Terry D. Nelson

Terry D. Nelson

Foley & Lardner LLP

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A Compilation of Enforcement and Non-Enforcement Actions

SEC Looks to Step Up Oversight of the Fund Industry - At a recent conference, Mary Jo White, SEC chairman, announced that the SEC will look to increase its scrutiny of the mutual fund asset management segment to ensure...more

1/2/2015 - Enforcement Enforcement Actions False Statements Family Offices Hedge Funds Mutual Funds SEC Securities Securities Fraud Strategic Enforcement Plan

A Compilation of Enforcement and Non-Enforcement Actions

Non-Enforcement - Cost of Proposed User Fees by Registered Investment Advisers Further Discussed - SEC Valuation Guidance for All Funds - Update on Insider Trading in Mutual Fund...more

10/1/2014 - Conflicts of Interest Enforcement Enforcement Actions Insider Trading Investment Adviser Mutual Funds SEC Subpoenas Valuation

A Compilation of Enforcement and Non-Enforcement Actions

SEC Proposes Extension of Principal Trade Rule for Registered Advisers/Broker-Dealers - The SEC has proposed extending to December 31, 2016, the sunset date for the expiration of Rule 206(3)-3T (the “Rule”) under the...more

9/2/2014 - Broker-Dealer Compliance Enforcement Enforcement Actions Fraud Investment Advisers Act of 1940 SEC

A Compilation of Enforcement and Non-Enforcement Actions

Renewed Call for Investment Adviser User Fees - As we reported in previous editions of our Investment Management Newsletter, various persons have proposed that a user fee be imposed on SEC registered investment...more

8/1/2014 - Compliance Dodd-Frank Enforcement Enforcement Actions Investment Adviser JOBS Act Non-Enforcement OCIE SEC

A Compilation of Enforcement and Non-Enforcement Actions

As reported in the May 2014 edition of Legal News: Investment Management Update, the SEC has made cybersecurity readiness a high-priority item to review when it conducts examinations of registered broker-dealers and...more

7/1/2014 - Affiliated-Business Arrangements Affiliates Broker-Dealer Cybersecurity Dodd-Frank Enforcement Enforcement Actions Investment Adviser Retaliation Sanctions SEC

A Compilation of Enforcement and Non-Enforcement Actions

Concerns Noted During Private Equity Adviser Exams - Routine examinations by the SEC at advisory firms who manage the assets of private equity funds have uncovered some serious concerns about the way such advisers...more

5/30/2014 - Enforcement Enforcement Actions FINRA Investment Adviser Mutual Funds OCIE Popular Private Equity Private Equity Funds Professional License SEC Whistleblowers

A Compilation of Enforcement and Non-Enforcement Actions - 04/30/14

Enforcement Matters: Improper Calculation of Client Advisory Fees Results in Enforcement Action - In a recent action (In the Matter of Transamerica Financial Advisors, Inc., Investment Advisers Act Release No....more

4/30/2014 - Cybersecurity Enforcement Enforcement Actions Fraud Sanctions SEC

A Compilation of Actions - April 01, 2014

In a recent SEC no-action letter (RS Global Natural Res. Fund, SEC no-action letter, available 3/6/14), the SEC stated that it would take a non-enforcement position if a SEC registered investment adviser to a fund registered...more

4/1/2014 - Compliance Enforcement Investment Company Act of 1940 No-Action Letters SEC

A Compilation of Enforcement and Non-Enforcement Actions - December 31, 2013

Investment Advisers — Are Your “IA Reps” Registered as Required? Why You Should Care - As we approach the end of the calendar year, it is a good time for investment advisers to check if all of its personnel who are...more

12/31/2013 - Chief Compliance Officers Compliance Enforcement Enforcement Actions Hedge Funds Investment Adviser Investment Advisory Agreements SEC

A Compilation of Enforcement and Non-Enforcement Actions - November 08, 2013

Non-Enforcement Matters - SEC Focused on Compliance Programs - SEC Beefing Up its Risk and Examinations Office - SEC Guidance on Valuation of Portfolio Securities - Affiliated Exchange-Traded Funds May...more

11/8/2013 - Compliance Enforcement Enforcement Actions Non-Enforcement SEC

A Compilation of Enforcement and Non-Enforcement Actions - October 30, 2013

Non-Enforcement Matters: - No Rush to Advertise by Hedge Funds - Updated Guidance From the SEC - Results of Dodd-Frank Legislation on Investment Adviser Registration Numbers Enforcement...more

10/30/2013 - Dodd-Frank Enforcement Enforcement Actions Hedge Funds Investment Adviser Non-Enforcement SEC

A Compilation of Enforcement and Non-Enforcement Actions - September 30, 2013

Non-Enforcement Matters - SEC to Monitor Fund Performance Claims - Suit Against Exchange Traded Funds’ Investment Adviser Dismissed - Counterparty Risk Management Practices for Mutual...more

9/30/2013 - Enforcement Enforcement Actions Investment Adviser Mutual Funds Non-Enforcement Regulation M SEC

A Compilation of Enforcement and Non-Enforcement Actions - August 30, 2013

Non-Enforcement Matters: - Private Fund Issuers’ Use of New SEC Rule 506(c) Hardly a “Slam Dunk” - Advisers Need to Revisit Their Business Continuity Plans. Enforcement Matters: - Registered...more

8/30/2013 - Continuity of Enterprises Enforcement Enforcement Actions Investment Adviser Non-Enforcement Private Funds Rule 506 Offerings SEC

A Compilation of Enforcement and Non-Enforcement Actions - July 01, 2013

Re: Possible SRO for Investment Advisers and Fiduciary Standard for Broker-Dealers — What Others Are Saying - In the ongoing debate over whether a supervisory regulatory agency, other than the SEC, should be delegated...more

7/1/2013 - Enforcement Fees Fiscal Year Fraud Investment Adviser Investors Non-Enforcement SEC

A Compilation of Enforcement and Non-Enforcement Actions - May 31, 2013

Board Oversight of Distribution and Financial Intermediaries - One of the SEC’s stated focuses is on payments for “distribution in guise.” Mutual funds are only permitted to pay for distribution of their shares if...more

5/31/2013 - CFTC Conflicts of Interest Enforcement Fund Managers Identity Theft Investment Management Misappropriation Mutual Funds SEC Shareholders Social Media

A Compilation of Enforcement and Non-Enforcement Actions - May 01, 2013

* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more

5/1/2013 - Enforcement Enforcement Actions False Advertising FATCA Fees Investment Adviser Non-Enforcement Offshore Funds Reporting Requirements SEC

A Compilation of Enforcement and Non-Enforcement Actions - January 31, 2013

In This Issue: Non-Enforcement Matters - FINRA Announces Regulatory and Examination Priorities for 2013 - SEC Previous Hedge Fund Enforcement Trends for 2013 Enforcement Matters - Another...more

1/31/2013 - Complex Financial Products Compliance Cybersecurity Data Protection Enforcement FINRA Hedge Funds Insider Trading Money Laundering Non-Enforcement Private Placements SEC

A Compilation of Enforcement and Non-Enforcement Actions - December 28, 2012

In This Issue: Non-Enforcement Matters: - New SEC Registrants Under Dodd-Frank to Be Focus of SEC Examination Program - FINRA Rule 5123 Revisited Enforcement Matters: - SEC Accuses...more

12/28/2012 - Board of Directors Dodd-Frank Enforcement Fiduciary Duty FINRA Hedge Funds Investment Adviser SEC

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