Action against Respondents, an investment adviser and its principal, for alleged violations of the Advisers Act compliance, custody, and books and records rules. According to the SEC, Respondents made material misstatements on their annual Forms ADV, including that Respondent adviser did not have custody of client assets and had chief compliance officers in place. The SEC further alleges that Respondent violated the Advisers Act custody rule by failing to retain an independent CPA and failing to timely distribute audited financials to investors, among other violations.

SEC Order