Emily Fulginiti

Emily Fulginiti

Cozen O'Connor

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

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

10/18/2024  /  Collateralized Loan Obligations , Insider Trading , Investment Adviser , Investment Advisers Act of 1940 , Misuse of Information , MNPI , Policies and Procedures , Portfolio Managers , Registered Investment Advisors , Securities and Exchange Commission (SEC)
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