News & Analysis as of

Policies and Procedures MNPI Insider Trading

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

Cozen O'Connor

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

Cozen O'Connor on

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

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

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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