GlennCap LLC Censured by the SEC for Cherry-Picking

(CRD#: 290351)


GlennCap LLC is a Connecticut limited liability company with its principal place of business in Greenwich, Connecticut. GlennCap has been registered as an investment adviser with the State of Connecticut since January 3, 2018, except for a period from December 31, 2019 to January 14, 2020 when GlennCap failed to renew its registration because of insufficient funds in its renewals account. GlennCap has also been registered as an investment adviser with the State of 1 The findings herein are made pursuant to Respondents’ Offer of Settlement and are not binding on any other person or entity in this or any other proceeding. 3 New York since April 22, 2019, and on a conditional, restricted basis with the State of Texas since January 23, 2020. According to GlennCap’s Form ADV filed on March 24, 2023, GlennCap manages $14 million in assets for 75 clients, all of whom are individual investors.

Allegations of Misconduct

According to publicly available records released by the Securities and Exchange Commission (SEC), From at least January 2020 to March 2022, GlennCap, acting through Glenn, its sole owner and principal, engaged in undisclosed “cherry-picking,” a practice of fraudulently allocating profitable trades to favored accounts at the expense of other advisory clients. Glenn allocated a disproportionate number of trades with positive first-day returns to accounts belonging to certain favored clients, GlennCap (which Glenn owns), and another account that Glenn controlled, while allocating a disproportionate number of trades with negative first-day returns to other client accounts. Glenn accomplished this by executing block trades in GlennCap’s omnibus brokerage account and then waiting until later in the day, after he could see whether the positions had increased or decreased in value, to allocate the trades to either favored or disfavored accounts. Respondents also made false and misleading statements concerning their trading practices in GlennCap’s Forms ADV, Part 2A (“Brochures”), which were provided to clients and prospective clients. By virtue of this conduct, Respondents willfully violated Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act.

Accordingly, it is hereby ORDERED that:

  • Respondents GlennCap and Glenn cease and desist from committing or causing any violations and any future violations of Section 17(a) of the Securities Act, Section 10(b) of the Exchange Act and Rule 10b-5 thereunder, and Sections 206(1) and 206(2) of the Advisers Act.
  • Respondent GlennCap is censured.
  • Respondents shall, within 14 days of the entry of this Order, pay, jointly and severally, disgorgement of $2,743,616 and prejudgment interest of $251,357, and Respondent Glenn shall pay a civil money penalty in the amount of $500,000, to the Securities and Exchange Commission.


For a copy of the full SEC cease-and-desist order, click here.

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Financial advisors have a legal and regulatory obligation to recommend only suitable investments that are appropriate for their clients’ needs and objectives. Their employing brokerage firm has a legal and regulatory obligation to supervise the Financial Advisors’ sales practices and dealings with clients. To the extent any of these duties are breached, the customer may be entitled to a recovery of his or her investment losses.

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Customer-specific suitability requires that a member or associated person have a reasonable basis to believe that the recommendation is suitable for a particular customer based on that customer’s investment profile. Among the criteria that a financial advisor must evaluate to satisfy his or her customer-specific suitability obligations include the investor’s age, tax status, time horizon, liquidity needs, and risk tolerance; a client’s other investments, financial situation and needs, investment objectives, and any other information disclosed by the customer should also be considered.

The Wolper Law Firm represents investors nationwide in securities litigation and arbitration on a contingency fee basis. Matt Wolper, the Managing Principal of the Wolper Law Firm, is a trial lawyer who has handled hundreds of securities cases during his career involving a wide range of products, strategies and securities. Prior to representing investors, he was a partner with a national law firm, where he represented some of the largest banks and brokerage firms in the world in securities matters. We can be reached at (800) 931-8452 or by email at mwolper@wolperlawfirm.com.


Attorney Matthew Wolper

Attorney Matthew WolperMatt Wolper is a trial lawyer who focuses exclusively on securities litigation and arbitration. Mr. Wolper has handled hundreds of securities matters nationwide before the Financial Industry Regulatory Authority (FINRA), American Arbitration Association (“AAA”), JAMS, and in state and federal court. Mr. Wolper has handled and tried cases involving complex financial products and strategies ranging from traditional stocks and bonds to options, margin and other securities-based lending products, closed/open-end mutual funds, structured products, hedge funds, and penny stocks. [Attorney Bio]