David Dickstein

Katten Muchin Rosenman LLP

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Client Alert: Proposed SEC Rules for Investment Advisers and Regulated Funds, and New FTC Safeguard Rule Applicable to Private...

On February 9, 2022, the Securities and Exchange Commission (SEC) voted to propose new rule 206(4)-9 under the Investment Advisers Act of 1940 (Advisers Act) and 38a-2 under the Investment Company Act of 1940 (collectively...more

3/4/2022 / Broker-Dealer , Cybersecurity , Fiduciary Duty , Investment Adviser , Investment Advisers Act of 1940 , New Rules , Retail Investors , Securities and Exchange Commission (SEC)

SEC Staff Observes Practices of Private Fund Advisers That Raise Concerns

Investment advisers that manage private funds should promptly review their compliance policies and procedures, practices and disclosures to ensure these address, and are not inconsistent with, the areas of concern raised in a...more

2/14/2022 / Broker-Dealer , Disclosure Requirements , Fiduciary Duty , Investment Adviser , Investment Management , New Rules , Retail Investors , Securities and Exchange Commission (SEC) , Standard of Conduct

Department of Labor Finalizes 18-Month Extension for Simplified Compliance With the BIC Exemption Under the ERISA Fiduciary Advice...

On November 29, the US Department of Labor (DOL) finalized its 18-month extension of the transition period under the Best Interest Contract Exemption (the "BIC Exemption"). As described in Katten's earlier advisory,...more

12/1/2017 / Benefit Plan Sponsors , Best Interest Contract Exemptions , Department of Labor (DOL) , Employee Retirement Income Security Act (ERISA) , Fiduciary Duty , Fiduciary Rule , Financial Services Industry , Investment Adviser , Principal Transaction Exemption , Retirement Plan

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 , Securities and Exchange Commission (SEC)

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