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Firm Agrees to Pay $1 Million Settlement for Custody Rule Violations

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November 19, 2015

Dear Friends,

Today the SEC announced that an investment adviser and its former CCO have agreed to settle charges that it repeatedly violated the custody rule.

The Firm agreed to pay a $1 million penalty, to be suspended for one year from raising any capital, and to have a compliance monitor for three years. The former CCO agreed personally to pay a $60,000 penalty and will be suspended for one year from acting as a CCO or appearing before the SEC as an attorney.

The SEC claimed the Firm was repeatedly late in providing investors with audited financial statements, among other matters.  “There is no place for recidivism in the securities markets… so now they [the Firm] face more severe consequences,” said Andrew M. Calamari, Director of the SEC’s New York Regional Office.

Please click here for the SEC’s order. Please feel free to contact us with any questions at (212) 867-0200 or email us at info@counselworksllc.com.

Thank you,



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CounselWorks is a strategic business and regulatory consulting firm, that provides project-based consulting and manages compliance and regulatory programs for hedge funds, private equity firms, investment companies, broker-dealers and investment banks.
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