GC Was Diligent But He Blew It, Says Columnist

The investment advisory firm had been around for more than 30 years, burnishing a reputation for “for probity and integrity.” Now it’s defunct, after failing to weather a scathing SEC final order that cited the company for “misleading performance advertising” and having no policy for reviewing marketing materials, not to mention accepting gifts from money managers who would benefit from being touted by the firm. The writer suggests much of the blame can be laid on the general counsel, who even though he flagged some instances of malfeasance, failed to articulate and enforce a consistent policy.