The SEC charged dually registered broker-dealer/investment adviser, J.P. Morgan Securities LLC, and investment adviser, J.P. Morgan Investment Management Inc., in five separate enforcement actions for failures including misleading disclosures to investors, breach of fiduciary duty, prohibited joint transactions and principal trades, and failures to make recommendations in the best interest of customers. The firm agreed to pay a combined $151 million in voluntary disgorgement and civil penalties for the settled actions. The affiliated transaction cases do not appear to have involved actions intended at enriching the firm at the expense of clients or investors, and in fact, on their face appear to have been intended to benefit clients and investors. However, the defendants violated the affiliated and principal transaction provisions of Section 17 of the Investment Company Act and Section 206(3) and failed to comply with the technical requirements under such regulations.