Global Macro Asset Management LLC and Donald Cody Fined for Fee Disclosure Violations

NV Securities Admin Orders

Filed June 30th, 2025

Detected March 17th, 2026

Summary

The Nevada Securities Division has fined Global Macro Asset Management LLC and Donald Cody $2,950.23 for failing to properly disclose fees, resulting in client overcharges. The order resolves the administrative investigation into these activities.

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What changed

The Nevada Securities Division has issued an administrative order against Global Macro Asset Management LLC and its representative Donald Edmund Cody, imposing a total fine of $2,950.23. The respondents were found to have improperly disclosed fees charged to a client, leading to an overcharge. The order resolves the Division's administrative investigation into these specific activities, with the respondents consenting to the entry of the order and waiving their rights to a hearing and appeal.

Regulated entities, particularly investment advisers and representatives in Nevada, should review their fee disclosure practices to ensure compliance with the Nevada Uniform Securities Act and the Investment Advisers Act of 1940. Failure to properly disclose fees can result in overcharges and subsequent enforcement actions. While this order resolves the current investigation, the Division reserves the right to pursue further action for other unaddressed activities. Respondents must submit the total fine amount to the Nevada Secretary of State.

What to do next

Review and update fee disclosure policies and procedures to ensure full compliance with the Nevada Uniform Securities Act and the Investment Advisers Act of 1940.
Ensure all client fee overcharges are identified and rectified.
Submit the total fine amount of $2,950.23 to the Nevada Secretary of State by the effective date of the order.

Penalties

Total fine of $2,950.23 ($950.23 for inspection costs and $2,000.00 administrative order). Violation of the order may constitute a felony.

Source document (simplified)

STATE OF NEVADA

OFFICE OF THE SECRETARY OF STATE

SECURITIES DIVISION

1 STATE OF NEVADA WAY, 3RD FLOOR
LAS VEGAS, NEVADA 89119

In the Matter of:

GLOBAL MACRO ASSET
MANAGEMENT LLC (CRD #171568); and
DONALD EDMUND CODY, an Individual
(CRD #1200329),

Respondents.

TO:
Global Macro Asset Management LLC
c/o Donald Edmund Cody
3753 Howard Hughes Parkway, Suite 200
Las Vegas, NV 89169

WHEREAS, GLOBAL MACRO ASSET MANAGEMENT LLC, CRD No. 171568, is a
Nevada-based investment advisory firm located at 3753 Howard Hughes Parkway, Suite 200, Las
Vegas, NV 89169;

WHEREAS, DONALD EDMUND CODY, CRD No. 1200329, (Respondent Cody), is a
Nevada-based investor adviser representative for Global Macro Asset Management LLC;

WHEREAS, on August 30, 2024, the Nevada Securities Division (Division), pursuant to the
Administrator's authority under NRS § 90.410, commenced an inspection of Respondents to
determine their compliance with the Nevada Uniform Securities Act, the Investment Advisers Act of
1940, and the various rules and regulations promulgated thereunder;

WHEREAS, Respondents did not properly disclose fees charged to one client, resulting in an
overcharge in fees;

Respondents shall submit a check made payable to the Secretary of State in the amount of
$950.23 for its fee for the inspection of Respondents' records performed under NRS §
90.410. The $950.23 inspection costs are to be submitted to the Division herewith upon
signing of this Order.
All amounts submitted under this section shall be remitted to:
Nevada Secretary of State
c/o Eli Beauchamp
1 State of Nevada Way, 3rd Floor
Las Vegas, Nevada 89119
In consideration, the Division will take no further enforcement action based upon the
circumstances covered by this investigation and Order and close its administrative
investigation of the Respondents in connection with the aforementioned activities.
Nothing in this Order shall be construed as a waiver of the Division's right to investigate
and pursue any violations by Respondents in connection with other activity not set forth
herein.
Nothing in this Order is intended to limit or create for third parties any private remedies
against Respondents.
This Order shall be effective as of the date on which it is signed by the Administrator as set
forth below.

IT IS SO ORDERED.
DATED this 30th day of June, 2025.

BY ORDER OF THE ADMINISTRATOR
Office of the Secretary of State, Securities Division

ERIN M. HOUSTON
Deputy Secretary for Securities
Securities Administrator

CONSENT TO ENTRY OF ADMINISTRATIVE ORDER

Respondents Global Macro Asset Management LLC and Donald Edmund Cody, hereby
acknowledge being served with a copy of this Order, have read the foregoing Order, are aware of
their rights to a hearing and appeal in this matter, and have waived the same.

Respondents specifically acknowledge that a violation of this Order may constitute a felony
pursuant to NRS 90.650.

Respondents admit the jurisdiction of the Securities Division of the Nevada Office of the
Secretary of State and consent to entry of this Order by the Administrator of the Division as settlement
of the issues contained within this Order.

Respondents state that no promise of any kind or nature, other than the consideration set forth
in the Order, was made to them to induce them to enter into this Order and that they have entered into
this Order voluntarily.

Dated this 21st day of June, 2025.

Donald Cody
Global Macro Asset Management LLC
Donald Edmund Cody, Individually and as a
Representative of Global Macro Asset Management
LLC)

June 21, 2025

RE Administrative Order CIC24-229

Dear Mr. Sirisy,

Thank you for your assistance in this matter.
Enclosed are two (2) checks.

1) For the inspection Fee of $950.23
2) For the Administrative Order CIC24-229 of $2,000.00

Sincerely,

Donald Cody, CEO Global Macro Asset Management

DONALD E CODY
700-496-8592
20335 JUBILEE WAY
PORTER RANCH, CA 91326

PAY TO THE
ORDER OF
NEVADA SECRETARY OF STATE
TWO THOUSAND AND 00/100
CHASE O
JPMorgan Chase Bank, N.A.
www.chase.com
MEMO ADMIN ORDER CIC24-229

6/21/25
$ 2000.00
DOLLARS

1322716272 4890113437 0202 1520250701-0000

DONALD E CODY
700-496-8592
20335 JUBILEE WAY
PORTER RANCH, CA 91326

PAY TO THE
ORDER OF
NEVADA SECRETARY OF STATE
NINE HUNDRED AND FIFTY AND 23/100
CHASE O
JPMorgan Chase Bank, N.A.
www.chase.com
MEMO INSPECTION FEE CIC 24-229

6/21/25
$ 950.23
DOLLARS

1322716272 4890113437 0202 1520250701-0001