The New Fall-Guy…the CCO

This week everyone is talking about the recent case against BlackRock Advisors and its former CCO.  The allegations were clear violations of Rule 206(4)-7 but not so clear violations of Rule 38a-1.  Both the firm and the advisory CCO were named in the proceeding, charged with violations and fined.  The firm was fined $12 million…

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More Custody Relief for Private Funds

The SEC issued a no-action letter last month regarding the Custody Rule, Rule 206(4)-2 of the Investment Advisers Act of 1940 (“Advisers Act”). The no-action letter to 16th Amendment Advisors LLC is important for certain private fund advisers as it provides relief from key requirements of the Rule. Specifically, the relief is intended for those…

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