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Policies and Procedures › Investment Advisers Act of 1940 › Insider Trading

Seward & Kissel LLP

SEC Voluntarily Dismisses Action against Hedge Fund Manager over Safeguarding Confidential Information while Participating on...

Seward & Kissel LLP on

On April 7, 2024, the United States District Court for the District of Connecticut approved the Securities and Exchange Commission’s request to dismiss its action against a hedge fund manager for the manager’s alleged failure...more

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

Cozen O'Connor

SEC Asserts Enforcement Authority for Inadequate 204A Policies and Procedures Despite No MNPI Misuse

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On August 26, 2024, it was not the first time the SEC settled charges with a Registered Investment Adviser (RIA) for willfully violating Section 204A of the Investment Advisers Act (204A) by failing to establish, maintain and...more

Foley Hoag LLP

SEC Division of Enforcement Warns of COVID19 Insider Trading Risks

Foley Hoag LLP on

On March 23, the SEC Division of Enforcement (Enforcement) issued a public statement bluntly warning issuers and insiders connected to them, along with broker-dealers and investment advisers, about the unique risks of insider...more

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