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Policies and Procedures MNPI Enforcement Actions

Seward & Kissel LLP

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

Seward & Kissel LLP on

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

Proskauer Rose LLP

SEC Enforcement Action Underscores Need for MNPI Policies in CLO Trading

Proskauer Rose LLP on

In a significant enforcement action, the SEC sanctioned a private fund manager for failing to establish and maintain adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while...more

Davies Ward Phillips & Vineberg LLP

SEC Adopts Amendments to Insider Trading Rules and Reporting Requirements

In late 2022, the U.S. Securities and Exchange Commission (SEC) adopted final amendments to certain rules and reporting requirements concerning insider trading arrangements, including Rule 10b5-1(c) under the Securities...more

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