S(F)(1)(C) AND 4S(G)(1) AND (3) OF THE ACT AND REGULATIONS 23.201(A) AND 23.202(A)(1) AND (B)(1). BY FAILING TO KEEP ALL COMMISSION-
REQUIRED RECORDS IN SUCH A MANNER AS TO MAKE THEM "READILY ACCESSIBLE," CIBC VIOLATED REGULATION 1.31. CIBC FAILED TO SUPERVISE
ITS SWAP DEALER BUSINESS ACTIVITIES DILIGENTLY DURING THE RELEVANT PERIOD. CIBC FAILED TO MAINTAIN AN ADEQUATE SUPERVISORY SYSTEM
TO ENSURE THAT EMPLOYEES DID NOT UTILIZE UNAPPROVED METHODS TO ENGAGE IN COMMUNICATIONS RELATING TO FIRM BUSINESS, INCLUDING
THE SWAP DEALER BUSINESS. CIBC'S FAILURE TO SUPERVISE IS DEMONSTRATED BY ITS FAILURE TO DETECT, PREVENT, AND REMEDIATE REPEATED
VIOLATIONS OF THE COMMISSION'S RECORDKEEPING REQUIREMENTS AND FIRM POLICIES AND PROCEDURES. SUPERVISORY PERSONNEL FAILED TO
ENSURE THAT EMPLOYEES COMPLIED WITH CIBC'S COMMISSION RECORDKEEPING OBLIGATIONS AND FIRM COMMUNICATIONS POLICIES AND IN SOME
INSTANCES, THEMSELVES VIOLATED THE POLICIES. THESE SUPERVISION FAILURES ALSO RESULTED IN THE FAILURE TO KEEP AND MAINTAIN
COMMISSION-REQUIRED RECORDS AND THE FAILURE TO MAINTAIN THE RECORDS IN SUCH A MANNER AS TO MAKE THEM READILY AVAILABLE. BY THIS
CONDUCT, CIBC FAILED TO SUPERVISE DILIGENTLY ITS OFFICERS, EMPLOYEES, AND AGENTS, IN VIOLATION OF SECTION 4S(H)(1)(B) OF THE ACT AND
REGULATION 23.602(A).civil judicial · block 1PDF pages 76–78
Full extracted filing text
Includes form instructions and options. Options shown in this text do not identify which boxes were selected.
GENERAL INSTRUCTIONS This Disclosure Reporting Page (DRP ADV) is an INITIAL OR AMENDED response used to report details for affirmative responses to Item 11.H. of Part 1A or Item 2.F. of Part 1B of Form ADV. Civil Judicial Check Part 1A item(s) being responded to: 11.H(1)(a) 11.H(1)(b) 11.H(1)(c) 11.H(2) Check Part 1B item(s) being responded to: 2.F(1) 2.F(2) 2.F(3) 2.F(4) 2.F(5) Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a completed Execution Page. One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the same event. Unrelated civil judicial actions must be reported on separate DRPs. PART I A. The person(s) or entity(ies) for whom this DRP is being filed is (are): You (the advisory firm) You and one or more of your advisory affiliates One or more of your advisory affiliates If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box. ADV DRP - ADVISORY AFFILIATE CRD Number: 4592303 This advisory affiliate is a Firm an Individual Registered: Yes No Name: EKMEKJIAN, VICKEN (For individuals, Last, First, Middle) This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser. This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's favor. If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H. (1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that occurred more than ten years ago. This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: B. If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided. Yes No NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records. PART II 1. Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) RACHEL RENDEL AS GENERAL PARTNER OF THE RENDEL FAMILY LTD. PARTNERSHIP I 2. Principal Relief Sought: Money Damages (Private/Civil Complaint) Other Relief Sought: 3. Filing Date of Court Action (MM/DD/YYYY): 09/22/2021 Exact Explanation If not exact, provide explanation: 4. Principal Product Type: Equity Listed (Common & Preferred Stock) Other Product Types: 5. Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case Number): SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN FRANCISCO CASE #:CGC-21-595440 6. Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): CIBC PRIVATE WEALTH ADVISORS, INC. 7. Describe the allegations related to this civil action (your response must fit within the space provided): THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST, OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT. 8. Current Status? Pending On Appeal Final 9. If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 10. If pending, date notice/process was served (MM/DD/YYYY): Exact Explanation If not exact, provide explanation: PLAINTIFF HAS DISMISSED THE ACTION If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only. 11. How was matter resolved: Dismissed 12. Resolution Date (MM/DD/YYYY): 07/20/2023 Exact Explanation If not exact, provide explanation: 13. Resolution Detail: A. Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)? Monetary/Fine Amount: $ 250,000.00 Revocation/Expulsion/Denial Disgorgement/Restitution Censure Cease and Desist/Injunction Bar Suspension B. Other Sanctions: ON MAY 31, 2023, THE PLAINTIFF VOLUNTARILY DISMISSED VICKEN EKMEKJIAN FROM THIS MATTER. C. Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: TO AVOID THE TIME, COSTS, AND UNCERTAINTIES OF A LITIGATION, WITHOUT ADMITTING ANY WRONGDOING ON JULY 6, 2023, THE PLAINTIFF AND CIBC PRIVATE WEALTH ADVISORS SETTLED THIS MATTER FOR $250,000. VICKEN EKMEKJIAN WAS NOT ASKED TO PARTICIPATE IN OR CONTRIBUTE TOWARDS THE SETTLEMENT. ON JULY 20, 2023, THE PLAINTIFF DISMISSED THE MATTER. 14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must fit within the space provided). THE COMPLAINT ALLEGES THAT CIBC PRIVATE WEALTH ADVISORS, INC. AND ITS ADVISORY AFFILIATE (THE "DEFENDANT") BREACHED THEIR FIDUCIARY DUTY AND FAILED TO EXERCISE REASONABLE CARE AND TO ACT WITH REASONABLE DILIGENCE IN THE COURSE OF PROVIDING DISCRETIONARY INVESTMENT ADVISORY SERVICES TO THE PLAINTIFF. THE COMPLAINT CLAIMS THAT DEFENDANT FAILED TO DISCLOSE MATERIAL INFORMATION ABOUT THE COURSE OF ACTION RECOMMENDED BY THE DEFENDANT, FAILED TO EXPLAIN THE NATURE, RISKS, AND IMPLICATIONS OF THE INVESTMENT DECISIONS RECOMMENDED BY THE DEFENDANT, AND MADE INVESTMENT DECISIONS IN MARCH 2020 THAT WERE CONTRARY TO THE BEST INTEREST, OBJECTIVES, AND RECOMMENDED ASSET ALLOCATION FOR THE PLAINTIFF'S ACCOUNT. ON MAY 31, 2023, THE PLAINTIFF VOLUNTARILY DISMISSED VICKEN EKMEKJIAN FROM THIS MATTER. TO AVOID THE TIME, COSTS, AND UNCERTAINTIES OF A LITIGATION, WITHOUT ADMITTING ANY WRONGDOING ON JULY 6, 2023, THE PLAINTIFF AND CIBC PRIVATE WEALTH ADVISORS SETTLED THIS MATTER FOR $250,000. VICKEN EKMEKJIAN WAS NOT ASKED TO PARTICIPATE IN OR CONTRIBUTE TOWARDS THE SETTLEMENT. ON JULY 20, 2023, THE PLAINTIFF DISMISSED THE MATTER.
* Metrics are based on the latest available data, including Form ADV filings, brochures, and relationship summaries pulled from the SEC IAPD, and may be subject to change. Learn what is included in the Rialytix data. Please refer to the firm's official disclosures for the most accurate information using their CRD number. This is not investment advice.