The Nutter Securities Enforcement Update is a periodic summary of noteworthy recent securities enforcement activity, settlements, decisions, and charges. ...more
The U.S. Securities and Exchange Commission (SEC) has conducted several publicized investigations focused on broker and investment adviser or advisor cherry-picking in recent years. Most recently, the SEC announced on August...more
On September 13, 2022, the U.S. Securities and Exchange Commission (“SEC”) announced a settlement with investment advisory firm Buckman Advisory Group LLC (“Buckman Advisory”) and its CEO Harry Buckman Jr. to settle...more
In late 2020, the SEC adopted1 rule amendments that require SECregistered investment advisers to, by November 4, 2022, switch their compliance regimes from the SEC’s current Advertising and Cash Solicitation Rules (Rules...more
In the last three weeks, the Division of Enforcement of the U.S. Securities and Exchange Commission has filed several complaints and resolved a number of open enforcement actions involving investment advisers. At first...more
SEC Speaks, the annual PLI conference that gives practitioners the chance to hear directly from SEC Staff, was held on October 8 and 9 in a virtual setting. While the conference (like everything else) felt a bit different...more
DOJ's New Guidance for Evaluating Corporate Compliance Programs - Why it matters: On February 8, 2017, the DOJ released, to little fanfare, a new guidance document entitled "Evaluation of Corporate Compliance Programs."...more
The Commission prevailed at trial in a market manipulation case. The trial followed a series of settlements and a grant of summary judgment in the Commission’s favor as to one defendant. The remaining defendant, a former NFL...more
The Commission has increasingly focused on data analysis as an aid to its enforcement program. Two recent cases brought against investment advisers for cherry picking illustrate different facets of the approach....more
The DOJ reiterated its Yates policy this week under which cooperation credit is conditioned on furnishing the Department with the identity of individuals involved in corporate wrongdoing. Officials also noted that part of...more
The Securities and Exchange Commission (the “SEC”) recently announced its enforcement results for fiscal year 2015. The release touted high-impact and first-of their-kind actions, as well as an increase in the number and...more