The reasons, which are not intended to be exhaustive, include the following:
1) The firm’s decision that the Trust Company, as custodian of a SIBL CD, is not required to file the TDF form, and its further failure to advise clients of its decision or the client’s obligation to file the TDF form.
2) The firm’s purging of files and destruction of documents with knowledge of an ongoing SEC inquiry into the SIBL CD and the CD sales practices.
3) The firm’s continued use of historical performance data in its SAS (and therefore SIM) presentations that are known to be incorrect, or at least not verifiable, in representations to clients.
4) The firm’s strategy to rapidly expand the number of financial advisors has placed the focus away from the clients to one predicated on creating the appearance of liquidity for the firm.
Exclusive: Stanford Whistle Blower: http://sivg.org/article/SEC_Whistleblowers_2.html