Custody

Remember that you have a compliance obligation to obtain an initial and an annual notice from these clients confirming that their SLOA instruction remains valid

The two advisers had overlapping owners, overlapping managers, overlapping advisory personnel, and overlapping operations including shared office space, without any policies or procedures to ensure ...

In total, since 2018, Hi2 Manager violated the custody rule on 17 occasions

The adviser purported to rely on the audited financials alternative to comply with the custody rule but failed to timely deliver the audited financial statements ...

Fund manager didn't properly distribute audits, regulators claim

Although the firm’s compliance manual contained generic language regarding the need to promptly update its Form ADV if there is additional information required for the ...

The adviser failed to have the funds and securities of seven of those pooled investment vehicles verified by actual examination or have audits performed of ...

Word on the street reveals SEC examiners are slowly returning to on-site exams, although many remain virtual. Their interest in adviser marketing has only heated ...

During the examination, Commission staff informed Ali about the Advisers Act custody rule’s requirements and its prohibition against commingling client money with the firm’s. However, ...

ECM failed to engage an independent public accountant to verify by actual examination at least once during each calendar year the REOC Funds’ funds and ...