Guidance clarifies assessment of liability under Rule 3110, including designation as supervisor, application of reasonableness standard, and factors for and against charging compliance officials.
On March 17, 2022, the...more
Recent actions reinforce the SEC’s commitment to applying traditional securities markets regulation in the cryptocurrency markets.
The US Securities and Exchange Commission (SEC, or the Commission) recently issued a public...more
The action underscores the need for investment advisers and broker-dealers to maintain robust policies and controls when utilizing third-party contractors.
On May 27, 2016, the Securities and Exchange Commission (SEC)...more
The action may have significant implications for PE advisers performing brokerage services; highlights SEC’s focus on advisers receiving transaction-based compensation.
On June 1, 2016, the Securities and Exchange...more
6/29/2016
/ Broker-Dealer ,
Investment Advisers Act of 1940 ,
Management Fees ,
Neither Admit Nor Deny Settlements ,
Offsets ,
Portfolio Companies ,
Private Equity ,
Private Funds ,
Registration Requirement ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Transaction-Based Compensation
Broker-dealers with historical or ongoing instances of non-compliance with the SEC’s Customer Protection Rule are encouraged to self-report by November 1, 2016.
On June 23, 2016, the Securities and Exchange...more
6/29/2016
/ Broker-Dealer ,
Compliance ,
Cooperation ,
Customer Protection Rule ,
Financial Industry Regulatory Authority (FINRA) ,
Individual Accountability ,
OCIE ,
Section 15(c) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Self-Reporting
The Ninth Circuit’s recent decision calls into question the Second Circuit’s definition of “personal benefit” for insider trading liability in criminal prosecutions.
On July 6, 2015, United States District Court Judge...more
7/13/2015
/ Broker-Dealer ,
Enforcement Actions ,
Hedge Funds ,
Illegal Tipping ,
Insider Trading ,
Judge Rakoff ,
Material Nonpublic Information ,
Personal Benefit ,
Popular ,
Securities and Exchange Commission (SEC) ,
US v Newman