Custody

"We are expressing a Staff position that an investment adviser relying on the exception for limited partnerships (or limited liability companies or other types of ...

Private fund adviser settles custody case - but where did all the money go?

It's has been a chore to lure an accountant in for a surprise exam in this year of the pandemic

SQN Capital relied on the Audited Financials Alternative to attempt to comply with the custody rule during the relevant period but failed to do so

TSP Capital will pay a $60K penalty under settlement agreement

TSP Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written P&Ps

RCW exclusive analysis of Form ADV data

No enforcement if financials can't be “distributed in time under certain unforeseeable circumstances”

The Division would not recommend enforcement action for distributing late a pool's audited financial statements due to certain unforeseeable circumstances

The FAQ slaps five conditions on the use of this regulatory relief