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Contrary to their disclosures HCM Kurt Hovan and Lisa 7 Hovan secretly used soft dollars to pay the salary of Kurt Hovan s brother Edward. As part of the scheme Kurt Hovan and Lisa Hovan had Edward Hovan create a 26 supposed research firm Bolton Research LLC Bolton. In HCM s February 13 2008 Form ADV Kurt Hovan Lisa Hovan and HCM listed 15 one of HCM s consultants as a portfolio manager. In 2008 and 2009 HCM had soft dollar agreements with two br...
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