Two affiliates of JPMorgan Chase & Co — JPMorgan Securities (JPMS), the firm’s brokerage unit, and JPMorgan Investment Management (JPMIM), which oversees its mutual funds — have agreed to pay $151m in combined civil penalties and voluntary payments to investors to settle four enforcement actions brought by the SEC.

The affiliates did so without admitting or denying the findings in the SEC’s orders, the regulator said in its press release.

The settlements were a part of five separate enforcement actions from the securities watchdog that alleged misleading disclosures to investors, breach of fiduciary duty, prohibited joint transactions and principal trades, and failures to make recommendations in the best interests of customers.

The SEC did not impose a penalty in one of the actions taken against JPMS, citing JPMS’s cooperation in the investigation and its remedial measures.

“JPMorgan’s conduct across multiple business lines violated various laws designed to protect investors from the risks of self-dealing and conflicts of interest,” said Sanjay Wadhwa, acting director of the SEC’s Division of Enforcement. “With today’s settlements, which include multiple self-reports and large voluntary payments to harmed investors, JPMorgan is being held accountable for its regulatory failures.”

Peek at a few orders

Here’s a glance at a few of the orders.

Conduit Private Funds Action 

In one of the orders, the agency alleged that the bank’s securities unit made misleading disclosures to brokerage customers who invested in JPMS’’s “Conduit” slate of private funds products.

The products pooled customer money and invested it in private equity or hedge funds that would later distribute shares of companies that went public. But JPMS did not tell customers it had complete discretion over when and how many shares would be sold, the SEC said.

And, at times, JPMorgan took months to sell the shares, exposing customers to market risk as the value of some shares dropped significantly, the agency said. JPMS agreed to pay $90m to more than 1,500 Conduit investor accounts and a $10m fine to the SEC, which will distribute that money to Conduit investors as well.

In that action, the SEC said JPMS violated Section 17(a)(2) of the Securities Act (inducing an offer or sale of any securities by means of any untrue statement of a material fact or omission making the statements misleading) and Section 17(a)(3) prohibiting in the offer or sale of securities from operating it as a fraud or deceit upon the purchaser.

Clone Mutual Funds Action

In another enforcement action, the SEC said JPMS, through its registered representatives, recommended certain mutual fund products to its retail brokerage customers when materially less expensive ETF products that offer the same investment portfolio to investors were also available on JPMorgan Securities’ platform, together with Clone Mutual Funds (Clone Pairs). Retail brokerage customers paid approximately $14.03m in higher fees expenses thereby, the SEC said.

The SEC said the firm violated Regulation Best Interest (Reg BI), and specifically its Care Compliance Obligation, which requires a broker-dealer to establish, maintain, and enforce written policies and procedures reasonably designed to achieve compliance with Reg BI under Exchange Act Rule 15l-1(a).

The firm was censured without a civil monetary penalty being imposed, thanks to JPMS voluntarily identifying the affected customers who purchased the mutual fund share classes that had higher fees than the ETFs during the relevant period. It has also completed full remediation for those customers, including reimbursing certain transactions that were not subject to Reg BI because they occurred before Reg BI’s compliance date.

Portfolio Management Program Action 

And in another action, the SEC said JPMS failed to fully and fairly disclose the financial incentive it and some of its financial advisers had when they recommended JPMS’s own Portfolio Management Program over third-party managed advisory programs offered by JPMS.

The SEC’s order found that JPMS violated SEC Rule 206(4)-7, for which the agency imposed a $45m penalty.