Recently, the Securities and Exchange Commission (“SEC”) issued an Order Instituting Administrative Cease-and-Desist Proceedings against Ronald S. Rollins (“Rollins”) of Plainfield, New Jersey (Rel. 34-70058). Rollins is the former Chief Compliance Officer (“CCO”) of Comprehensive Capital Management, Inc. (“CCM”), a…
According to Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Act”), the Securities and Exchange Commission (“SEC”) defines “custody” as “…holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them.” This…
Recently, the Securities and Exchange Commission (“SEC”) issued a Risk Alert (the “Alert”) concerning rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Rule”), commonly referred to as “The Custody Rule” for investment advisers. The Alert was issued as…
The California Department of Corporations (“DOC”) recently proposed amendments to the California investment adviser custody rule, Section 260.237 of Title 10 of the California Code of Regulations. The October 18, 2012 announcement follows an initial invitation for comments on the…
Jacko Law Group, P.C. (“JLG”) wrote a Legal Tip titled Private Fund Adviser Updates: The New Sec Presence Examination in November, 2012.… Read More
Jacko Law Group, P.C. (“JLG”) wrote a Legal Tip titled Practical Considerations For Private Fund Managers In a Changing Regulatory Environment in August, 2010.… Read More
Jacko Law Group, P.C. (“JLG”) wrote a Legal Tip titled Sec Releases Significant Amendments To The Custody Rule (Rule 206(4)-2) in January, 2010.… Read More