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The SEC's exam division releases this risk alert "so that advisers may prepare themselves for an examination"
The adviser failed to distribute required audited financials
The audits were completed pursuant to the International Standards on Auditing, not U.S. GAAS requirements; and the auditor was not registered with the PCAOB, resulting ...
The adviser purported to rely on the exception to the qualified custodian requirement but did not obtain an audit of each of the Funds and ...
The firm also did not properly describe the status of its fund’s financial statement audits when filing its Forms ADV and did not update certain ...
CGMI willfully violated the recordkeeping requirements of Section 17(a) of the Exchange Act and Rule 17a-3 thereunder, which require broker-dealers to make and keep current ...
He failed to take necessary steps to do so despite being on notice of the rule’s requirements and was aware of the ongoing failures in ...
The reps made handwritten or typed changes on the clients’ standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the ...
SEC rule restricts certain PF adviser activities
This is another new Advisers Act rule directed at PF advisers in 2023