Pr2022 156 Table

Ten investment advisers, including Garrison Investment Group LP (fined $330,000), were penalized by the SEC for failing to amend or comply with Custody Rule requirements, with no allegations of fraud or misappropriation, only procedural compliance failures.

The SEC imposed administrative penalties on ten investment advisers for violations of Rule 206(4)-2, primarily for failing to amend custody disclosures or maintain proper safeguards. Fines ranged from $50,000 to $330,000, with Garrison Investment Group LP receiving the highest penalty, while QVR LLC and Polaris Equity Management were each fined $50,000. All violations involved procedural noncompliance—such as inadequate audits, notification failures, or outdated custody arrangements—with no allegations of fraud, misappropriation, or investor harm.

The SEC penalized ten investment advisers for violations of the Custody Rule (Rule 206(4)-2), targeting failures to amend required filings, update custody arrangements, or meet audit and notification obligations. BiscayneAmericas Advisers L.L.C. was fined $135,000, Garrison Investment Group LP received the largest penalty at $330,000, and Janus Henderson Investors US LLC, Lend Academy Investments, Ridgeview Asset Management Partners LLC, Steward Capital Management, Inc., and Titan Fund Management, LLC were fined between $70,000 and $150,000. QVR LLC and Polaris Equity Management, Inc. each received the minimum penalty of $50,000. The enforcement actions focused exclusively on procedural and administrative noncompliance, with no allegations of fraud, misappropriation of client assets, or intentional deception. The SEC emphasized deterrence and institutional adherence to custody safeguards rather than remediation for actual investor harm. These penalties reflect the agency’s ongoing commitment to enforcing custody rule requirements across registered advisers. All actions were administrative, not criminal, and aimed at ensuring accurate disclosures and proper oversight of client assets.