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Custody

A guide to help you comply with the custody rule
The outcome of each case will speak to the Commission’s interpretation of how serious such offenses are and what punishment fits these violations
Former SEC official and now Proskauer Partner Robert Plaze permits RCW to share his guide to the Advisers' Act custody rule.
A New York investment adviser didn’t hire a public accountant to audit its subsidiary’s private fund and now its bank account is $250,000 lighter, the ...
In July 2016, GIG’s Chief Compliance Officer identified the omission of parties from the Application and the resulting non-compliance with the Co-Invest Order and informed ...
ED Capital also failed to comply with the requirement that every investment adviser registered with the Commission adopt and implement written policies and procedures reasonably ...
This is a copy of an adviser's OCIE document request letter from a 2018 exam that focused on custody.
Questions have swirled in the industry around the application of the federal securities laws and FINRA rules regarding the custody of digital asset securities. In ...
One of the biggest obstacles preventing investment advisers from investing in FinTech and digital currencies is a familiar nemesis: the custody rule. “It’s mind bogging ...
If you’re having difficulty making the case for sufficient resources for your firm’s compliance program, you may want to consider laying the latest speech from ...
Corinthian misused the assets in a private equity fund, Corinthian Equity Fund II, LP (“CEF 2”) that it advised to the advantage of Corinthian and ...
OCIE Director Pete Driscoll
xaminers have frequently observed deficiencies with respect to the custody rule, and in 2017, OCIE issued a Risk Alert identifying some of the typical deficiencies ...
In a bid to provide greater flexibility to broker-dealers withdrawing their registration, the SEC has approved amendments to FINRA rule 4570 affording firms the option ...
Gooder can clearly do better. Grenville Gooder, Jr., a 55-year securities industry veteran, and his SEC-registered advisory firm Ascension Asset Management ($152M in AUM), were ...
A new letter from the SEC’s Division of Investment Management seeks your guidance on how the agency should deal with the non-delivery versus payment custody ...
We welcome input and engagement from all interested parties regarding the potential considerations posed by digital assets with respect to the Custody Rule.
Individual B never agreed to serve as Ascension’s CCO and was unaware that Ascension and Gooder had named him as the firm’s CCO until after ...
Nichter knowingly devised, and intended to devise, a scheme or artifice to defraud, and to obtain money, funds, and other property by means of materially ...
In what may be the last SEC no-action letter released for some time due to the government shutdown, the Division of Investment Management last month ...
Staff Letter No-Action relief under Section 206(4) and Rule 206(4)-2 under the Investment Advisers Act of 1940 Dec. 20, 2018 Investment Advisers Act Section 206(4) ...
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