had to pay redundant expenses without the knowledge of the undisclosed information of such conflicts of interest, both before and after investing in such foreign funds;                (3)  failing to

and former directors of EARTH had jointly acted, conspired, permitted, or helped another in making false entries or failing to enter material statement in relation of the debt, for the purpose of

from DAOLS’ failure to exercise due care and diligence in protecting the interests of the bondholders, including failing to verify existing encumbrances on the condominium units serving as collateral

and procedures as specified in the notification by failing to put in place an effective debenture underwriting system to categorize High Net Worth investors. SEC Act S.116 Settlement Committee

with the rules, conditions and procedures as specified in the notification by failing to put in place an effective debenture underwriting system to categorize High Net Worth investors. SEC Act S.116

, failed to comply with the rules, conditions and procedures as specified in the notification by failing to put in place an effective debenture underwriting system to categorize High Net Worth investors

, conditions and procedures as specified in the notification by failing to put in place an effective debenture underwriting system to categorize High Net Worth investors. SEC Act S.116 Settlement Committee

, conditions and procedures as specified in the notification by failing to put in place a sufficient and effective system for analyzing, reviewing and monitoring the quality of securities. SEC Act S.117

procedures as specified in the notification. In this regard, Bitazza failed to provide the management and operational data recording system by failing to present appropriate loan process and agreements to the

procedures as specified in the notification of the Capital Market Supervisory Board by failing to have a sufficient and effective system for executing securities transactions for the mutual fund. SEC Act S