HARTFORD FUNDS DISTRIBUTORS, LLC · 2020. 12. 20. · HARTFORD FUNDS DISTRIBUTORS, LLC CRD# 45995...

BrokerCheck Report

HARTFORD FUNDS DISTRIBUTORS, LLC

Section Title

Report Summary

Firm History

CRD# 45995

1

9

Firm Profile 2 - 8

Page(s)

Firm Operations 10 - 17

Disclosure Events 18

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HARTFORD FUNDS DISTRIBUTORS,LLC

CRD# 45995

SEC# 8-51290

Main Office Location

690 LEE ROADWAYNE, PA 19087Regulated by FINRA Philadelphia Office

Mailing Address

690 LEE ROADWAYNE, PA 19087

This firm is a brokerage firm and an investmentadviser firm. For more information aboutinvestment adviser firms, visit the SEC'sInvestment Adviser Public Disclosure website at:

Business Telephone Number

610-386-4000

https://www.adviserinfo.sec.gov

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 limited liability company.

This firm was formed in Delaware on 10/01/2001.

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 2 types of businesses.

This firm is affiliated with financial or investmentinstitutions.

This firm does not have referral or financialarrangements with other brokers or dealers.

This firm is registered with:

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

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1©2020 FINRA. All rights reserved. Report about HARTFORD FUNDS DISTRIBUTORS, LLC

https://adviserinfo.sec.gov/firm/summary/45995


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This firm is classified as a limited liability company.

This firm was formed in Delaware on 10/01/2001.

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.

HARTFORD FUNDS DISTRIBUTORS, LLC

SEC#

45995

8-51290

Main Office Location

Mailing Address

Business Telephone Number

Doing business as HARTFORD FUNDS DISTRIBUTORS, LLC

610-386-4000

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?

HARTFORD FUNDS MANAGEMENT GROUP, INC

OWNER OF HARTFORD FUNDS DISTRIBUTORS, LLC

75% or more

No

Domestic Entity

12/2012

Yes

Is this a domestic or foreignentity or an individual?

Legal Name & CRD# (if any):

Position



Position Start Date


DAVEY, JAMES EDWARD

CHAIRMAN, MANAGER AND SR MANAGING DIRECTOR

Less than 5%

No

Individual

12/2013

Yes

2041562



Position


Position Start Date

DECKER, ANDREW SHIELDS

AML OFFICER

Less than 5%

Individual

03/2015

1921043








Direct Owners and Executive Officers (continued)

Firm Profile




Less than 5%

No

Yes

Position



Position Start Date


FIXER, MICHAEL JOSEPH

ASSISTANT TREASURER/ASSISTANT VICE PRESIDENT

Less than 5%

No

Individual

02/2008

Yes

5601318



Position



Position Start Date


FROST, GREGORY A.

CHIEF FINANCIAL OFFICER,MANAGING DIRECTOR, AND MANAGER

Less than 5%

No

Individual

12/2013

Yes

2864924



GARGER, WALTER FRANCIS

4753411








Firm Profile

Position



Position Start Date


GENERAL COUNSEL AND MANAGING DIRECTOR

Less than 5%

No

Individual

12/2013

Yes

4753411


Position



Position Start Date


JEFFERSON, KERAYA SHERIE

CHIEF COMPLIANCE OFFICER

Less than 5%

No

Individual

09/2014

Yes

5046523



Position


Position Start Date


MELCHER, JOSEPH GARY

EXECUTIVE VICE PRESIDENT

Less than 5%

Individual

06/2019

Yes

3152206









Firm Profile



No

Yes

Position



Position Start Date


O'NEILL, SHANNON

FINOP, CONTROLLER AND VICE PRESIDENT

Less than 5%

No

Individual

05/2015

Yes

6202623



Position



Position Start Date


PURTILL, SABRA R

TREASURER

Less than 5%

No

Individual

09/2017

Yes

2449290



SWANSON, MARTIN ALLEN

Individual

1414020









Firm Profile

Position



Position Start Date


PRESIDENT, CHIEF EXECUTIVE OFFICER, CHIEF MARKETING OFFICER,AND MANAGING DIRECTOR

Less than 5%

No

Individual

06/2019

Yes







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

Indirect Owners

Firm Profile

HARTFORD HOLDINGS, INC.

OWNER

HARTFORD FUNDS MANAGEMENT GROUP, INC

75% or more

No

Domestic Entity

05/2018

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established




THE HARTFORD FINANCIAL SERVICES GROUP, INC. (HIG)

OWNER

HARTFORD HOLDINGS, INC.

