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Articles Posted in Custody

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SEC Cites Three Advisers for Failure to Timely Audit Private Funds

Custody presents a compliance danger for investment advisers, including advisers to private funds. Three recent enforcement cases illustrate the importance of diligent compliance for fund advisers with custody of client assets.  According to the Advisers Act, an investment adviser has custody of client assets if it holds, directly or indirectly,…

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SEC Multi-Branch Initiative Results in Branch Office Risk Alert

Late last year, the SEC’s Office of Compliance Inspections and Examinations (OCIE), now known as the Division of Examinations, issued a compliance risk alert warning investment advisers to ensure that their compliance programs are uniform and are uniformly applied across all branch office locations. The alert summarized the findings from…

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