SEC Release: In re Aletheia Research and Management, et. al.
SEC Release No. 34-64442 / IA-3197
May 9, 2011
The SEC announced a settled civil administrative action against a California-based investment adviser and two of its principals for violations that included (i) failing to disclose certain requested information regarding prior SEC examinations; (ii) failing to implement appropriate policies and procedures; (iii) failing to have an annual surprise examination of the adviser's hedge funds and to provide the hedge fund investors with quarterly account statements and timely annual audit reports; and (iv) failing to keep employee acknowledgments of receipt of the firm's code of ethics. Among other things, the settlement required the firm to retain an Independent Consultant to review its policies and procedures, and ordered $400,000 in civil monetary penalties.
Cross References
Advisers Act §§ 204(a), 206(2), 206(4)
Advisers Act Rules 204-2(a)(12), 206(4)-2(a), 206(4)-7
Exchange Act § 15(b)