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Custody Rule Financial Statements

Goodwin

SEC Sends Second Message to Private-Fund Sponsors on Audit Obligations Under Custody Rule Through Enforcement Actions

Goodwin on

On September 5, 2023, almost one year since its first flurry of similar Custody Rule actions,  the SEC announced settlements with five SEC-registered investment advisers to private funds with respect to alleged violations of...more

Holland & Knight LLP

Summary and Early Analysis of New SEC Private Fund Rules

Holland & Knight LLP on

The U.S. Securities and Exchange Commission (SEC) on Aug. 23, 2023, adopted the long-awaited private fund rules (Private Fund Rules) under the Investment Advisers Act of 1940 (Advisers Act) as part of SEC Release No. IA-6383...more

Goodwin

SEC Sends Message to Private Fund Sponsors on Audit Obligations Under Custody Rule Through Enforcement Actions

Goodwin on

​​​​​​​On September 9, 2022, the SEC announced settlements with nine SEC-registered investment advisers to private funds with respect to alleged violations of Rule 206(4)-2 under the Investment Advisers Act of 1940 (the...more

Winstead PC

SEC Fines Private Fund Sponsor for Failing to Deliver Audited Financials

Winstead PC on

On May 22, 2020, the Securities and Exchange Commission (the “SEC”) initiated and settled cease-and-desist proceedings against a private fund sponsor that allegedly failed to timely deliver audited financial statements to the...more

Proskauer - The Capital Commitment

SEC clamps down on Custody Rule

Under rule 206(4)-2 of the Advisers Act, otherwise known as the Custody Rule, it is a fraudulent practice for a registered investment adviser to have custody of client funds or securities, unless the adviser takes certain...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - September 2019

In this issue, we summarize regulatory, litigation and industry developments from May to September 2019 impacting the investment management sector, including SEC action on standards of conduct for broker-dealers and...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - June 2019

In the inaugural issue of Investment Management Update, we summarize regulatory, litigation and industry developments from February 2019 to May 2019 impacting the investment management sector....more

Katten Muchin Rosenman LLP

Bridging the Week - April 2015 #3

CFTC Commissioner Bowen Argues for User Fees During House Subcommittee Hearing; Commissioner Wetjen Calls for Bankruptcy Law Amendments to Permit Individual Segregation of Customer Funds - Commodity Futures Trading...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

Stinson - Corporate & Securities Law Blog

Providing Audited Financial Statements Late Leads to Charges of Custody Rule Violations

The SEC announced charges against an investment advisory firm and three of its top officials for violating the “custody rule” that requires firms to follow certain procedures when they control or have access to client money...more

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