The SEC announced settled charges against Jordan/Zalaznick Advisers, Inc., the primary filing adviser for an umbrella registration with multiple relying advisers, for failing to implement compliance policies and procedures to supervise its relying advisers. A condition of umbrella registration is that every adviser under the “umbrella” operates under a single code of ethics and a unified compliance program administered by a single chief compliance officer. Each relying adviser, its employees, and persons acting on its behalf are subject to the filing adviser’s supervision and control. As part of its remedial efforts, the firm proactively engaged an independent compliance consultant to conduct ongoing email monitoring, provide periodic employee compliance training, and hired an additional person to join its compliance team. Nevertheless, the firm agreed to pay a $150,000 civil penalty.