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Policies and Procedures Compliance Insider Trading

Seward & Kissel LLP

SEC Charges Investment Adviser with Compliance Policy Failures Regarding its Handling of Material Nonpublic Information

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Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC charged a hedge fund manager registered as an investment adviser (Adviser) with failing to...more

Snell & Wilmer

SEC Reporting Update - December 2024

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Insider Trading Policies. As previously discussed in our Winter 2022-2023 Corporate Communicator, the Securities and Exchange Commission (“SEC”) adopted final rules in December 2022 relating to insider trading policy...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

Lowenstein Sandler LLP

SEC Settlement Reflects Continued Scrutiny Regarding MNPI, Advertisements and Investor Communications

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On December 26, 2023, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser, OEP Capital Advisors, L.P. (OEP). The settlement found that OEP had failed (a) to maintain...more

Bracewell LLP

Personal Devices and Messaging Platforms in the Workplace: Tips, Tactics and Best Practices for In-House Counsel

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Federal regulators have cracked down on the use of texts messages and messaging platforms for business communications, using their broad authority to root out record retention violations, resulting in significant fines and...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

Sheppard Mullin Richter & Hampton LLP

NFT Insider Trading Compliance Policies – What They Cover and Why You Need One

It is well known that insider trading—the practice of buying and selling stocks, bonds, or other securities based on material, non-public information—is unlawful. For that reason, many companies have compliance programs and...more

Faegre Drinker Biddle & Reath LLP

Ubiquitous Use of WhatsApp and Other Unrecorded Internal Communications Result in Substantial Penalties in Recent SEC, CFTC...

The SEC has, for many years, used broker-dealer and associated persons’ failure to create and maintain books and records as a basis for the imposition of serious penalties. In recent actions, it appears to be continuing—and...more

McDermott Will & Emery

[Webinar] Hedge Fund Legal & Compliance Roundtable - March 3rd, 4:30 pm - 5:30 pm EST

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Join us for a virtual roundtable discussion regarding the changing securities regulatory and enforcement landscape. The election of Joe Biden and his subsequent nomination of Gary Gensler as the next chairman of the US...more

Foley Hoag LLP

SEC Brings First Enforcement Action Against Issuer for Disclosures About Financial Effects of COVID-19

Foley Hoag LLP on

On December 4, 2020, the SEC brought its first case charging a public company, The Cheesecake Factory, with making misleading disclosures about the effects of COVID-19 on its business operations and financial condition. The...more

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