In a previous blog post, we discussed a few key areas for consideration regarding a firm’s annual review. We covered the integral area of the Code of Ethics – but in today’s blog post we focus on the importance of analyzing your firm’s policies regarding custody.
In a speech given in late April, Peter Driscoll, Director of the Office of Compliance Inspections and Examinations (OCIE), discussed the importance of cooperation among compliance officers, senior management, and the OCIE to promote compliance and more effectively protect…
Michelle L. Jacko wrote a Legal Tip for Jacko Law Group titled How Prepared Are You for an SEC Examination? in July, 2018.… Read More
The Securities and Exchange Commission (SEC) today released an order instituting administrative and cease-and-desist proceedings against an investment advisory firm and three top officials for violating the custody rule that requires firms to follow certain procedures when they control…
The Legal Tip for Jacko Law Group titled 2014 Sec Enforcement Cases – A Year In Review was written in November, 2014.… Read More
Michelle L. Jacko wrote the article titled Custody compliance Creating More Clarity which was published in the Charles Schwab Compliance Review in July, 2014. … Read More
Jacko Law Group, PC (“JLG”) each month publishes a Legal Tip, written by one of its professional staff on a relevant topic specific to the securities industry. In late May 2014, JLG, wrote and released a Legal…
The Legal Tip for Jacko Law Group titled California’s Revised Custody Rule Seeks Uniformity was written in May, 2014.… Read More
Recently, the California Department of Business Oversight (“DBO”) officially adopted revisions to the California investment adviser custody rule, Section 260.237 of Title 10 of the California Code of Regulations (the “Rule”). According to the DBO, these changes were in response…… Read More
As an Arizona-based private equity fund and its manager discovered at the end of February 2014, paying one’s expenses with client’s assets is both problematic and liable to receive prosecution by the Securities and Exchange Commission (“SEC”). Clean Energy Capital,…