Closed-end funds (CEFs) offer investment advantages such as access to specialized or illiquid assets. They may, however, present unique risks based on their complexity, illiquidity, leverage, and/or investment in speculative assets. From March 2021 to at least February 2023, Colorado Financial failed to reasonably supervise and have reasonably designed policies and procedures regarding recommendations to purchase CEFs investing in high-yield, below-investment-grade debt securities, some of which were leveraged and all of which were inconsistent with customers’ investment profiles.