75% or more

Yes

Domestic Entity

08/2002

Yes



Company through whichindirect ownership isestablished

Relationship to Direct Owner

Relationship Established









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

No

No

No

Federal Regulator Status Date Effective

SEC Approved 10/30/1998

Self-Regulatory Organization Status Date Effective

FINRA Approved 10/30/1998






Firm Operations

Registrations (continued)

U.S. States &Territories

Status Date Effective

Alabama Approved 05/11/1999

Alaska Approved 02/12/1999

Arizona Approved 04/28/1999

Arkansas Limited 02/08/1999

California Approved 12/17/2001

Colorado Approved 11/05/1998

Connecticut Approved 10/30/1998

Delaware Approved 04/09/1999

District of Columbia Approved 12/18/1998

Florida Approved 04/13/1999

Georgia Approved 04/28/1999

Hawaii Approved 04/21/1999

Idaho Approved 09/11/1998

Illinois Approved 01/12/1999

Indiana Approved 04/21/1999

Iowa Approved 01/22/1999

Kansas Approved 03/29/1999

Kentucky Approved 04/08/1999

Louisiana Approved 02/02/1999

Maine Approved 06/10/1999

Maryland Approved 02/04/1999

Massachusetts Approved 02/17/1999

Michigan Approved 05/19/1999

Minnesota Approved 04/27/1999

Mississippi Approved 03/05/1999

Missouri Approved 04/15/1999

Montana Limited 01/29/1999

Nebraska Limited 04/21/1999

Nevada Approved 11/05/1998

New Hampshire Limited 04/30/1999

New Jersey Approved 05/06/1999

New Mexico Approved 04/14/1999

New York Approved 09/06/2002

U.S. States &Territories

Status Date Effective

North Carolina Approved 02/19/1999

North Dakota Limited 04/06/1999

Ohio Approved 04/27/1999

Oklahoma Approved 04/08/1999

Oregon Approved 02/19/1999

Pennsylvania Approved 04/23/1999

Puerto Rico Approved 05/22/2008

Rhode Island Approved 04/07/1999

South Carolina Approved 02/09/1999

South Dakota Approved 11/05/1998

Tennessee Approved 04/07/1999

Texas Limited 04/23/1999

Utah Approved 11/16/1998

Vermont Approved 04/30/1999

Virgin Islands Approved 06/01/2006

Virginia Approved 04/15/1999

Washington Approved 02/04/1999

West Virginia Approved 04/06/1999

Wisconsin Approved 04/19/1999

Wyoming Approved 02/08/1999






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.

This firm currently conducts 2 types of businesses.

Types of Business

Mutual fund underwriter or sponsor

Municipal securities broker






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 not refer or introduce customers to other brokers and dealers.






Firm Operations

Industry Arrangements

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

Name: HARTFORD ADMINISTRATIVE SERVICES COMPANY (HASCO)

Business Address: 690 LEE ROADWAYNE, PA 19087

Effective Date: 12/03/2012

Description: HASCO IS THE REGISTERED TRANSFER AGENT FOR THE OPEN-ENDINVESTMENT COMPANIES DISTRIBUTED BY THE REGISTRANT ANDMAINTAINS CERTAIN BOOKS AND RECORDS RELATED TO DIRECTACCOUNTS WHERE HARTFORD FUNDS DISTRIBUTORS, LLC MAY BENAMED AS BROKER DEALER OF RECORD AND/OR OVERSEESMAINTENANCE OF SUCH BOOKS & RECORDS BY SUB-TA/SERVICEPROVIDER.

Name: TERRANUA U.S. CORP

Business Address: 535 5TH AVENUE, 4TH FLOORNEW YORK, NY 10017


Description: TERRANUA U.S. CORP'S MY COMPLIANCE OFFICE TOOL IS AREGULATORY COMPLIANCE SOFTWARE PRODUCT THAT MAINTAINSAND TRACKS EMPLOYEE PERSONAL TRADING ACCOUNTS AND OTHERCERTIFICATIONS REQUIRED BY THE FIRM'S CODE OF ETHICS ANDOTHER POLICIES. THE CONTRACT IS CURRENTLY WITH HARTFORDFUNDS MANAGEMENT GROUP, INC (HFMG) WHICH IS HARTFORDFUNDS DISTRIBUTOR'S (HFD'S) DIRECT PARENT COMPANY AND HFDLEVERAGES THIS RELATIONSHIP.

Name: IRON MOUNTAIN INFORMATION MANAGEMENT, LLC

Business Address: 455 DUNKSFERRY RD.BENSALEM, PA 19020


Description: MAINTAINS ARCHIVED BOOKS & RECORDS FOR THE REGISTRANT ANDOPEN-END INVESTMENT COMPANIES DISTRIBUTED BY THEREGISTRANT BEYOND TWO YEARS, FOR THE REMAINING REQUIREDRETENTION PERIOD.

Name: ACCUITY, INC.

Business Address: 29 BROOK ST.LAKEVILLE, CT 06039






Firm Operations

Industry Arrangements (continued)

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

Business Address: 29 BROOK ST.LAKEVILLE, CT 06039


Description: ACCUITY, INC/NATIONAL REGULATORY SERVICES (NRS) SOFTWARE ISUSED TO MANAGE AND RETAIN THE FIRM'S RECORDS RELATING TOAPPROVAL OF COMMUNICATIONS WITH THE PUBLIC, AND OTHERINTERNAL/INSTITUTIONAL COMMUNICATIONS.

Name: THE HARTFORD FINANCIAL SERVICES GROUP, INC (HIG)

Business Address: ONE HARTFORD PLAZAHARTFORD, CT 06155


Description: HIG IS THE ULTIMATE PARENT COMPANY OF THE REGISTRANT ANDMAINTAINS CERTAIN BOOKS AND RECORDS RELATED TO SHAREDSERVICES ON BEHALF OF THE REGISTRANT.






