Simons Says: You Might Not Realize You Have Custody

Based on deficiency letters that we have seen over the past year and especially in the past few months, it appears that many advisers either didn’t believe that the SEC Staff was serious about looking closely at the adequate safekeeping … Read More ›

Simons Says: Déjà vu All Over Again

I read something the other day that I want to share, “It will take over 24 million man hours to comply with Dodd-Frank rules per year. It took only 20 million to build the Panama Canal,” according to Rep. Neugebauer, … Read More ›