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Asset Management Regulatory Year in Review 2024

2024 was a year of meaningful regulatory change for asset managers globally. The regulatory activity was wide ranging and without a particular unifying theme. In fact, the wide, and in cases diverging focuses of key global...more

“Oops, I was a Broker!?” SEC Cracks Down on Investment Adviser Representatives Acting as Unregistered Brokers

On 14 January 2025, the Securities and Exchange Commission (SEC) announced settled charges against three investment adviser representatives for acting as unregistered brokers in the sale of membership interests in certain...more

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

SEC Staff Identifies Several Paths to “Inadvertent Custody” Under the Advisers Act Custody Rule

Last week, the staff of the Securities and Exchange Commission (“SEC”) clarified its views on certain arrangements that can result in investment advisers having “custody” of client assets, as defined in rule 206(4)-2 (the...more

SEC Fines Alternative Mutual Fund Adviser for Improper Handling of Fund Assets

On February 12, 2015, the Securities and Exchange Commission (“SEC”) brought and settled charges against an investment adviser to several alternative mutual funds alleging, among other charges, failure to comply with the...more

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