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The Commission alleges that Envision and Headding violated Sections 206(1) and 206(2) of the Investment Advisers Act. The Commission further alleges that Envision violated Section 204 of the Advisers Act and Rule 204 2 thereunder for failure to maintain books and records and that Headding aided and abetted those violations. The Commission seeks permanent injunctions cheap jerseys, disgorgement with prejudgment interest, and civil penalties..
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