The Japan Securities and Exchange Surveillance Commission has recommended that the Prime Minister and the Commissioner of the Financial Services Agency take administrative action against Takumi Investment Advisors Co., Ltd. after an inspection found serious misconduct in its discretionary investment management and investment advisory businesses. The Commission found the firm kept placing client money into bonds issued by Company A and ultimately invested in B Medical Corporation even as Takumi's chief investment officer was siphoning funds from B Medical, then used JPY 80 million from four clients to meet redemption payments to 24 existing investors instead of investing as represented. In the Commission's view, the conduct amounted to serious breaches of the firm's duty of loyalty to discretionary clients. The inspection covered 17 discretionary clients with JPY 240 million under contract, of which JPY 210 million was placed in Company A bonds and then invested in B Medical Corporation. The Commission said the structure created acute conflicts of interest because Takumi's representative director also ran Company A and B Medical had previously owned more than 99% of Takumi, yet the firm continued the investment even after JPY 205 million was privately diverted from B Medical. Some clients later received reports describing stable bond investments that had not occurred, and the Commission also cited receipt of client money into bank accounts in Takumi's name, late or missing six-month investment reports, and failure to notify authorities after management became aware of the misconduct. Separately, the Commission found the firm advised 39 clients on RL360 Insurance Company Limited's Regular Savings Plan without sufficiently assessing whether the product could lawfully be handled in Japan given RL360 lacked investment management registration. It also found that Takumi's "Money Trouble Consultation Desk" website omitted required regulatory disclosures and used fictitious testimonials. In a related step, the Kanto Finance Bureau issued RL360 a warning letter for conducting financial instruments trading without registration.