Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •The SEC’s first “Shadow Trading” trial; •SCOTUS’s...more
In December 2018, the SEC announced two enforcement actions involving business development companies (BDCs) – one against Fifth Street Management, LLC, the former external registered investment adviser to two BDCs, and the...more
Under Rule 204A-1 of the Investment Advisers Act of 1940, a registered investment adviser’s written code of ethics must include requirements for reporting of personal securities holdings and trading activity by the adviser’s...more