The SEC brought an enforcement action against Agamas Capital Management, LP finding that Agamas failed to adopt and implement written compliance policies and procedures required by Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. In particular, the SEC found that with respect to private funds, the adviser lacked compliance procedures covering:
- valuation of fund assets,
- the accuracy of disclosures to fund investors about the valuation practice, and
- cross trades between clients.
The SEC ordered the adviser to pay a civil penalty of $250,000.
Please click here to access the administrative order.