The following summarizes recent legal developments of note affecting the mutual fund/investment management industry. On October 21, 2024, the SEC Division of Examinations (“EXAMS”) published its annual Examination Priorities...more
Fund and Investment Management January 2019 (No. 1) REGULATORY UPDATES Policy Initiatives Set Forth by the U.S. Securities and Exchange Commission’s (“SEC”) Investment Management Division On September 28, 2018, Division of...more
New Rules, Proposed Rules, Guidance and Alerts - SEC STAFF GUIDANCE AND ALERTS – SEC Staff No-Action Letter Allows Fund Boards to Rely on CCO Representations for Affiliated Transactions – In a no-action letter to the...more
If a team from the SEC arrives at your office and says, “We are conducting an on-site examination and would like to talk to the CCO right now,” are you prepared? A handful of registered investment advisers have faced surprise...more
This week I have been exploring the different types compliance committee’s which an organization can utilize to help effect a best practices compliance program. I have written about compliance committee’s at the Board of...more
On November 4, 2015, Andrew Ceresney, director of the Securities and Exchange Commission’s (SEC’s) Division of Enforcement (Enforcement Division), delivered the keynote address at the 2015 National Conference of the National...more
One of the things that I am questioned on is when to bring in outside counsel for a Foreign Corrupt Practices Act (FCPA) investigation or simply to take a look at an issue that may have raised a Red Flag but is not yet a FCPA...more
On January 23, 2013, Bruce Karpati, Chief of the Asset Management Unit (the “AMU”) of the Enforcement Division of the Securities and Exchange Commission, addressed the Private Equity International Conference in New York. Mr....more