The Office of the Chief Accountant of the SEC’s Division of Investment Management periodically issues “Dear Chief Financial Officer” letters to help registered investment companies, business development companies (BDCs), and...more
In an offshoot of its enforcement action against Apollo Management L.P. (Apollo) last year, the Securities and Exchange Commission (SEC) on October 25 charged a former senior partner at Apollo with defrauding his fund clients...more
The SEC’s focus in the action was not on the manner of the firm’s responses to the breach or whether there was any actual harm, but predominantly on the adequacy of the firm’s written policies for safeguarding customer...more
9/24/2015
/ Client Data ,
Compliance ,
Cyber Attacks ,
Cyber Crimes ,
Cyber Threats ,
Cybersecurity ,
Data Breach ,
Data Security ,
Enforcement Actions ,
Hackers ,
Investment Adviser ,
OCIE ,
Popular ,
Privacy Policy ,
Securities and Exchange Commission (SEC)
The SEC’s order provides significant guidance on how the SEC staff will scrutinize the propriety of payments made pursuant to commonly occurring agreements between mutual funds and their service providers and with respect to...more
9/23/2015
/ Dealers ,
Enforcement Actions ,
Financial Institutions ,
Financial Markets ,
Intermediaries ,
Investment Adviser ,
Investment Companies ,
Investment Company Act of 1940 ,
Mutual Funds ,
Securities and Exchange Commission (SEC) ,
Shareholders