Hudson Housing Capital Llc

Allegations: DURING THE PERIOD MAY 14, 2009 THROUGH JANUARY 21, 2013, HUDSON HOUSING SECURITIES LLC FAILED TO ENFORCE ITS WRITTEN PROCEDURES FOR THE REVIEW OF ELECTRONIC CORRESPONDENCE WITH THE PUBLIC RELATING TO ITS INVESTMENT BANKING AND SECURITIES BUSINESS. Status: Final Sanction Detail: A CENSURE AND A $7500 FINE. HUDSON HOUSING SECURITIES LLC HAS SUBMITTED AN ELECTION OF PAYMENT FORM SHOWING THE METHOD BY WHICH IT PROPOSES TO PAY THE FINE IMPOSED. Summary: WITHOUT ADMITTING OR DENYING THE ALLEGATIONS, TO SETTLE THE MATTER HUDSON HOUSING SECURITIES LLC ENTERED INTO AN AWC WITH FINRA AND PAID A FIND IN THE AMOUNT OF $7500.

Allegations: THE SEC ALLEGED THAT HUDSON HOUSING CAPITAL LLC ("HHC") HAS FAILED TO TIMELY DISTRIBUTE ANNUAL AUDITED FINANCIAL STATEMENTS TO THE INVESTORS IN NUMEROUS PRIVATE INVESTMENT FUNDS THAT IT ADVISED IN EACH FISCAL YEAR FROM 2012 THROUGH 2017, IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-2 COMMONLY REFERRED TO AS THE "CUSTODY RULE," AND HHC ALSO FAILED TO ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT VIOLATIONS OF THE ADVISERS ACT AND FAILED TO REVIEW AT LEAST ANNUALLY THESE POLICIES AND PROCEDURES, IN VIOLATION OF SECTION 206(4) OF THE ADVISERS ACT AND RULE 206(4)-7. Status: Final Sanction Detail: CIVIL PENALTY OF $65,000 WAS PAID ON SEPTEMBER 27, 2018. Summary: HHC UNDERTOOK REMEDIAL ACTIONS, INCLUDING MAKING CUSTODY ARRANGEMENTS TO COMPLY WITH THE CUSTODY RULE AND REVISING AND IMPLEMENTING ITS COMPLIANCE POLICIES AND PROCEDURES. HHC FULLY PAID THE FINE AGREED UPON.