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Final Private Fund Adviser Rules

On August 23, 2023, the Securities and Exchange Commission (the “SEC”) approved by a 3-2 vote a final rule enacting a series of wide-sweeping changes to the regulation of the private funds industry (the “Final Rule”). While...more

Marketing Rule's Transition Period Set to Expire; SEC Enforcement to Follow

On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) announced that it was adopting amendments under the Advisers Act of 1940 (the “Advisers Act”) to implement a revised Rule 206(4)-1 (the “Marketing...more

SEC Adopts New Marketing Rule for Investment Advisers

On December 22, 2020, the U.S. Securities and Exchange Commission (“SEC”) adopted amendments under the Investment Advisers Act of 1940 modernizing the rules governing investment adviser marketing. The amendments replace and...more

SEC Office of Compliance Inspections and Examinations Issues COVID-19 Risk Alert to Broker-Dealers and Investment Advisers

On August 12, 2020, the SEC Office of Compliance Inspections and Examinations (OCIE) published a Risk Alert that identifies potential issues related to the COVID-19 pandemic for SEC-registered investment advisers and...more

OCIE Risk Alert on Principal and Agency Cross Transactions

On September 4, 2019, the Office of Compliance Inspections and Examinations (“OCIE”) published a risk alert identifying the most frequent compliance issues involving principal and agency cross transactions from exams...more

SEC OCIE Risk Alert Update: Supervision of Disciplined Individuals

On July 23, 2019, the Securities and Exchange Commission’s Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert summarizing the findings of a recent series of exams focused on oversight practices of...more

Investment Adviser Agrees to Pay $5 Million for Compliance Deficiencies in Valuing Client Assets

On June 4, 2019, the Securities and Exchange Commission (“SEC”) announced that Deer Park Road Management Company, LP (“Deer Park”), a prominent private fund manager in the mortgage-backed securities space and registered...more

Possible Examination by SEC of Exempt Reporting Advisers

Marc Wyatt, Acting Director of the Securities and Exchange Commission’s (“SEC”) Office of Compliance Inspections and Examinations (“OCIE”), recently took part in a meeting of the ABA Hedge Fund Sub-Committee on November 20,...more

OCIE Issues Risk Alert Relating to Outsourced Chief Compliance Officers

On November 9, 2015, the Office of Compliance Inspections and Examinations (“OCIE”) released the findings of its Outsourced CCO Initiative, which examined nearly 20 investment advisers and investment companies that are...more

SEC to Recommend Additional Compliance Rules for Investment Advisers

David W. Grim, Director of the SEC’s Division of Investment Management (the “Division”), recently noted in testimony before a U.S. House of Representatives subcommittee that the Division is developing new rule recommendations...more

SEC Issues Cybersecurity Guidance Update for Investment Advisers

On April 28, 2015, the SEC’s Division of Investment Management (the “Division”) issued a Guidance Update regarding the SEC’s initiative to assess cybersecurity preparedness and threats in the securities industry, further...more

SEC Comments Regarding Current Hedge Fund Priorities

On September 12, 2013, the SEC published a recent speech by Norm Champ, Director of the SEC’s Division of Investment Management, in which he notes his views as to current priorities for the SEC in its regulation of hedge fund...more

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