Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more
8/1/2025
/ Books & Records ,
Chief Compliance Officers ,
Enforcement Actions ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Misleading Statements ,
Penalties ,
Personal Liability ,
Recordkeeping Requirements ,
Registered Investment Advisors ,
Regulatory Oversight ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC)
Last year, we highlighted the risks of filing a Section 220 books and records request post-litigation, citing a case where the Delaware Chancery Court found that such use was an improper attempt to “sue first, ask questions...more
If a team from the SEC arrives at your office and says, “We are conducting an on-site examination and would like to talk to the CCO right now,” are you prepared? A handful of registered investment advisers have faced surprise...more