SEC’s Recent Actions Against Two Investment Advisers Raise Important Lessons for All Investment Advisers

Recently announced cases against two registered investment advisers and certain of their executives serve as timely reminders of where the SEC is focusing its attention. Although the SEC’s actions are based on alleged intentional violations or disregard of certain regulations, they include important lessons for law-abiding registered investment advisers. Advisers should be aware of the SEC’s focus areas and ensure that the annual review of their compliance program addresses policies related to, among other things:

..their trading policies and, specifically, whether they are conducting any undisclosed principal trading;

..whether they have custody of client assets and, if so, the need to comply with the custody rule;

..whether their compliance policies and program adequately and specifically address their business structures...

Please see full alert below for more information.

LOADING PDF: If there are any problems, click here to download the file.


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Morrison & Foerster LLP - Broker-Dealer Compliance + Regulation | Attorney Advertising

Written by:

more+
less-

Morrison & Foerster LLP - Broker-Dealer Compliance + Regulation on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×
Loading...
×
×