Tsp Capital Management Group, Llc

Allegations: WITH RESPECT TO THE CAMEROON FUND, TSP RELIED ON THE AUDITED FINANCIALS ALTERNATIVE TO ATTEMPT TO COMPLY WITH THE CUSTODY RULE FOR THE YEARS 2014 THROUGH 2018. TSP ATTEMPTED TO ENGAGE A PCAOB REGISTERED FIRM TO AUDIT THE CAMEROON FUND'S ANNUAL FINANCIAL STATEMENTS, BUT DUE TO THE NATURE OF THE AGRICULTURAL ASSETS OF THE CAMEROON FUND AND OTHER EXTENUATING CIRCUMSTANCES, SUCH AS THE POLITICAL CLIMATE IN CAMEROON, TSP WAS UNABLE TO DO SO. THE SETTLEMENT FINDS THAT THE 2014 AND 2015 AUDITS WERE DELIVERED 686 DAYS AND 927 DAYS LATE, RESPECTIVELY, AND THAT TSP FAILED TO PROCURE AUDITED FINANCIALS FOR THE CAMEROON FUND FROM 2016 THROUGH 2018. ACCORDINGLY, THE SETTLEMENT FINDS THAT TSP DID NOT SATISFY THE REQUIREMENTS OF THE AUDITED FINANCIALS ALTERNATIVE IN RULE 206(4)-2(B)(4) FOR THE CAMEROON FUND FOR FISCAL YEARS 2014 THROUGH 2018 AND WAS THEREFORE OBLIGATED TO COMPLY WITH ALL OF THE REQUIREMENTS OF THE CUSTODY RULE WITH RESPECT TO THE CAMEROON FUND DURING THOSE YEARS, WHICH IT ALSO FAILED TO DO. TSP ALSO NOTES THAT IT HAS DESCRIBED THESE AUDIT DELAYS OF THE CAMEROON FUND IN ITS PRIOR AMENDMENTS TO THE FORM ADV. THE SETTLEMENT WITH THE SEC ALSO FINDS THAT TSP FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND RULES THEREUNDER. WHILE TSP'S WRITTEN POLICIES AND PROCEDURES REFERENCED THE CUSTODY RULE, TSP WAS AWARE OF ITS OBLIGATIONS UNDER THE CUSTODY RULE WITH RESPECT TO THE CAMEROON FUND, AND TSP ATTEMPTED TO COMPLY WITH THE CUSTODY RULE WITH RESPECT TO THE CAMEROON FUND, THE SETTLEMENT FINDS THAT TSP'S POLICIES WERE NOT REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE CUSTODY RULE BECAUSE TSP WAS UNABLE TO ACTUALLY COMPLY WITH THE CUSTODY RULE AS DESCRIBED ABOVE. Status: Final Sanction Detail: ON MAY 22, 2020 THE SEC PUBLISHED A SETTLEMENT AGREEMENT BETWEEN TSP AND THE SEC. AS PART OF THE SETTLEMENT, TSP HAS AGREED TO PAY A $60,000 PENALTY, AND ACCEPT A CENSURE. Summary: WITHOUT ADMITTING OR DENYING THE FINDINGS, TSP HAS AGREED TO A CEASE AND DESIST, CENSURE, AND A CIVIL MONETARY PENALTY IN THE AMOUNT OF $60,000. THE CAMEROON FUND IS ALSO NO LONGER A CLIENT OF TSP.