Charles Pratt & Company, L.L.C.

Allegations: FIRM FAILED TO OBTAIN AN INDEPENDENT VERIFICATION OF ASSETS OF A PRIVATE FUND CLIENT, OR, ALTERNATIVELY, DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS PREPARED IN ACCORDANCE WITH GENERALLY ACCEPTED ACCOUNTING PRINCIPLES ("GAAP") TO THE INVESTORS IN ONE PRIVATE FUND THAT IT ADVISED FOR EACH FISCAL YEAR FROM 2010 THROUGH 2018. FOR FISCAL YEARS 2019 AND 2020, THE ANNUAL AUDITED FINANCIAL STATEMENTS FOR THE FUND WERE DISTRIBUTED TO INVESTORS 481 DAYS LATE AND 222 DAYS LATE, RESPECTIVELY. RESPONDENT ALSO FAILED TO OBTAIN THE REQUISITE INDEPENDENT VERIFICATION OF CLIENT ASSETS FROM AN INDEPENDENT PUBLIC ACCOUNTANT FOR 465 DISCRETIONARY CLIENT ACCOUNTS THAT IT ADVISED FOR EACH YEAR FROM 2010 THROUGH 2020. AS A RESULT OF THE FOREGOING, THE FIRM VIOLATED SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 THEREUNDER, COMMONLY REFERRED TO AS THE "CUSTODY RULE." THE FIRM ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND THE RULES THEREUNDER, A VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7 THEREUNDER. Status: Final Sanction Detail: $100,000 PENALTY Summary: SEC ACCEPTED THE FIRM'S OFFER AND ORDERED THE SANCTIONS LISTED ABOVE.