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

07/29/2016

101 MONTGOMERY ST.27TH FLOORSAN FRANCISCO, CA 94104

130373

LATTICE STRATEGIES LLC is under common control with the firm.

LATTICE STRATEGIES, LLC AND THE APPLICANT ARE UNDER THE COMMONCONTROL OF HARTFORD FUNDS MANAGEMENT GROUP, INC.

Description:

Investment AdvisoryActivities:

Securities Activities:

Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:

Yes

No

No

12/31/2012


147746

HARTFORD FUNDS MANAGEMENT COMPANY, LLC is under common control with the firm.

HARTFORD FUNDS MANAGEMENT COMPANY, LLC AND THE APPLICANTARE UNDER THE COMMON CONTROL OF HARTFORD FUNDSMANAGEMENT GROUP, INC.

Description:



Country:

Foreign Entity:

Effective Date:

Business Address:

CRD #:






Firm Operations

Organization Affiliates (continued)HARTFORD FUNDS MANAGEMENT COMPANY, LLC AND THE APPLICANTARE UNDER THE COMMON CONTROL OF HARTFORD FUNDSMANAGEMENT GROUP, INC.

Description:

Yes

No

No

12/31/1996

ONE HARTFORD PLAZAHARTFORD, CT 06155

106699

HARTFORD INVESTMENT MANAGEMENT COMPANY is under common control with the firm.

HARTFORD INVESTMENT MANAGMENT COMPANY IS AN AFFILIATED FIRM,THAT IS ULTIMATELY OWNED BY THE SAME PARENT COMPANY, THEHARTFORD FINANCIAL SERVICES GROUP, INC.

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.

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§ 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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

Current Status: Final






Initiated By: FINRA

Principal Sanction(s)/ReliefSought:

Other

Date Initiated: 02/07/2013

Docket/Case Number: 2010024617701

Principal Product Type: Mutual Fund(s)

Other Product Type(s):

Allegations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





https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2010024617701



Other

Other Sanction(s)/ReliefSought:

N/A

Resolution Date: 02/07/2013

Resolution:

Other Sanctions Ordered:

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS,THEREFORE IT IS CENSURED AND FINED $100,000, JOINTLY ANDSEVERALLY. FINE PAID IN FULL ON 2/15/13.

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

No

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Acceptance, Waiver & Consent(AWC)

iReporting Source: Firm

Allegations: BETWEEN FEB. 2008-09 (THE "RELEVANT PERIOD"), HIFSCO APPROVED ABROCHURE CALLED "STAYING AHEAD OF THE CURVE" WHICH WASDISTRIBUTED BY HIFSCO'S AFFILIATED WHOLESALE BROKER DEALER,HARTFORD LIFE DISTRIBUTORS, TO RETAIL SELLING FIRMS (THE "BROCHURE"). THE BROCHURE DISCUSSED THE HARTFORD'S FLOATINGRATE FUND (THE "FUND") WHICH INVESTED IN THE BANK LOAN MARKET .HIFSCO SERVED AS REGISTERED INVESTMENT ADVISOR, PRINCIPALUNDERWRITER AND EXCLUSIVE SELLING AGENT FOR THE FUND. FINRAALLEGED THAT THE BROCHURE MADE CERTAIN STATEMENTS REGARDINGTHE FUND THAT WERE UNWARRANTED AND MISLEADING IN LIGHT OFCHANGING CONDITIONS IN THE BANK LOAN MARKET DURING THERELEVANT PERIOD IN VIOLATION OF FINRA RULE 2010, NASD RULES 2110AND 2210. FINRA ALSO ALLEGED THAT HIFSCO'S SUPERVISORYPROCEDURES AND SYSTEMS WERE NOT REASONABLY DESIGNED TOENSURE THAT THE RELEVANT INFORMATION AND MARKET DATA ABOUTTHE FUND WAS CONVEYED TO THE APPROPRIATE INDIVIDUALSRESPONSIBLE FOR UPDATING THE BROCHURE DURING THE RELEVANTPERIOD IN VIOLATION OF NASD'S RULES 3010(A) AND (B).







Initiated By: FINRA


Civil and Administrative Penalt(ies) /Fine(s)


CENSURE


Docket/Case Number: 2010024617701



BETWEEN FEB. 2008-09 (THE "RELEVANT PERIOD"), HIFSCO APPROVED ABROCHURE CALLED "STAYING AHEAD OF THE CURVE" WHICH WASDISTRIBUTED BY HIFSCO'S AFFILIATED WHOLESALE BROKER DEALER,HARTFORD LIFE DISTRIBUTORS, TO RETAIL SELLING FIRMS (THE "BROCHURE"). THE BROCHURE DISCUSSED THE HARTFORD'S FLOATINGRATE FUND (THE "FUND") WHICH INVESTED IN THE BANK LOAN MARKET .HIFSCO SERVED AS REGISTERED INVESTMENT ADVISOR, PRINCIPALUNDERWRITER AND EXCLUSIVE SELLING AGENT FOR THE FUND. FINRAALLEGED THAT THE BROCHURE MADE CERTAIN STATEMENTS REGARDINGTHE FUND THAT WERE UNWARRANTED AND MISLEADING IN LIGHT OFCHANGING CONDITIONS IN THE BANK LOAN MARKET DURING THERELEVANT PERIOD IN VIOLATION OF FINRA RULE 2010, NASD RULES 2110AND 2210. FINRA ALSO ALLEGED THAT HIFSCO'S SUPERVISORYPROCEDURES AND SYSTEMS WERE NOT REASONABLY DESIGNED TOENSURE THAT THE RELEVANT INFORMATION AND MARKET DATA ABOUTTHE FUND WAS CONVEYED TO THE APPROPRIATE INDIVIDUALSRESPONSIBLE FOR UPDATING THE BROCHURE DURING THE RELEVANTPERIOD IN VIOLATION OF NASD'S RULES 3010(A) AND (B).


