Custody

Regulation 1.49(d)(3) provides that, in order to hold customer funds with a depository located outside of the United States, the depository must be: (i) a ...

Starting in at least 2009, Total Wealth and Cooper breached their fiduciary duties to their clients and investors through a fraudulent scheme to collect, and ...

The disclosures also failed to adequately disclose that Total Wealth already had a significant number of revenue sharing agreements in place. For example, according to ...

Confusion over the custody rule continues to reign more than five years after the SEC revised the rule. And even OCIE examiners don’t always agree ...

The verdict’s finally in on a repeat violator and it includes language preventing the adviser’s owners from adding any new clients or assets for a ...

Kelly knew or was reckless in not knowing about, and substantially assisted, SBAM’s violations of the custody rule. Kelly executed the notarized offer of settlement ...

The 2010 Order notwithstanding, SBAM failed to comply with the custody rule in the years that followed. SBAM neither submitted to a surprise examination, nor ...

When the SEC releases three enforcement cases on the same day – tied to the same issue – you know a message is being sent. ...

By all measures the investment adviser industry shows healthy growth. That’s one of the conclusions in the recently released 15th annual Evolution Revolution study from ...

This matter involves violations by Respondents in failing to adequately complete requisite surprise examinations pursuant to Section 206(4) of the Advisers Act and Rule 206(4)-2 ...