FYI: Unregistered Adviser Integrated with Registered Adviser
Posted onFYI: The SEC settled an administrative proceeding against an unregistered adviser to private funds that was found ineligible to rely on the exempt reporting adviser exemption because it and its affiliated SEC-registered investment adviser (an adviser to individuals) were under common control and operationally integrated. The SEC’s settlement order cited various factors for finding the two advisers integrated: they were both owned by the same owner, shared the same employees, operated in the same office, shared the same technology systems and failed to maintain policies and procedures addressing registration or exemption from registration as an investment adviser. Violations alleged included, […]