ADMINISTRATIVE PROCEEDING
File No. 3-21111

September 19, 2022 - The Securities and Exchange Commission today instituted settled administrative proceedings against Matthew W. Dreyer, a certified public accountant licensed in New York, for his conduct in connection with his engagement in March 2018 to verify client funds and securities of which an SEC-registered investment adviser had custody.

According to the SEC's order, Dreyer agreed to perform a surprise custody examination for the investment adviser in March 2018, but failed to complete the examination for more than two years. The order finds that after the investment adviser contacted Dreyer in late March 2020 to explain that it was undergoing an SEC examination and to ask him if he had any documentation of his work it could provide to examiners, Dreyer issued an undated report for the surprise examination to the investment adviser which contained numerous misrepresentations regarding procedures he claimed to have performed during the examination but never actually carried out. The order further finds that, when told by the investment adviser that SEC examination staff had asked for the report's date, Dreyer misrepresented the date he completed the report as July 31, 2018, while understanding that this information would be provided to the SEC examination staff. According to the order, Dreyer's conduct violated applicable professional standards for integrity, exercising due care, and obtaining, preparing and maintaining appropriate engagement documentation.

Without admitting or denying the findings, Dreyer consented to the SEC's order finding that Dreyer lacked integrity and engaged in improper professional conduct within the meaning of Section 4C of the Securities Exchange Act of 1934 and Rule 102(e)(1)(ii) of the Commission's Rules of Practice. Dreyer agreed to be suspended from appearing or practicing before the SEC as an accountant. The SEC's order permits Dreyer to apply for reinstatement after five years.

The SEC's investigation was conducted by Jonathan Grant, Amy Mayer, and Wendy B. Tepperman of the New York Regional Office, and was supervised by Sheldon L. Pollock.