RIA Compliance Blog
The Securities and Exchange Commission (“SEC”) issued a settled administrative order against TAG Associates LLC (“TAG”), a Delaware limited liability company registered with the SEC as an investment adviser since January 2002. Among other violations identified in the proceeding, the SEC found that TAG failed to comply with Regulation S-ID by inadequately administering and maintaining its written Identity Theft Prevention Program (“Program”), as required under 17 C.F.R. § 248.201. While the proceeding also involved a separate finding relating to the Custody Rule under the Investment Advisers Act, the order highlighted the violation of Regulation S-ID and the importance of ongoing compliance reviews and management oversight in ensuring that Programs are properly administered and maintained.