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SEC Charges Five Registered Investment Advisers for Marketing Rule Violations

The US Securities and Exchange Commission (“SEC”) recently settled charges against five registered investment advisers for violations of Rule 206(4)-1 (“Marketing Rule”) under the Investment Advisers Act of 1940, as amended...more

WhatsApp All Over Again: The SEC Brings More Recordkeeping Charges Against Broker-Dealers and Investment Advisers for Off-Channel...

On February 9, 2024, the Securities and Exchange Commission (SEC) announced charges against five broker-dealers, seven dually registered broker-dealers and investment advisers, and four affiliated investment advisers for...more

US Securities and Exchange Commission Division of Examinations 2022 Exam Priorities

On March 30, 2022, the Division of Examinations of the US Securities and Exchange Commission (the “Division” and “SEC,” respectively) announced its examination priorities for 2022. This year’s priorities specifically focus...more

SEC Examinations Division Issues Risk Alert on ESG Products and Services

On April 9, 2021, the Division of Examinations of the US Securities and Exchange Commission (“Division” or “staff”) issued a risk alert to highlight the staff’s observations from its recent examinations of investment...more

SEC’s Division of Examinations 2021 Exam Priorities – Investment Advisers and Investment Companies

On March 3, 2021, the Division of Examinations of the US Securities and Exchange Commission (the “Examinations Division” and “SEC,” respectively) announced its 2021 examination priorities, which, as in previous years, provide...more

SEC Examinations Division Issues Risk Alert Regarding Digital Assets

On February 26, 2021, the Division of Examinations (“Division”) of the US Securities and Exchange Commission (“SEC”) published a risk alert regarding its continued focus on digital assets (“Risk Alert”). The term “digital...more

Fintech Companies Face Investment Company Status Challenges

Fintech companies can face a variety of regulatory challenges under the federal securities laws, including one that often receives minimal attention, namely a company’s status as an “investment company” under the US...more

SEC Adopts Fund of Funds Arrangements Rule

On October 7, 2020, the US Securities and Exchange Commission (“SEC”) adopted a new rule under the Investment Company Act of 1940 (the “Investment Company Act”) with respect to fund of fund arrangements.1 New Rule 12d1-4...more

US SEC Announces Flexibility in Comment Period Closing Dates Due to COVID-19 Challenges

The US Securities and Exchange Commission (“SEC”) recently announced that it will not take final action before April 24, 2020, regarding the following five proposed actions, which have comment periods expiring in March, to...more

SEC Publishes Final Interpretation of Investment Adviser Standard of Conduct

On June 5, 2019, the SEC published an interpretation of the standard of conduct for investment advisers under the Investment Advisers Act of 1940. The objective of the Proposed and Final Interpretations was to reaffirm and...more

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