On March 7, 2019, the SEC announced an enforcement action against Ascension, an SEC-registered investment adviser, and its founder, sole owner, and sole operator, Gooder. For as long as a decade, Ascension and Gooder failed to comply with Advisers Act Section 206(4) and Rule 206(4)-7 thereunder (the “Compliance Rule”) and Rule 206(4)-2 thereunder (the “Custody Rule”), and also failed to make and keep certain required books and records pursuant to Advisers Act Section 204 and Rule 204-2 thereunder (the “Books and Records Rule”) (collectively, “the Rules”). Ascension’s Forms ADV that Gooder signed and directed to be filed with the Commission contained materially untrue statements that further demonstrate Respondents’ indifference to the regulatory requirements of an SEC-registered investment adviser. In particular, in multiple Forms ADV filed with the Commission, Gooder and Ascension (i) falsely stated that Ascension did not have custody of client assets, (ii) repeatedly named an individual as Ascension’s Chief Compliance Officer (“CCO”) even though that individual was never responsible for administering any written compliance policies and procedures for the firm, and (iii) on one occasion in 2011, identified a second individual as Ascension’s CCO in the firm’s Form ADV unbeknownst to this individual. From in or about October 2004 until November 2015, Ascension did not adopt and implement any written compliance policies and procedures required by Advisers Act Rule 206(4)-7(a). During this same time period, Ascension did not conduct the reviews required by Advisers Act Rule 206(4)-7(b). Specifically, Gooder, despite being Ascension’s sole control person, failed to take any steps to prepare the required written compliance policies and procedures or conduct the required reviews for Ascension.