SEC Charges Firm for Disclosure and Policies and Procedures Failures
Last week, the Securities and Exchange Commission (“SEC”) announced the settlement of two enforcement actions relating to disclosure and policies and procedures violations involving two
Risk Alert: Examinations Focused on Additional Areas of the Adviser Marketing Rule
On June 8, 2023, the U.S. Securities and Exchange Commission Division of Examinations released a second Risk Alert concerning amended Rule 206(4)-1 (the “Marketing Rule”).
SEC Continues to Charge Firms with Widespread Recordkeeping Failures
Yesterday, the Securities and Exchange Commission (“SEC”) charged HSBC Securities (USA) Inc. and Scotia Capital (USA) Inc. for widespread failures to maintain and preserve electronic communications in
SEC Adopts Amendments to Enhance Private Fund Reporting
Yesterday, the Securities and Exchange Commission (“SEC”) adopted amendments to Form PF that affect advisers to all private equity funds and large hedge fund advisers.
Understanding the Impact of the Proposed Amendments to Beneficial Ownership Reporting
Last Friday, the Securities and Exchange Commission (SEC) reopened the comment period for its proposed amendments to modernize the rules governing beneficial ownership reporting. The
SEC Exam Tips
Tips for SEC Exam Preparedness Before the SEC comes in: Once you are notified of an Exam: New for 2023:
Form PF Reminder for Advisers to Private Funds
As we wrap up another Form ADV season, we here at SEC3 wanted to remind all of our private fund advisers with a calendar fiscal
How to Make Sure Your Newly Registered Adviser is Compliant with the SEC
The Securities and Exchange Commission (“SEC”) issued a Risk Alert on March 27, 2023, Observations from Examinations of Newly Registered Advisers. The Risk Alert focuses
Recent SEC Examination Request Lists – Marketing Section
The Commission has significantly expanded their scope and request of items pertaining to advisers’ marketing content. We have recently gone through a number of exams
Silicon Valley Bank and Investment Advisers
On Friday, March 10, 2023, Silicon Valley Bank (“SVB”) was seized by the Federal Deposit Insurance Corporation (“FDIC”). SVB, a prominent lender in the world
