The US Securities and Exchange Commission has issued a cease-and-desist order against three Raymond James entities for improperly charging advisory fees on inactive retail clients' accounts and charging too much commission for brokerage customer investments in certain unit investment trusts.

At various times between 2013 and 2018, the SEC alleges, Raymond James advisors failed to review the suitability of certain advisory accounts, despite having promised to do so on their Form ADV supplications and Part 2A brochures. They did not adopt policies and procedures reasonably designed to prevent violations concerning the suitability of fee-based advisory accounts and they overvalued certain assets that led them to charge excess advisory fees. Raymond James brokers failed to have a reasonable basis for recommending certain unit investment trust (UIT) transactions to their customers and failed to disclose the conflict of interest associated with earning greater compensation when recommending certain securities without providing applicable sales-load discounts to brokerage customers. These failures involved products sold and services provided to retail investors. Raymond James admits and denies nothing.

The details of the dormant accounts are particularly notable. Between 2013 and 2017, advisors failed to review 7,708 advisory accounts properly even though they had partaken in no securities trading activity for at least 12 months, in contravention of the firm's policies and procedures. The inactive accounts paid the advisors $4.9 million in advisory fees.

The order charges Raymond James & Associates and Raymond James Financial Services Advisors with breaking ss206(2) and 206(4) Investment Advisors Act 1940 and Rule 206(4)-7. It also charges Raymond James & Associates and Raymond James Financial Services with breaking ss17(a)(2) and (3) Securities Act 1933.  To settle the charges, the three firms agreed to be censured and to 'disgorge' allegedly ill-gotten gains of $12 million and to pay a $3 million civil penalty. They have agreed to pay off wronged investors.