SEC Charges Massachusetts-Based Investment Adviser with Marketing, Books and Records, and Compliance Rule Violations

ADMINISTRATIVE PROCEEDING
File No. 3-22525

September 4, 2025 – The Securities and Exchange Commission today announced charges against Meridian Financial, LLC (“Meridian”), a Massachusetts-based registered investment adviser, for failing to comply with various provisions of the Investment Advisers Act of 1940 (the “Advisers Act”) concerning marketing, recordkeeping, the implementation of compliance policies and procedures, and the conducting of Meridian’s annual compliance review.

According to the SEC’s order, Meridian disseminated a website advertisement in which it claimed it “refuse[d] all conflicts of interest.” However, Meridian recognized various conflicts of interest inherent in the role as an investment adviser, including conflicts of interest disclosed in its Form ADV Part 2A brochure. As such, the SEC’s order finds Meridian violated the requirement that Meridian have a reasonable basis to believe that it would be able to substantiate the claim in its advertisement that it refused all conflicts of interest upon demand by the Commission. The SEC’s order also states that Meridian failed to maintain copies of all of its advertisements, including advertisements that appeared on its website, for the periods required. In addition, the SEC’s order describes violations of the Compliance Rule. Specifically, Meridian failed to implement its policies and procedures concerning reliance on third parties for recordkeeping and for the conducting of an annual compliance review. Meridian also failed to conduct an annual review of its compliance policies and procedures as required under the Advisers Act.

Meridian consented to the entry of the SEC’s order finding that it violated Sections 204(a) and 206(4) of the Advisers Act and Rules 204-2(a)(11), 206(4)-1(a), and 206(4)-7 thereunder. In addition to a cease-and-desist order and censure, Meridian agreed to pay a $75,000 civil penalty and was ordered to engage in undertakings designed to correct the compliance failures identified.

The SEC’s investigation was conducted by Jonathan T. Menitove of the Division of Enforcement’s Asset Management Unit. The investigation was supervised by Colin Forbes and Corey Schuster of the Asset Management Unit. Charlies Liu and Eric Tso of the Division of Examinations in the Boston Regional Office assisted with the investigation.