In addition:
As an initial matter, the Complaint alleges that Signature and the other Defendants conspired to carry out the fraudulent dividend distribution scheme, and thus many of the allegations in the Complaint apply to all three Defendants…
I just don't buy it. What monetary interest would Signature have in participating in such a conspiracy? None that I can see, unless COR is prepared to go further, and allege that money changed hands under the table.
I believe Signature was negligent. It should have made an effort to find out more about its client, "Adam Carter". It should have investigated the background of the GIM note. It should perhaps have notified FINRA or the SEC of those very large issuances during the interim period. But I don't think COR will ever succeed in proving that Bogutski plotted to defraud COR. The burden of proof for that allegation is on COR, and I don't begin to see how COR can come up with anything convincing.