On Monday, the SEC provided a press release regarding recent administrative and cease-and-desist proceedings against three different firms. These actions were centered around the validity of the compliance programs of the involved firms, and, in one case, the level of involvement of the Chief Compliance Officer. The press release is summed up by Robert Kaplan of the SEC:
“The failure to adopt and maintain adequate compliance policies and procedures is a significant violation of the federal securities laws,” said Robert Kaplan, Co-Chief of the SEC Division of Enforcement’s Asset Management Unit. “We will continue to work with our counterparts in the national exam program to identify investment advisers that put their investors at risk by failing to take their compliance obligations seriously.”