SEC Releases Slate of Enforcement Actions Against Advisers Related to Custody Rule Violations and Form ADV Deficiencies

On September 9, 2022, the Securities and Exchange Commission (“SEC”) announced charges against several investment advisers for failure to comply with requirements of Section 206(4) of the Advisers Act and the rules promulgated thereunder (commonly known as the “Custody Rule”) and deficiencies related to Form ADV filings.

The advisers included BiscayneAmericas Advisers L.L.C., Garrison Investment Group, LP, Janus Henderson Investors US LLC, Lend Academy Investments, LLC, Polaris Equity Management, Inc., QVR, LLC, Ridgeview Asset Management Partners, LLC, Steward Capital Management, Inc., and Titan Fund Management, LLC.  The advisers all agreed to settle the charges and will pay combined penalties of over $1 million.

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