David Dickstein

David Dickstein

Katten Muchin Rosenman LLP

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SEC Enforcement Action Alleges an Adviser Failed to Adopt Adequate Cybersecurity Policies and Procedures; SEC Issues an Investor...

On September 22, 2015, the Securities and Exchange Commission (SEC) filed a settled administrative proceeding[1] alleging that a registered investment adviser failed to adopt cybersecurity procedures in violation of an SEC...more

9/25/2015 - Cybersecurity Data Breach Enforcement Actions Investment Adviser Personally Identifiable Information Risk Alert SEC Security and Privacy Controls

SEC Enforcement Action Signifies the Need for Investment Advisers to Adopt Written Expense Allocation Policies

On June 29, the Securities and Exchange Commission charged Kohlberg Kravis Roberts & Co. (KKR) with violations of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940, as amended, and Rule 206(4)-7 thereunder for...more

7/16/2015 - Allocation of Funds Enforcement Actions Fiduciary Duty Investment Adviser Investment Advisers Act of 1940 Policies and Procedures SEC

SEC Division of Investment Management Issues Guidance Update Relating to Rule 204A-1 of the Investment Advisers Act

In June, the Securities and Exchange Commission’s Division of Investment Management issued a Guidance Update relating to Rule 204A-1 under the Investment Advisers Act of 1940. Rule 204A-1 provides that a registered investment...more

7/16/2015 - Ethics Exceptions Guidance Update Investment Adviser Investment Advisers Act of 1940 Reporting Requirements Rule 204-2 SEC

Effective Date of Investment Adviser Pay-to-Play Rule Ban on Third-Party Solicitation

The Securities and Exchange Commission’s Rule 206(4)-5 (Pay-to-Play Rule) under the Investment Advisers Act of 1940, as amended, prohibits, among other restrictions, an investment adviser subject to the rule, and its covered...more

7/16/2015 - FINRA General Solicitation Investment Adviser Investment Advisers Act of 1940 MSRB Municipal Advisers Pay-To-Play SEC Third-Party

SEC to Examine Never-Before Examined Registered Investment Advisers

The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) announced that it is launching an initiative, as part of its existing National Exam Program, to examine investment advisers who...more

2/25/2014 - Investment Adviser OCIE SEC

Corporate and Financial Weekly Digest - Volume IX, Issue 8

In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more

2/24/2014 - Bank Holding Company Banking Sector Broker-Dealer Disclosure Requirements Dodd-Frank Federal Reserve Financial Regulatory Reform FINRA Foreign Banks Investment Adviser IRS OTC SEC Tax Preparers Tax Returns

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