October 29, 2024
Failure to Supervise
ChapmanAlbin is investigating Horter Investment Management, LLC, a Cincinnati-based investment adviser, and its founder and CEO, Drew K. Horter, following an SEC order imposing sanctions for failing to supervise an investment adviser representative (IAR) who misappropriated client funds. The SEC’s findings allege that Horter and his firm did not establish adequate supervisory policies or follow existing protocols, allowing an IAR to misuse client assets.
According to the SEC, between November 2015 and March 2017, the IAR misappropriated $728,001 from clients, using the funds for personal expenses and other unauthorized purposes. The complaint highlights that Horter Investment Management’s oversight structure was insufficient, particularly for remote advisers. The SEC has ordered a $100,000 civil penalty for the firm and a $50,000 penalty for Horter, alongside a six-month supervisory suspension for Horter.
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