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Alan Markfeld
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Dharmi is an excellent securities lawyer who understands the law as it pertains to these cases. She is extremely proactive and represents her clients well. I highly recommend Jacko and Dharmi.
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Danielle Martin
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I’ve had the privilege of working closely with this firm in my role as Chief Compliance Officer and I can confidently say they are an exceptional compliance partner. Their depth of experience is immediately evidentand they bring a level of practical knowledge. What I truly enjoy is their ability to translate complex regulatory requirements into plain English, often using real, everyday examples that make implementation far more manageable. They are also incredibly responsive and reliable. In a field where timing matters, their prompt communication and thoughtful guidance have been invaluable. If you’re looking for a compliance attorney who combines expertise, clarity, and professionalism, I highly recommend them.
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Curt Rocca
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Michelle and the team at Jacko Law Group have helped guide through a variety of critical circumstances as we ventured through the uncharted and unfamiliar territory of becoming and successfully operating as an RIA. I have particularly appreciated Michelle's personal involvement and genuine caring about us and our organization. She has been responsive and her counsel has been consistently on-point and helpful. She artfully guided us through our initial filing process and first SEC exam process - which went very well. Very grateful to Michelle and her team.
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Nicholas Di Paolo
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Michelle and her team were excellent to work with, front to back. They helped me to understand the challenges ahead and were always proactive in their consultation through every step of my transition. JLG truly know the wealth management industry very well and did a great job of understanding the challenges unique to my business. Without them, I can confidently say I would not have felt as comfortable through the transition as I did. Fortunately, that's not something that stops there - Michelle and her team have kept in touch to ensure that I'm on top of certain administrative issues, trends, and simply showing me that they care about my business and success. I look forward to continuing to work with them for many years to come.
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Margery Neis
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Dharmi Mehta was extremely helpful when my business partner and I transitioned to a new RIA firm. She and her staff were all very professional. Her guidance during our transition was invaluable. I highly recommend Dharmi and Jacko Law Group.
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Joseph Burwell
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Dharmi and Amandeep were a delight to work with. They assisted me with a claim and stuck with me the entire way through. Dharmi's advice was invaluable, and I was most impressed by her clear and professional communication. From beginning-to-end, both Dharmi and Amandeep kept me well informed. Their entire team are proud of their work and rightfully so. Thank you!
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Faruk Jaffer
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My mentor once told me that a good attorney is worth their weight in gold — and that couldn't be more true of Michelle and Amanda. Their expertise, professionalism, and responsiveness were top notch every step of the way. It's rare to find legal partners who are not only sharp and thorough, but also genuinely invested in your success. I’m grateful for their guidance and highly recommend them to anyone seeking trusted legal counsel.
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everistus etafo
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It is my great Privilege to share my Review of what Atty Dharmi Mehta of Jacko Law Group did for me and by extension for my family. From the first time complimentary conversation we had having spoken to several other Lawyers ,l knew she was the right person for the Job .Because of her background as a former RR ,she was professional,kind, Empathetic,listened and was focused on fighting for me. From a potential of been terminated with cause ,l was able to walk away with a clean U5 with a validation that l did nothing wrong except what was in the best Interest of my clients. I hope nobody ever has to go through what l have Experienced, but if you do ,you want Dharmi Mehta beside you .Rest assured your service Deserve 10 stars but this forum only allows 5. Me and my family are forever grateful and will make sure that any RR who needs an advocate will know about you . Everistus Etafo
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Karen Althaus
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I have worked with Jacko Law Group for 2 different business situations that necessitated an attorney. In both cases, the team was very thorough & competent. Their attention to our situation and the extra effort they put into our case(s) was very much appreciated. I would highly recommend Jacko Law Group!
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  • HCR Advisors Settles SEC Charges on Failure to Supervise and Implement Compliance-Related Policies and Procedures

Annual Reviews & Risk Assessments

HCR Advisors Settles SEC Charges on Failure to Supervise and Implement Compliance-Related Policies and Procedures

A businessman in a suit leaning over a desk | Jacko Law Group, PC
HCR Wealth Advisors agreed to a cease-and-desist order, a $220,000 penalty, and a $328,912 payment to its harmed clients in order to settle charges with the U.S. Securities and Exchange Commission (“SEC”). The SEC complaint alleged that HCR had failed to reasonably supervise and implement its own compliance-related policies and procedures in response to fraudulent actions by one of its former investment advisors. In parallel criminal proceedings, adviser Jeremy Joseph Drake plead guilty to defrauding two of his clients and committing wire fraud. He was sentenced to 30 months custody and ordered to pay $1.2 million. Drake had managed over $50 million in assets for more than 20 HCR clients during his tenure at the firm.

Management Fee Fraud and Misappropriation of Client Funds

Over the course of three years, Drake defrauded a married couple by telling them they were paying a management fee at a VIP client rate of 0.15 to 0.20 percent of their assets under management. In reality, the clients paid the traditional HCR client fee of 1 percent of their managed assets. The difference in rates led to them pay an excess of $1.2 million more in fees than Drake falsely promised them over the course of the three-year period. Of the $1.2 million received, HCR paid nearly $900,000 of it to Drake and the firm retained the remaining $300,000. Drake further misappropriated over $200,000 from four clients, transferring the funds to accounts belonging to a failing restaurant to which he had obtained 3 percent ownership interest. As part of the scheme to mislead his clients, Drake created false and misleading documents and statements. He also created a misleading email address, which he used to send emails from someone he claimed was a manager at the firm.

Failure to Supervise and Implement Policies and Procedures

The SEC Order found that HCR violated the Advisers Act by failing to engage in reasonable supervision over Drake and also violated the act by failing to implement established policies and procedures designed to prevent violations of the Advisers Act. HCR had been warned by an outside compliance consultant that Drake might attempt to use client funds in order to fund the restaurant; however, HCR did not investigate further to determine the source of the investments or monitor accounts related to the restaurant despite the consultant’s advice. Furthermore, HCR did not follow its policies and procedures by monitoring Drake’s activities and emails for potential violations of the company policies and procedures or federal securities laws. Though HCR had policies and procedures in place to conduct prompt, thorough and fair reviews of all client complaints, the firm failed to do so when it received two client complaints from Drake’s clients. Instead of performing an investigation and documenting its findings, allegedly the firm only relied upon Drake’s own false description of his actions. Read the full SEC Press Release here.

Let our Experience Work for You

Internal controls are of paramount importance for they serve to detect circumvention of firm policies and federal securities laws. Though it can be difficult to sometimes detect if someone is actively committing fraud, this risk can be mitigated by investment advisers implementing robust supervisory programs, educating their employees and implementing effective policies and procedures. It is crucial for firms to follow up on red flags, track deceptive behaviors, and document investigations. Jacko Law Group, PC is highly experienced in developing supervisory internal controls (e.g., policies and procedures) and risk mitigation techniques for detecting “red flags” so that areas of concern, such as suspicious activities or complaints can be timely investigated and illegal activity stopped.  For more information, contact our team of attorneys today.

About the author

Managing Partner and CEO

Michelle L. Jacko, Esq. is the Managing Partner and CEO of Jacko Law Group, PC (“JLG”), which offers securities, corporate, real estate, and employment law counsel to broker-dealers, investment advise...

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