The Robare Group, LTD. v. SEC

Rogers, Circuit Judge:

The Robare Group, an investment adviser, and its principals petition for review of the decision of the Securities and Exchange Commission that they violated Section 206(2) and Section 207 of the Investment Advisers Act, 15 U.S.C. §§ 80b-6(2), 80b-7. They contend that the Commission's findings of inadequate disclosure of financial conflicts of interest over a period of years are not supported by substantial evidence, as shown by the contrary decision of the administrative law judge. Upon review, we hold that the Commission's findings of negligent violations under Section…