On January 13, 2025, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against twelve firms for recordkeeping failures related to off-channel communications – i.e., failure to maintain business...more
1/28/2025
/ Broker-Dealer ,
Corporate Communications ,
Corporate Governance ,
Electronic Communications ,
Enforcement Actions ,
Penalties ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation
On December 20, 2024, the U.S. Securities and Exchange Commission (the “SEC”) issued a press release highlighting settled enforcement actions against a private fund adviser and two pre-IPO companies for failure to timely file...more
1/3/2025
/ Blue Sky Laws ,
Corporate Governance ,
Enforcement Actions ,
Form ADV ,
Form D Filing ,
Preemption ,
Private Funds ,
Securities Act of 1933 ,
Securities and Exchange Commission (SEC) ,
Startups ,
Unregistered Securities
A recent Securities and Exchange Commission (“SEC”) settled enforcement action serves as an excellent reminder of the risk of operational integration to firms that operate multiple advisory entities, especially where one of...more
10/7/2024
/ Affiliates ,
Cease and Desist ,
Civil Monetary Penalty ,
Compliance ,
Custody Rule ,
Enforcement Actions ,
Exemptions ,
Investment Adviser ,
Private Funds ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On August 14, 2024 the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against 26 SEC-registered investment advisers, broker-dealers and dually-registered broker-dealers and investment advisers...more
9/3/2024
/ Broker-Dealer ,
Civil Monetary Penalty ,
Compliance ,
Data Preservation ,
Electronic Communications ,
Enforcement Actions ,
Investment Adviser ,
Mobile Devices ,
Recordkeeping Requirements ,
Regular Business Communications ,
Securities and Exchange Commission (SEC) ,
Settlement
On April 12, 2024, the U.S. Securities and Exchange Commission (the “SEC”) announced settled charges against five registered investment advisers for violations of Rule 206(4)-1 (the “Marketing Rule”) under the Investment...more
On February 9, 2024 the U.S. Securities and Exchange Commission (the “SEC”) announced charges against 16 registered investment advisers and broker-dealers for pervasive recordkeeping failures related to off-channel...more
2/16/2024
/ Broker-Dealer ,
Compliance ,
Data Preservation ,
Electronic Communications ,
Enforcement Actions ,
Instant Messaging Apps ,
Mobile Devices ,
Penalties ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On September 11, 2023 the U.S. Securities and Exchange Commission (the “SEC”) announced charges against nine registered investment advisers for advertising hypothetical performance to the general public on their websites...more