Investment Adviser MNPI Compliance Issues
The EXAMS staff at the SEC recently released a Risk Alert on the topic of material non-public information and adviser Codes of Ethics. Long cited
2022 Exam Insights and SEC Priorities: Part 1
May 2022 By Janaya Moscony, Brian Robling and John Lukan Click here to read the full article.
2022 Examination Priorities
The 2022 Examination Priorities (“2022 Priorities”) covered many areas of compliance risk under the “focus area” headings, but also highlighted new SEC perspectives as reflected
What Happened to Regulators Focusing on Retail Clients?
As we predicted in our February 2nd Communique, the SEC is proposing new rules that will significantly impact private fund advisers if adopted. The February
The SEC Continues to Improve its Assessments in the Private Fund Space
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
SEC Chairman Gensler Speaks – More Rules and Disclosure?
SEC Chairman Gary Gensler spoke last week, at the Northwestern Pritzker School of Law’s Annual Securities Regulation Institute. After providing a brief history lesson of the first
Happy New Year!
We want to take the opportunity to wish all of our clients, friends, and colleagues the absolute best year ahead. As we move into 2022,
Enforcement Trends – Fiscal Year 2021
The SEC Division of Enforcement recently released its 2021 Annual Report for the fiscal year ended this past September. The report, taking an abbreviated form
Insights on Form CRS Expectations That You Won’t Find in the FAQs
Investment Advisers that serve retail investors are required to maintain Form CRS and deliver it to each such retail investor. According to Rule 204-5 of
SEC Sanctions Firms over Cybersecurity Incident Responses
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
