News & Analysis as of

Custody Rule Chief Compliance Officers

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: October 2019

Proskauer Rose LLP on

Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Kramer Levin Naftalis & Frankel LLP

Funds Talk: March 2017

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - A Source of Concern for the SEC — The Outsourcing by Investment Advisers and Funds of Compliance Activities - In a recent National Exam Program Risk Alert (dated November 9, 2015) the U.S....more

Proskauer - Corporate Defense and Disputes

SEC Once Again Sanctions The CCO of An Investment Advisory Firm

On November 19, 2015, the SEC announced a settlement with investment advisory firm Sands Brothers Asset Management, LLC for violating the Custody Rule, SEC Rule 206(4)-2, which requires that registered investment advisers who...more

Broker-Dealer Compliance + Regulation

SEC Sanctions Adviser, Executives and CCO for Custody Rule Violation – Again

On November 19, 2015, the SEC sanctioned a registered investment adviser, its two owners, and a former chief compliance officer for violating the Advisers Act “custody rule” after previously settling similar charges and...more

McGuireWoods LLP

SEC Seeks Serious Penalties Against Sands Brothers and its Senior Officers for Alleged Repeated Custody Rule Violations - Former...

McGuireWoods LLP on

On October 29, 2014, the SEC announced that it had instituted administrative proceedings under the Investment Advisers Act of 1940 against Sands Brothers Asset Management LLC (Sands Brothers), its two co-founders and the...more

Broker-Dealer Compliance + Regulation

SEC Targets More Firms for Custody Rule Violations

On October 28, 2013, the SEC sanctioned three registered investment advisers for, among other things, violating Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). These settled actions, the subject of a special SEC...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - March 15, 2013

In this issue: - Mary Jo White, Nominee for Chair of the SEC, Appears Before Senate Banking Committee - SEC Proposes Rules Regarding Technology Systems - FINRA Amends Rules to Address Extraordinary Market...more

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