On September 6, 2012, the SEC issued a settled administrative proceeding against two investment advisory firms, located in Portland Oregon, and their owner. The proceeding involved a failure by the adviser to provide appropriate disclosure with respect to revenue sharing and other conflicts of interest. The proceeding stemmed from an SEC investigation that uncovered a number of violations, in particular with respect to a lack of disclosure on revenue-sharing payments from a brokerage firm to mutual funds recommended by the adviser that provided the adviser with an incentive to recommend those mutual funds.

SEC Charges Oregon-Based Investment Adviser for Failing to Disclose Revenue Sharing Payments, SEC Press Release No. 2012-180 (September 6, 2012), available at http://www.sec.gov/news/press/2012/2012-180.htm.