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SEC Sanctions Investment Adviser for Improper Allocation of Expenses

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November 23, 2015

Dear Friends,

Today, the SEC issued an order against an investment adviser for improper allocation of expenses to its fund client (the “Fund”) and failure to adopt compliance policies and procedures, specific to Fund expense allocation, resulting in a $250,000 settlement.

The SEC found that the firm negligently charged compliance, legal and operating expenses to the Fund. Even though the limited partnership agreement disclosed that the Fund would pay for the legal and accounting fees of the Fund, there was no disclosure that the adviser was authorized to charge the Fund for its compliance consulting fees.

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

Thank you,



About CounselWorks LLC

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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