In New Orleans, Equitas Capital Advisors and Equitas Partners, as well as owner David Thomas Jr., chief compliance officer Susan Christina, and former owner and chief compliance officer Stephen Derby Gisclair, failed to adopt and implement written compliance policies and procedures and conduct annual compliance reviews to satisfy the Compliance Rule, the SEC charges. What's more, the Equitas firms made false and misleading disclosures about historical performance, compensation, and conflicts of interest, and "inadvertently yet repeatedly" overbilled and underbilled their clients, according to the SEC. REPEATED WARNINGS Many of these violations occurred despite warnings by SEC examiners during examinations of the Equitas firms in 2005, 2008, and 2011, according to the agency. The firms, Thomas, and Gisclair failed to disclose these deficiencies to potential clients in response to questions in certain due diligence questionnaires or requests for proposals, the SEC says.