Resolution:


Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, THE FIRM CONSENTEDTO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF FINDINGS. THEFIRM WAS CENSURED AND FINED $100,000 JOINTLY AND SEVERALLY WITHFORMERLY AFFILIATED HARTFORD LIFE DISTRIBUTORS, LLC N/K/AFORETHOUGHT DISTRIBUTORS, LLC. THE FINE WAS PAID TO FINRA ON2/15/13.

Sanctions Ordered: CensureMonetary/Fine $100,000.00

Acceptance, Waiver & Consent(AWC)

Disclosure 2 of 3

i

Reporting Source: Regulator

Allegations: SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8750, SECURITIESEXCHANGE ACT 34-54720, INVESTMENT ADVISERS RELEASE 40-2567,INVESTMENT COMPANY RELEASE 40-27549, NOVEMBER 8, 2006:HARTFORD INVESTMENT WILLFULLY VIOLATED SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT, SECTION 206(2) OF THE ADVISERS ACTAND SECTION 34(B) OF THE INVESTMENT COMPANY ACT.FROM AT LEAST JANUARY 2000 THROUGH DECEMBER 2003, HARTFORDINVESTMENT AND OTHER RESPONDENTS, MADE MATERIALMISREPRESENTATIONS AND OMITTED TO STATE MATERIAL FACTS TO THEFUNDS SHAREHOLDERS AND BOARDS OF DIRECTORS RELATING TOTHEIR USE OF $51 MILLION OF FUND ASSETS IN THE FORM OF DIRECTEDBROKERAGE COMMISSIONS TO SATISFY FINANCIAL OBLIGATIONS TOCERTAIN BROKER-DEALERS FOR THE MARKETING AND DISTRIBUTION OFTHE FUNDS.






https://www.finra.org/rules-guidance/oversight-enforcement/finra-disciplinary-actions?search=2010024617701


Initiated By: UNITED STATES SECURITIES AND EXCHANGE COMMISSION


Cease and Desist



Docket/Case Number: 3-12476



SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8750, SECURITIESEXCHANGE ACT 34-54720, INVESTMENT ADVISERS RELEASE 40-2567,INVESTMENT COMPANY RELEASE 40-27549, NOVEMBER 8, 2006:HARTFORD INVESTMENT WILLFULLY VIOLATED SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT, SECTION 206(2) OF THE ADVISERS ACTAND SECTION 34(B) OF THE INVESTMENT COMPANY ACT.FROM AT LEAST JANUARY 2000 THROUGH DECEMBER 2003, HARTFORDINVESTMENT AND OTHER RESPONDENTS, MADE MATERIALMISREPRESENTATIONS AND OMITTED TO STATE MATERIAL FACTS TO THEFUNDS SHAREHOLDERS AND BOARDS OF DIRECTORS RELATING TOTHEIR USE OF $51 MILLION OF FUND ASSETS IN THE FORM OF DIRECTEDBROKERAGE COMMISSIONS TO SATISFY FINANCIAL OBLIGATIONS TOCERTAIN BROKER-DEALERS FOR THE MARKETING AND DISTRIBUTION OFTHE FUNDS.


Resolution:

Other Sanctions Ordered: UNDERTAKINGS: A. THE RESPONDENTS FORMED A DISCLOSURE REVIEWCOMMITTEE DESIGNED TO ENSURE THAT PROSPECTUS AND SAIDISCLOSURES FOR INVESTMENT PRODUCTS ARE ACCURATE,APPROPRIATE, TIMELY AND, WHERE APPROPRIATE, CONSISTENT. THECOMMITTEE INCLUDES SENIOR BUSINESS LEADERS, COMPLIANCEOFFICERS AND ATTORNEYS.B. THE RESPONDENTS HAVE APPOINTED A SENIOR LEVEL EMPLOYEE TOIMPLEMENT WRITTEN POLICIES AND PROCEDURES.WITHIN 90 DAYS OF THE ENTRY OF THE ORDER, THE RESPONDENTSSHALL APPOINT A SENIOR LEVEL EMPLOYEE RESPONSIBLE FOROVERSIGHT OF RELATED COMPLIANCE MATTERS. SHALL ANNUALLYSUBMIT, FOR REVIEW AND APPROVAL ANY CHANGES IN THEDISCLOSURES IN FUNDS' PROSPECTUSES AND ESTABLISH AN INTERNALCOMPLIANCES CONTROLS COMMITTEE.

Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THISORDER; ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIESACT, SECTION 15(B) OF THE EXCHANGE ACT, SECTIONS 203(E) AND 203(K)OF THE ADVISERS ACT, AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENTCOMPANY ACT, IT IS HEREBY ORDERED THAT: HARTFORD INVESTMENT ISCENSURED.RESPONDENT HARTFORD INVESTMENT CEASE AND DESIST FROMCOMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT, SECTION 206(2) OF THE ADVISERS ACTAND SECTION 34(B) OF THE INVESTMENT COMPANY ACT. WITHIN 30 DAYSOF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT IN THE AMOUNT OF$40 MILLION AND CIVIL MONEY PENALTIES IN THE AMOUNT OF $15MILLION, FOR WHICH RESPONDENTS SHALL BE JOINTLY AND SEVERALLYLIABLE. THE RESPONDENTS SHALL PAY THE ENTIRE $55 MILLION TO THEAFFECTED HARTFORD FUNDS.

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

No

Sanctions Ordered: CensureMonetary/Fine $15,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Order






Sanction Details: WITHOUT ADMITTING OR DENYING THE FINDINGS, RESPONDENTCONSENTED TO THE DESCRIBED SANCTIONS AND TO THE ENTRY OF THISORDER; ACCORDINGLY, PURSUANT TO SECTION 8A OF THE SECURITIESACT, SECTION 15(B) OF THE EXCHANGE ACT, SECTIONS 203(E) AND 203(K)OF THE ADVISERS ACT, AND SECTIONS 9(B) AND 9(F) OF THE INVESTMENTCOMPANY ACT, IT IS HEREBY ORDERED THAT: HARTFORD INVESTMENT ISCENSURED.RESPONDENT HARTFORD INVESTMENT CEASE AND DESIST FROMCOMMITTING OR CAUSING ANYVIOLATIONS AND ANY FUTURE VIOLATIONS OF SECTIONS 17(A)(2) AND17(A)(3) OF THE SECURITIES ACT, SECTION 206(2) OF THE ADVISERS ACTAND SECTION 34(B) OF THE INVESTMENT COMPANY ACT. WITHIN 30 DAYSOF THE ENTRY OF THIS ORDER, PAY DISGORGEMENT IN THE AMOUNT OF$40 MILLION AND CIVIL MONEY PENALTIES IN THE AMOUNT OF $15MILLION, FOR WHICH RESPONDENTS SHALL BE JOINTLY AND SEVERALLYLIABLE. THE RESPONDENTS SHALL PAY THE ENTIRE $55 MILLION TO THEAFFECTED HARTFORD FUNDS.

Regulator Statement SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8752, NOVEMBER 16,2006: BASED ON THE REPRESENTATIONS IN THE RESPONDENT'S MARCH16, 2006 REQUEST LETTER, THE COMMISSION HAS DETERMINED THAT,PURSUANT TO RULE 602(E), A SHOWING OF GOOD CAUSE HAD BEENMADE AND THAT THE REQUEST FOR A WAIVER OF THE DISQUALIFICATIONSHOULD BE GRANTED. ACCORDINGLY, IT IS ORDERED THAT A WAIVER OFTHE DISQUALIFICATION PROVISION OF RULE 602(C)(3) UNDER THESECURITIES ACT RESULTING FROM THE ENTRY OF THE ORDER IS HEREBYGRANTED.

SEC ADMIN RELEASES 33-10438, 34-82151, IA RELEASE 40-4813,INVESTMENT COMPANY ACT RELEASE 40-32906, NOVEMBER 22, 2017: THERESPONDENT HAS SUBMITTED AN AMENDED OFFER OF SETTLEMENT,WHICH THE COMMISSION HAS DETERMINED TO ACCEPT, PROPOSING TOMODIFY THE COMMISSION'S 2006 ORDER TO: RELIEVE THE RESPONDENTOF THE OBLIGATION TO MAINTAIN A DISCLOSURE REVIEW COMMITTEE INACCORDANCE WITH PARAGRAPH 35.A OF THE 2006 ORDER; RELIEVE THERESPONDENT OF THE OBLIGATION TO MAINTAIN AN INTERNALCOMPLIANCE CONTROLS COMMITTEE IN ACCORDANCE WITHPARAGRAPHS 36.D - 36.H OF THE 2006 ORDER; MODIFY THEREQUIREMENTS REGARDING REVENUE SHARING POLICIES INACCORDANCE WITH PARAGRAPH 35.B OF THE 2006 ORDER; AND MODIFYTHE REQUIREMENTS REGARDING ANNUAL COMPLIANCE TRAINING INACCORDANCE WITH PARAGRAPH 36.I OF THE 2006 ORDER.SOLELY FOR PURPOSES OF THESE PROCEEDINGS AND ANY OTHERPROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TOWHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING ORDENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'SJURISDICTION OVER THEM AND THE SUBJECT MATTER OF THESEPROCEEDINGS, WHICH ARE ADMITTED, RESPONDENTS CONSENT TO THEENTRY OF THIS ORDER MODIFYING ORDER INSTITUTING ADMINISTRATIVEAND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, ANDIMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDERPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, SECTIONS 203(E) AND203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, AND SECTIONS 9(B)AND 9(F) OF THE INVESTMENT COMPANY ACT OF 1940.

