SEC Alleges Adviser Ignored Compliance Responsibilities, Falsely Identified CCOs
ACA Insight
March 18, 2019
“This action should be a wake-up call to advisory firms who deliberately make false material assertions on a Form ADV,” said Lewis Baach partner Jason Berland. “This is particularly true when a firm blatantly fails to designate an appropriate individual to be responsible for administering compliance programs. In a situation, such as the one here, where one of the chief compliance officer designees was allegedly unaware he was designated, civil money penalties should be a real concern.”