While there is a lot of buzz this week related to the Proposed Amendments to Form PF, we are mindful that final rules often look very
The SEC brought sanctions against three firms (and related entities) registered as broker-dealers, investment advisers, or both, for cybersecurity failures. Between 2017 and 2021 each firm experienced
As we wrote last month, the SEC has been full throttle in targeting firms for enforcement for failing to file and deliver Form CRS where
SEC staffers have long asserted that their efforts are informed by a risk-based assessment in selecting registrants for examination. A key component of this has
The SEC is full throttle ahead currently targeting multiple firms for enforcement related to failure to file Form CRS. The SEC originally gave companies some
We want to take the opportunity to share a few significant items put out by the SEC last month. Enforcement Annual Report On November 2,
