Custody

Bollinger was responsible for adopting and implementing Fortius’ compliance program. Between 2003 and August 2012 (throughout the entirety of Oliver’s association with the firm), Fortius ...

We would not recommend enforcement action to the Commission against a Fidelity Entity if that Fidelity Entity continues to fulfill its regulatory requirements under the ...

To amend the Investment Advisers Act of 1940 and to direct the Securities and Exchange Commission to amend its rules to modernize certain requirements relating ...

Blue Ocean’s internal policies and procedures established that Winkelmann, as Blue Ocean’s CEO and CCO, was responsible for Blue Ocean’s compliance program. During the relevant ...

Respondents failed reasonably to supervise Douglas E. Cowgill (“Cowgill”), the former Chief Compliance Officer (“CCO”) of Professional Investment Management, Inc. (“PIM”), an investment adviser registered ...

This matter involves repeated failures by SPC, an accounting firm, and Joseph A. Scolaro, an SPC partner, in connection with SPC’s examinations of client funds ...

It’s amazing that all these years after the custody rule was toughened by the SEC that no one had raised this issue until now. The ...

The Division of Investment Management would not recommend enforcement action to the Commission under Section 206(4) of, and Rule 206(4)-2 under, the Advisers Act if ...

TPGS failed to ensure that client securities were maintained by a qualified custodian. For example: (1) paper stock certificates for certain securities purchased by IPE ...

This example may give you ideas for improving your firm's custody policy and procedure.