Complete text of SEC/Cabot Money Management can be found at:
sec.gov
The two most interesting things to note are the paragraph outling a March 23, 1987 Consent Decree. This action was a result of CMM failing to comply with the SEC's marketing/advertising regulations. The SEC felt that some of CMM's marketing material was potentially misleading and created confusion to investors.
" 3. On March 23, 1987, Cabot Money Management and Lutts
consented, without admitting or denying the findings, to the
entry of a Commission order finding that it violated Sections
206(1), (2) and (4) of the Advisers Act and Rules 206(4)-1(a)(2)
and 206(4)-1(a)(5) thereunder, imposing a censure, and ordering
them to comply with certain undertakings. See In the Matter of
Cabot Money Management, Inc. and Robert T. Lutts, Investment
Advisers Act Rel. No. 1063 (March 23, 1987). "
The text also shows that Timothy Lutts's explanation of the late 13F filings as oversights due to the rapid growth in assets in late 1995 is not accurate, as reported in the WSJ on August 16th. A further paragraph in the findings follows.
" 2. On the last trading day of July 1995, Cabot Money
Management and Lutts exercised investment discretion with respect
to accounts that held in excess of $100 million in publicly
traded equity securities described in Exchange Act Rule 13f-1(c)
as "Section 13(f) securities." Cabot Money Management's and
Lutts' holdings of "Section 13(f) securities" in discretionary
accounts also exceeded $100 million on the last trading day of
September, November and December 1995." |
