In 2004, a "New York Times" investigative report by Diana B. Henriques named First Command as being one of several investment firms engaged in deceptive marketing of financial instruments aimed at military veterans. On 15 December of that year, the U.S. Securities and Exchange Commission (SEC) determined that First Command had "willfully violated the Securities Act of 1933 Section 17(a)(2) dealing with inter-state fraud" in its marketing activities targeting veterans. In particular, the SEC concluded that First Command had sold mutual fund investments to veterans termed "systematic plans" that bore very high sales charges termed "front-end sales loads", "by, in part, making misleading statements and omissions concerning, among other things: (a) comparisons between the systematic plan and other mutual fund investments; (b) the availability of the Thrift Savings Plan ("TSP"), which offers military investors many of the features of a systematic plan at lower costs; and (c) the efficacy of the front-end sales load in ensuring that investors remain committed to the systematic plan."