- 2013
Over roughly a 2½-year period, respondent’s former employee allegedly misappropriated $33,147 of dividends owed to four advisory clients/participants in pooled investment vehicles managed by respondent. He was able to accomplish this because a principal of the firm had delegated to him the task of preparing the checks. The SEC found that respondent failed to reasonably supervise its employee, and violated the custody rule of the Investment Advisers Act in its processes for its pooled investment vehicles.
