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JPMorgan Chase agreed to pay $151 million in penalties and voluntary transactions to investors to settle five enforcement actions the Securities and Exchange Commission made public Thursday.

In the most impactful order, the bank’s securities unit made misleading disclosures to brokerage customers who invested in JPMorgan’s “Conduit” slate of private funds products, the SEC found.

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 JPMorgan did not tell customers it had complete discretion over when and how many shares would be sold, the SEC said. 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.

JPMorgan agreed to pay $90 million to more than 1,500 Conduit investor accounts and, further, to pay a $10 million fine to the SEC, which will distribute that money to Conduit investors, too.

JPMorgan self-reported to the SEC that certain investors “had complained as a result of the failure to promptly sell certain shares,” the agency said.

The bank agreed to pay $45 million in penalties to resolve allegations that its securities unit failed to disclose the financial incentive JPMorgan and some of its financial advisers would receive by recommending its Portfolio Management Program over third-party managed advisory programs. Assets under management in the program’s strategies nearly tripled, between July 2017 and last month, to more than $30 billion, the SEC said.

JPMorgan will pay $5 million to settle allegations that its investment management unit caused $4.3 billion in prohibited joint transactions, which benefited a foreign money market fund for which JPMorgan served as a delegated portfolio manager.

The bank will pay a further $1 million over another type of prohibited transaction: principal trades. Between July 2019 and March 2021, JPMorgan’s investment management unit engaged in or caused 65 prohibited principal trades with a total notional value of roughly $8.2 billion, the SEC found. 

During that time, a JPMorgan portfolio manager directed an unaffiliated broker-dealer to buy commercial paper or short-term fixed income securities from JPMorgan’s securities unit, which the bank’s investment management unit then purchased on behalf of one of its clients, the SEC said. Principal trades are generally prohibited to avoid undisclosed conflicts of interest. JPMorgan notified the SEC of the prohibited trades when the bank learned about them and voluntarily provided documentation promptly, the agency said.