Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion
Once upon a time, in 1994, when I was a young lawyer in the SEC’s Division of Investment Management (Division), Office of Chief Counsel, we received a request to modify a previously granted but totally impractical no-action...more
On July 21, 2021, the Division of Examinations (“Exams”) issued a risk alert on principal and cross trading practices by investment advisers (the “Risk Alert”). This Risk Alert supplements a prior risk alert published by...more
In This Issue. The federal bank regulatory agencies requested public comment on proposed guidance designed to help banking organizations manage risks associated with third-party relationships; the Office of the Comptroller of...more
On March 11, 2021, the staff of the SEC’s Division of Investment Management issued a statement addressing cross trading among affiliated registered funds and soliciting feedback in this area. The staff issued the statement in...more
In this podcast, Greg Nowak, a partner in Troutman Pepper’s Investment Management and Compliance and Hedge Funds Practice Groups, is joined by Evan Katz, Managing Director of Crawford Ventures, Inc., for a candid review of...more
Last month the SEC brought an enforcement action illustrating how cross trades can trip up a manager of a private fund. The SEC’s settlement with investment manager Lone Star Value Management LLC was based on allegations...more
On September 4, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert regarding principal trading and agency cross transactions under Section...more
Failures by a number of investment advisers to comply with certain rules governing principal and agency cross trades has prompted the compliance inspections staff of the Securities and Exchange Commission (SEC) to issue a...more
The Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) issued a risk alert earlier this month from its national examination program warning investment advisers of the most common...more
In This Issue. The Securities and Exchange Commission (SEC) issued a risk alert on investment adviser principal and agency cross trading compliance issues, published disclosure interpretations relating to the Inline XBRL...more