On September 23, 2014, the SEC settled charges against Barclays Capital Inc. for failing to maintain an adequate internal compliance system after it acquired the advisory business of Lehman Brothers in September 2008. According to the SEC’s order, Barclays Capital failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and failed to maintain certain required books and records. The SEC found that these deficiencies contributed to various violations of the Advisers Act by Barclays Capital, including executing more than 1,500 principal transactions with clients without making the required written disclosures or obtaining client consent; charging commissions and fees that were inconsistent with its disclosures to clients; and violating the custody rule under the Advisers Act. Barclays Capital agreed to pay a $15 million penalty and retain an independent compliance consultant to settle the charges.