The SEC recently required a registered investment adviser to retain an outside compliance consultant for two years to help them build and implement a robust compliance program.
The registered investment adviser agreed to this to settle SEC charges that it failed to implement an adequate compliance program. The SEC alleges that two successive chief compliance officers were internal employees that had little compliance experience or training. The firm failed to conduct and document annual compliance reviews and tried to use written supervisory procedures from a predecessor broker-dealer firm as an adviser compliance manual.
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