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SEC Proposes Enhancements to Regulation S-P

Last week, the Securities and Exchange Commission (the “SEC”) proposed amendments to Regulation S-P (the “Proposal”) that would require registered investment advisers (“RIAs”), broker-dealers (“BDs”), investment companies...more

SEC Sanctions Registered Broker-Dealer in First-Ever Section 11 Enforcement Proceeding

In a recent administrative order (the “Order”), the Securities and Exchange Commission (the “SEC”) charged a registered broker-dealer (the “Broker-Dealer”) with improper switching or replacing of variable annuities in...more

SEC's Division of Examinations Releases 2022 Examination Priorities

Each year, the SEC’s Division of Examinations (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their compliance...more

SEC Continues Focus on Conflicts Disclosures in Enforcement Actions Totaling $106 Million in Fines and Disgorgement

The U.S. Securities and Exchange Commission (the “Commission”) recently entered into four consent orders (collectively, the “Orders” and each, an “Order”) with registered investment advisers (“RIAs” and each, an “RIA”) that...more

Securities Regulators Focus on Forgivable Recruitment Loans/Bonuses, Social Media Influencers, and Rescission Offers

In recent weeks, we have observed significant new developments in securities regulation related to two enforcement actions by the U.S. Securities and Exchange Commission (the “Commission”) and an unexpected (and, to our...more

SEC Sanctions Firm for Policies that (Theoretically Could Have) Curtailed Whistleblowers

On June 23, 2021, the U.S. Securities and Exchange Commission (the “Commission”) entered an administrative order1 (the “Order”) that, among other things, fined a broker-dealer (“BD”) $208,912 for alleged violations of Rule...more

SEC Division of Examinations Releases 2021 Examination Priorities

Each year, the SEC’s Division of Examinations (f.k.a. OCIE) (the “Division”) releases its priorities for the upcoming year, providing SEC registrants with a helpful tool to assist in managing, reviewing, and updating their...more

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