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Policies and Procedures Material Nonpublic Information Enforcement Actions

WilmerHale

SEC Enforcement Actions Reflect Expanding Focus on Advisers’ Policies and Procedures to Prevent Misuse of Material Nonpublic...

WilmerHale on

The Securities and Exchange Commission (SEC) recently brought settled enforcement actions against two registered investment advisers for failing to establish, maintain, and enforce written policies and procedures reasonably...more

WilmerHale

SEC Sanctions CLO Manager for Inadequate Polices to Prevent Nonpublic Information Misuse

WilmerHale on

On August 26, 2024, the Securities and Exchange Commission (SEC) announced an order against a registered investment adviser, Sound Point Capital Management, LP, for its failure to “establish, maintain, and enforce written...more

Fenwick & West LLP

SEC Fines Life Sciences Company for Regulation FD Violations

Fenwick & West LLP on

For the first time in six years, the U.S. Securities and Exchange Commission issued an enforcement action against a company solely for Regulation FD violations. On Aug. 20, the SEC announced that it charged life sciences...more

Jones Day

CFTC Announces Insider Trading Task Force and New Insider Trading Case

Jones Day on

Commodity brokerage firms need to be vigilant as the CFTC signals increased policing and prosecution of insider trading. The Commodity Futures Trading Commission ("CFTC") filed a complaint on September 28, 2018, in the...more

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