Custody

It’s been one year since the SEC issued its long-awaited guidance concerning custody (IA Watch, Feb. 23, 2017), yet confusion continues to reign. This is ...

It would be fair to declare John Rogicki as a CCO who went bad. The former compliance officer at Train, Babcock Advisors ($434M in AUM) ...

Rogicki took advantage of his roles as investment adviser and trustee to the foundation by liquidating securities positions in the foundation's advisory account with TBA ...

TBA’s then Chief Compliance Officer informed the Commission staff that TBA had failed to comply with the Custody Rule’s requirement to engage an independent public ...

Even if MUN tokens had a practical use at the time of the offering, it would not preclude the token from being a security. Determining ...

It’s the gift that keeps on giving: the challenge of mastering the SEC’s custody rule. The puzzle takes a new turn with Form ADV season ...

This week, representatives from the Investment Adviser Association are scheduled to meet with staff in OCIE and the Division of Investment Management about custody. The ...

That new guidance from the SEC earlier this year about the custody rule has made its way to OCIE exams (IA Watch, Feb. 23, 2017). ...

Respondents failed, however, until long after making the investments, to inform the investors in the foreign currency-focused fund that some of the fund’s assets were ...

One must be pretty bad in the compliance role for the SEC to bar a person from serving as CCO.   In a new settlement, ...