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Incorrect “Fee Waiver” Formula Leads to Multi-Million Dollar Penalty

On June 16, 2023, the Securities and Exchange Commission (“SEC”) issued a press release announcing a $2.5 million settlement order of an enforcement action (the “Order”) against a multi-trillion dollar registered investment...more

Mind your P’s and P’s – SEC Settles Enforcement Action Related to ESG Policies and Procedures

The Securities and Exchange Commission (the “SEC”) has again set its sights on registrants’ environmental, social, and governance (“ESG”)-related investing. In another major action against registrants involving ESG-related...more

SEC Sanctions Registered Broker-Dealer in First-Ever Section 11 Enforcement Proceeding

In a recent administrative order (the “Order”), the Securities and Exchange Commission (the “SEC”) charged a registered broker-dealer (the “Broker-Dealer”) with improper switching or replacing of variable annuities in...more

SEC Releases Cryptocurrency and Digital Asset Guidance

The SEC published guidance with respect to cryptocurrencies, digital tokens, and similar investments (each a “digital asset”) that is designed to help issuers and others determine whether the applicable digital asset is a...more

Investment Management Regulation: Year in Review

As we prepare for a new year of regulatory initiates and actions, we believe it is important to take inventory of the most significant regulatory events from the past year. True to its word, the SEC focused on reducing...more

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