ACCORDINGLY, IT IS HEREBY ORDERED THAT THE RELEVANTPARAGRAPHS OF THE 2006 ORDER BE MODIFIED. ALL OTHER PROVISIONSOF THE 2006 ORDER REMAIN IN EFFECT.






SEC ADMINISTRATIVE PROCEEDING RELEASE 33-8752, NOVEMBER 16,2006: BASED ON THE REPRESENTATIONS IN THE RESPONDENT'S MARCH16, 2006 REQUEST LETTER, THE COMMISSION HAS DETERMINED THAT,PURSUANT TO RULE 602(E), A SHOWING OF GOOD CAUSE HAD BEENMADE AND THAT THE REQUEST FOR A WAIVER OF THE DISQUALIFICATIONSHOULD BE GRANTED. ACCORDINGLY, IT IS ORDERED THAT A WAIVER OFTHE DISQUALIFICATION PROVISION OF RULE 602(C)(3) UNDER THESECURITIES ACT RESULTING FROM THE ENTRY OF THE ORDER IS HEREBYGRANTED.

SEC ADMIN RELEASES 33-10438, 34-82151, IA RELEASE 40-4813,INVESTMENT COMPANY ACT RELEASE 40-32906, NOVEMBER 22, 2017: THERESPONDENT HAS SUBMITTED AN AMENDED OFFER OF SETTLEMENT,WHICH THE COMMISSION HAS DETERMINED TO ACCEPT, PROPOSING TOMODIFY THE COMMISSION'S 2006 ORDER TO: RELIEVE THE RESPONDENTOF THE OBLIGATION TO MAINTAIN A DISCLOSURE REVIEW COMMITTEE INACCORDANCE WITH PARAGRAPH 35.A OF THE 2006 ORDER; RELIEVE THERESPONDENT OF THE OBLIGATION TO MAINTAIN AN INTERNALCOMPLIANCE CONTROLS COMMITTEE IN ACCORDANCE WITHPARAGRAPHS 36.D - 36.H OF THE 2006 ORDER; MODIFY THEREQUIREMENTS REGARDING REVENUE SHARING POLICIES INACCORDANCE WITH PARAGRAPH 35.B OF THE 2006 ORDER; AND MODIFYTHE REQUIREMENTS REGARDING ANNUAL COMPLIANCE TRAINING INACCORDANCE WITH PARAGRAPH 36.I OF THE 2006 ORDER.SOLELY FOR PURPOSES OF THESE PROCEEDINGS AND ANY OTHERPROCEEDINGS BROUGHT BY OR ON BEHALF OF THE COMMISSION, OR TOWHICH THE COMMISSION IS A PARTY, AND WITHOUT ADMITTING ORDENYING THE FINDINGS HEREIN, EXCEPT AS TO THE COMMISSION'SJURISDICTION OVER THEM AND THE SUBJECT MATTER OF THESEPROCEEDINGS, WHICH ARE ADMITTED, RESPONDENTS CONSENT TO THEENTRY OF THIS ORDER MODIFYING ORDER INSTITUTING ADMINISTRATIVEAND CEASE-AND-DESIST PROCEEDINGS, MAKING FINDINGS, ANDIMPOSING REMEDIAL SANCTIONS AND A CEASE-AND-DESIST ORDERPURSUANT TO SECTION 8A OF THE SECURITIES ACT OF 1933, SECTION15(B) OF THE SECURITIES EXCHANGE ACT OF 1934, SECTIONS 203(E) AND203(K) OF THE INVESTMENT ADVISERS ACT OF 1940, AND SECTIONS 9(B)AND 9(F) OF THE INVESTMENT COMPANY ACT OF 1940.

ACCORDINGLY, IT IS HEREBY ORDERED THAT THE RELEVANTPARAGRAPHS OF THE 2006 ORDER BE MODIFIED. ALL OTHER PROVISIONSOF THE 2006 ORDER REMAIN IN EFFECT.

iReporting Source: Firm

Initiated By: SECURITIES AND EXCHANGE COMMISSION


Disgorgement


CEASE AND DESIST, UNDERTAKING, CENSURE, CIVIL AND ADMINISTRATIVEPENALTIES


Docket/Case Number: 3-12476


Other Product Type(s): THE HARTFORD MUTUAL FUNDS AND HARTFORD HLS SERIES FUNDS

Allegations: THE SEC ALLEGED THAT HARTFORD INVESTMENT FINANCIAL SERVICES,LLC (HIFS) AND HL INVESTMENT ADVISORS (HL ADVISORS) VIOLATEDSECTIONS 17(A)(2) AND (3) OF THE SECURITIES ACT OF 1933, SECTION206(2) OF THE INVESTMENT ADVISERS ACT OF 1940, AND SECTION 34(B)OF THE INVESTMENT COMPANY ACT OF 1940 THROUGHMISREPRESENTATIONS OR OMISSIONS OF FACT CONCERNING THE USEOF DIRECTED BROKERAGE IN CONNECTION WITH THE MARKETING ANDDISTRIBUTION OF HARTFORD MUTUAL FUNDS AND ANNUITIES. THE SECALLEGED THAT HARTFORD SECURITIES DISTRIBUTION COMPANY, INC.(HSD) CAUSED AND AIDED AND ABETTED THE ALLEGED VIOLATIONS BYHIFS AND HL ADVISORS OF SECTIONS 17(A)(2) AND (3) OF THE SECURITIESACT OF 1933 AND SECTION 206(2) OF THE INVESTMENT ADVISERS ACT OF1940.


