The SEC’s order finds that UBS failed to develop and implement policies and procedures reasonably designed to educate and train UBS registered representatives in connection with the sale of reverse convertible notes (RCNs) so that they could form a reasonable basis to make suitable recommendations. RCNs are complex securities that feature embedded derivatives whose performance is driven by the concept of implied volatility. Without adequate education and training, certain registered representatives made unsuitable recommendations in the sale of RCNs to certain retail customers in light of their investment profiles. UBS sold approximately $548 million in RCNs to more than 8,700 relatively ine...