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Cross Trading

Proskauer Rose LLP

SEC’s Division of Examinations Publishes Risk Alert on Investment Adviser Principal and Cross Trading Practices

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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

Goodwin

Agencies Publish Notice and Request for Comment on Proposed Interagency Guidance on Third-Party Relationships

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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

Goodwin

SEC Staff Seeks Input on Cross Trading Between Affiliated Funds

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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

Troutman Pepper

Summer Enforcement Action Review; Raising Money in a Pandemic - Investment Management Roundtable Discussion

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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

Proskauer - The Capital Commitment

When is a Cross-Trade a Principal Trade? SEC Brings Enforcement Action Against a Fund Manager That Appears not to Have Understood

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

WilmerHale

OCIE Issues Risk Alert Regarding Advisers and Principal and Agency Cross Trading

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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

Kramer Levin Naftalis & Frankel LLP

OCIE Notifies Investment Advisers of Principal and Agency Cross Trading Compliance Deficiencies

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

Ballard Spahr LLP

OCIE Issues Risk Alert on Principal and Agency Cross-Trading Compliance Issues

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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

Goodwin

Financial Services Weekly News: OCIE Issues Risk Alert On Investment Adviser Principal And Agency Cross Trading Compliance

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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

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