Resolution: Decision & Order of Offer of Settlement25©2020 FINRA. All rights reserved. Report about HARTFORD FUNDS DISTRIBUTORS, LLC






Resolution:

Other Sanctions Ordered: HIFS, HL ADVISORS AND HSD HAVE VOLUNTARILY UNDERTAKEN OROTHERWISE AGREED TO: (1.) FORM A DISCLOSURE REVIEW COMMITTEEDESIGNED TO ENSURE THAT ALL PROSPECTUS AND SAI DISCLOSURESFOR INVESTMENT PRODUCTS ARE ACCURATE; STRENGTHEN OVERSIGHTOVER COMPLIANCE MATTERS RELATED TO PREVENTING AND DETECTINGCONFLICTS OF INTERESTS, BREACHES OF FIDUCIARY DUTY, ANDVIOLATION OF FEDERAL SECURITIES LAWS RELATED TO INVESTMENTPRODUCTS; (2.) ENSURE THE RESPONDENTS' BOARDS OF DIRECTORSREVIEW AND APPROVE DISCLOSURES CONCERNING CERTAIN PAYMENTSMADE TO BROKER DEALERS AND OTHER INTERMEDIARIES; AND (3.)STRENGTHEN OVERALL COMPLIANCE OVERSIGHT PROVIDED WITHINHIFS, HL ADVISORS AND HSD.

Sanction Details: SANCTION DETAIL: IF SUSPENDED, ENJOINED OR BARRED, PROVIDEDURATION INCLUDING START DATE AND CAPACITIES AFFECTED (GENERALSECURITIES PRINCIPAL, FINANCIAL OPERATIONS PRINCIPAL, ETC.). IFREQUALIFICATION BY EXAM/RETRAINING WAS A CONDITION OF THESANCTION, PROVIDE LENGTH OF TIME GIVEN TO REQUALIFY/RETRAIN,TYPE OF EXAM REQUIRED AND WHETHER CONDITION HAS BEENSATISFIED. IF DISPOSITION RESULTED IN A FINE, PENALTY, RESTITUTION,DISGORGEMENT OR MONETARY COMPENSATION, PROVIDE TOTALAMOUNT, PORTION LEVIED AGAINST APPLICANT OR CONTROL AFFILIATE,DATE PAID AND IF ANY PORTION OF PENALTY WAS WAIVED:THE RESPONDENTS ARE REQUIRED TO PAY DISGORGEMENT OF $40MILLION AND CIVIL MONETARY PENALTIES OF $15 MILLION TO THEAFFECTED HARTFORD MUTUAL FUNDS WITHIN 30 DAYS OF NOVEMBER 8,2006.

Firm Statement ON NOVEMBER 8, 2006, THE SEC ISSUED AN ORDER THAT INSTITUTEDADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MADE CERTAINFINDINGS RELATIVE TO THESE PROCEEDINGS AND IMPOSED REMEDIALSANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 8AOF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIESEXCHANGE ACT OF 1934, SECTIONS 203(E) AND 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, AND SECTIONS 9(B) AND 9(F) OF THEINVESTMENT COMPANY ACT OF 1940. ALSO ON NOVEMBER 8, 2006, THERESPONDENTS SETTLED THIS MATTER WITHOUT ADMITTING OR DENYINGTHE FINDINGS SET FORTH IN THE SEC'S NOVEMBER 8, 2006 ORDER.PLEASE SEE RESPONSE TO QUESTION 12 FOR A DESCRIPTION OF THERESOLUTION OF THESE PROCEEDINGS. IN CONNECTION WITH SECADMINISTRATIVE PROCEEDING 3-12476, HIFS (NOW KNOWN AS HARTFORDFUNDS DISTRIBUTORS, LLC), HL ADVISORS AND HSD (COLLECTIVELY, "RESPONDENTS") SUBMITTED AN AMENDED OFFER OF SETTLEMENT("OFFER") TO REQUEST MODIFICATION OF THE SEC'S NOVEMBER 8, 2006ORDER ("2006 ORDER"). THIS OFFER WAS ACCEPTED BY THE SEC ONNOVEMBER 22, 2017 TO RELIEVE THE RESPONDENTS OF THE OBLIGATIONTO MAINTAIN A DISCLOSURE REVIEW COMMITTEE IN ACCORDANCE WITHPARAGRAPH 35.A OF THE 2006 ORDER AND AN INTERNAL COMPLIANCECONTROLS COMMITTEE IN ACCORDANCE WITH PARAGRAPHS 36.D - 36.HOF THE 2006 ORDER; MODIFY THE REQUIREMENTS REGARDING REVENUESHARING POLICIES IN ACCORDANCE WITH PARAGRAPH 35.B OF THE 2006ORDER; AND MODIFY THE REQUIREMENTS REGARDING ANNUALCOMPLIANCE TRAINING IN ACCORDANCE WITH PARAGRAPH 36.I OF THE2006 ORDER. THE PARAGRAPHS IDENTIFIED IN THE PRECEDINGSENTENCE WERE MODIFIED AND ALL OTHER PROVISIONS OF THE 2006ORDER REMAIN IN EFFECT. THE RESPONDENTS OBLIGATION TOMAINTAIN THE DISCLOSURE REVIEW COMMITTEE AND INTERNALCOMPLIANCE CONTROLS COMMITTEE IS UNTIL NOVEMBER 30, 2017.

