kaal:claim:2714974-014

Adopting a generic compliance program is not sufficient under Rule 206(4)-7: advisers that fail to specifically tailor their compliance program to their own business have incurred large penalties in SEC enforcement.

Source quote, verbatim

Failure on the part of advisers to specifically tailor a compliance program for their business has led to large penalties.

From

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016), Hedge Fund Mandatory Disclosure, p. 13
https://ssrn.com/abstract=2714974 · source PDF

Cite as

Kaal and Oesterle, The History of Hedge Fund Regulation in the United States (2016). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2714974

Holds when

applies to funds subject to Rule 206(4)-7

Classification

failuresupport: evidencedfailure: Untailored compliance programfamily: board-and-oversight-failurecompliance

Verify

The quote above is an exact substring of the source PDF, whose sha256 is 7764601d3ed5bb056b58949e8411eff9dfb9855f143719062030c980c5fa801b. Extraction method: pdf-text-layer.
Attestation record: colloquium/attestations/51551632fbd0fcff...json
Verify the binding yourself: curl -s https://wulfkaal.github.io/claims/2714974-014.md | sha256sum