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Material Nonpublic Information Securities and Exchange Commission (SEC) Chief Compliance Officers

Goodwin

SEC’s Division of Examinations Issues Risk Alert Regarding MNPI and Code of Ethics Compliance

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On April 26, 2022, the U.S. Securities and Exchange Commission’s (“SEC”) Division of Examinations (“EXAMS”) issued a risk alert concerning deficiencies related to Section 204A of the Investment Advisers Act of 1940 (“Advisers...more

Foley & Lardner LLP

Foley Governance and Regulatory Alert: Dangers of Chief Compliance Officer Backdating Documents

Foley & Lardner LLP on

The Securities and Exchange Commission (“Commission” or “SEC”) recently instituted settled administrative and cease-and-desist proceedings against a chief compliance officer of a registered investment adviser for record...more

Dorsey & Whitney LLP

SEC ALJ: No Sanction For Compliance Official Who Violated Statute

Dorsey & Whitney LLP on

Amid all the concern regarding the selection by the SEC of an administrative rather than a district court forum for brining agency enforcement action comes a decision which has the potential to change the tenor of the debate,...more

Foley & Lardner LLP

A Compilation of Non-Enforcement Actions

Foley & Lardner LLP on

Be Careful to Adhere to Best Practices When Approving Advisory Agreements - The Securities and Exchange Commission instituted and settled an administrative proceeding against an investment adviser, its principal, and...more

Dorsey & Whitney LLP

Wells Fargo Compliance Officer Charged With Altering Document

Dorsey & Whitney LLP on

The acquisition of Burger King by 3G Capital Partners is the matter that just keeps on giving – at least for SEC enforcement. Initially, the Commission brought an action against Wells Fargo broker Waldyr Da Silva Prado Neto,...more

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