Sanctions Ordered: CensureMonetary/Fine $15,000,000.00Disgorgement/RestitutionCease and Desist/Injunction

Decision & Order of Offer of Settlement






ON NOVEMBER 8, 2006, THE SEC ISSUED AN ORDER THAT INSTITUTEDADMINISTRATIVE AND CEASE-AND-DESIST PROCEEDINGS, MADE CERTAINFINDINGS RELATIVE TO THESE PROCEEDINGS AND IMPOSED REMEDIALSANCTIONS AND A CEASE-AND-DESIST ORDER PURSUANT TO SECTION 8AOF THE SECURITIES ACT OF 1933, SECTION 15(B) OF THE SECURITIESEXCHANGE ACT OF 1934, SECTIONS 203(E) AND 203(K) OF THEINVESTMENT ADVISERS ACT OF 1940, AND SECTIONS 9(B) AND 9(F) OF THEINVESTMENT COMPANY ACT OF 1940. ALSO ON NOVEMBER 8, 2006, THERESPONDENTS SETTLED THIS MATTER WITHOUT ADMITTING OR DENYINGTHE FINDINGS SET FORTH IN THE SEC'S NOVEMBER 8, 2006 ORDER.PLEASE SEE RESPONSE TO QUESTION 12 FOR A DESCRIPTION OF THERESOLUTION OF THESE PROCEEDINGS. IN CONNECTION WITH SECADMINISTRATIVE PROCEEDING 3-12476, HIFS (NOW KNOWN AS HARTFORDFUNDS DISTRIBUTORS, LLC), HL ADVISORS AND HSD (COLLECTIVELY, "RESPONDENTS") SUBMITTED AN AMENDED OFFER OF SETTLEMENT("OFFER") TO REQUEST MODIFICATION OF THE SEC'S NOVEMBER 8, 2006ORDER ("2006 ORDER"). THIS OFFER WAS ACCEPTED BY THE SEC ONNOVEMBER 22, 2017 TO RELIEVE THE RESPONDENTS OF THE OBLIGATIONTO MAINTAIN A DISCLOSURE REVIEW COMMITTEE IN ACCORDANCE WITHPARAGRAPH 35.A OF THE 2006 ORDER AND AN INTERNAL COMPLIANCECONTROLS COMMITTEE IN ACCORDANCE WITH PARAGRAPHS 36.D - 36.HOF THE 2006 ORDER; MODIFY THE REQUIREMENTS REGARDING REVENUESHARING POLICIES IN ACCORDANCE WITH PARAGRAPH 35.B OF THE 2006ORDER; AND MODIFY THE REQUIREMENTS REGARDING ANNUALCOMPLIANCE TRAINING IN ACCORDANCE WITH PARAGRAPH 36.I OF THE2006 ORDER. THE PARAGRAPHS IDENTIFIED IN THE PRECEDINGSENTENCE WERE MODIFIED AND ALL OTHER PROVISIONS OF THE 2006ORDER REMAIN IN EFFECT. THE RESPONDENTS OBLIGATION TOMAINTAIN THE DISCLOSURE REVIEW COMMITTEE AND INTERNALCOMPLIANCE CONTROLS COMMITTEE IS UNTIL NOVEMBER 30, 2017.

Disclosure 3 of 3

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Reporting Source: Firm

Initiated By: NATIONAL SECURITIES CLEARING CORPORATION (NSCC)


Civil and Administrative Penalt(ies) /Fine(s)



Docket/Case Number:



Allegations: NET CAPITAL OF HIFSCO WAS BELOW NSCC NET CAPITAL REQUIREMENTSIN A NUMBER OF PERIODS BETWEEN 1/1/2000 AND 12/31/2004. HIFSCO DIDNOT PROVIDE NSCC WITH A COPY OF THE 7/21/05 RULE 17A-11NOTIFICATION SUBMITTED TO THE SEC AND NASD. HIFSCO RECEIVEDNOTICE FROM NSCC ON 1/4/06 THAT A $5,000 FINE WOULD BE IMPOSED.HIFSCO RECEIVED AN INVOICE FROM THE NSCC FOR A $5,000 FINE ON2/7/06.








Resolution:


Sanction Details: A $5,000 FINE WAS PAID ON 2/9/06.

Firm Statement THIS IS A CLOSED MATTER.

Sanctions Ordered: Monetary/Fine $5,000.00

Other






End of Report

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HARTFORD FUNDS DISTRIBUTORS, LLC · 2020. 12. 20. · HARTFORD FUNDS DISTRIBUTORS, LLC CRD# 45995...

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