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Custody Rule Compliance Enforcement Actions

BCLP

Recent SEC Enforcement Action Integrating Affiliated Advisers

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A recent Securities and Exchange Commission (“SEC”) settled enforcement action serves as an excellent reminder of the risk of operational integration to firms that operate multiple advisory entities, especially where one of...more

Seward & Kissel LLP

SEC Enforcement Action Rundown

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Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of enforcement actions relating to recordkeeping failures,...more

Dorsey & Whitney LLP

RIA Regulatory Review - October 2023

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This RIA Regulatory Review highlights certain key regulatory developments affecting investment advisers. Please contact us with any questions on the topics covered below. The SEC Adopts Significant New Rules for Private...more

Goodwin

SEC Sends Second Message to Private-Fund Sponsors on Audit Obligations Under Custody Rule Through Enforcement Actions

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On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions,  the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of...more

Proskauer - The Capital Commitment

SEC clamps down on Custody Rule

Under rule 206(4)-2 of the Advisers Act, otherwise known as the Custody Rule, it is a fraudulent practice for a registered investment adviser to have custody of client funds or securities, unless the adviser takes certain...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - A Source of Concern for the SEC — The Outsourcing by Investment Advisers and Funds of Compliance Activities - In a recent National Exam Program Risk Alert (dated November 9, 2015) the U.S....more

Proskauer Rose LLP

Repeated Violations of the Custody Rule Result in SEC Administrative Action

Proskauer Rose LLP on

On October 29, 2014, the Securities and Exchange Commission (SEC) announced an administrative proceeding against a registered investment adviser, its principals and its chief compliance and operating officer for violating...more

Dorsey & Whitney LLP

This Week In Securities Litigation

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The Commission brought a series of administrative proceedings this week and one civil injunctive action. The civil injunctive action was an insider trading case. The administrative proceedings centered on FCPA violations, the...more

Stinson - Corporate & Securities Law Blog

SEC Charges Manager Of Private Equity Fund With Violation Of The Custody Rule

The SEC has settled an administrative action with the managing member of a fund of private equity funds. In an examination the SEC staff learned that the manager was violating the custody rule (Rule 206(4)-2 under the...more

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