SEC Administrative Action: Compliance Failures.

SEC order instituting administrative and cease-and-desist proceeding pursuant to Sections 203(e) and 203(k) of the Advisers Act. [SL Comment: This disciplinary action really goes to the conduct of, and the personnel involved in, the compliance process. The SEC stated that the firm (i) had failed to adopt remedial measures in response t prior examinations, (ii) its compliance procedures were generally inadequate, having been originally developed for a broker-dealer and not tailored to the firm's advisory business, and (iii) a CCO of whom the SEC "questioned [his] ability to adequately oversee [the firm's] compliance ooperations due to his lack of familiarity with the Advsiers Act and failure to obtain the proper training.]

Cross Reference(s): Advisers Act Sections 203(e) and 203(k).

View order in full here (links externally to SEC website).