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.

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

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

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

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

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

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• Qualification: Dr. Jones and the Raiders of Lost Capital: Hedge Fund Regulation, Part II
• Qualification: Recent developments in hedge fund enforcement and regulation by the SEC under the leadership of Chairman Cox suggest that he may not be the free market advocate everyone once thought he was