Private fund manager, ClearPath Capital Partners, LLC, was charged with Custody Rule violations for multiple failures to timely deliver audited financials to fund investors, including: 1) failure to demonstrate that it had delivered the audited financial statements it received; 2) late delivery of financial statements more than 120 days after FYE; and 3) failure to perform a final liquidating audit. The firm was further charged with including impermissible liability disclaimers or “hedge clauses” in its advisory and private fund agreements. The firm agreed to pay a civil penalty of $65,000 to settle the SEC’s charges.