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Disclosure Requirements Sanctions Disgorgement

Jones Day

First Circuit Reverses SEC Win in $93 Million Investment Adviser Disclosure Case

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The court rejects the SEC's per se materiality argument and requires proof of a causal connection between the defendant's allegedly inadequate disclosures and purported unlawful profits....more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - SEC Decides Against Mounting an Appeal in Koch Ruling - The July 2015 ruling by the D.C. Circuit Court in Koch v. SEC will apparently not be challenged by the SEC. The Court ruled in that...more

Dorsey & Whitney LLP

SEC Sanctions KKR Over Fee Allocations

Dorsey & Whitney LLP on

The SEC filed its first action involving a private equity fund and broken deal expenses. By the time the Commission discovered the question the firm realized it did not have a disclosure policy, retained a consultant to study...more

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