Two Point Capital, CEO dinged $100K for compliance procedure lapses

A New York-based investment advisory firm and its chief executive officer were fined a total of $100,000 by the Securities and Exchange Commission (SEC) for failing to adopt and implement policies and procedures tailored to guide the firm’s compliance with federal securities law.

Two Point Capital Management and CEO John McGowan “failed to adopt and implement reasonably designed compliance policies and procedures and to conduct annual reviews of its compliance program” from 2012-21, according to an SEC administrative proceeding issued Monday. Two Point was also faulted for failing to establish, maintain, and enforce a written code of ethics, as required by the Advisers Act.

The alleged violations were discovered during an SEC examination of the firm in 2021, the proceeding said.