Watch Out For Custody And Compliance Rule Sanctions

Law360, New York (November 22, 2013, 7:55 PM EST) -- The U.S. Securities and Exchange Commission recently announced sanctions against six investment advisory firms that, taken as a whole, highlight two continued areas of focus for the SEC: compliance program deficiencies, and violations of the “custody rule.” Firms should expect that these issues will remain a staple of regulator scrutiny.

Taken as a whole, the cases demonstrate that the SEC is concerned with ensuring that each firm maintains a robust compliance program that is reasonably designed to address areas of risk and ensure orderly operation, and...
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