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Troutman Pepper Locke

FUNDamentals: Form N-PX — Institutional Investment Managers Must File, Even if No ‎Proxies Were Voted

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With Form ADV annual updating amendments due for many investment advisers by the end of next month, advisers should consider whether to update their proxy voting policies and related disclosure in Part 2A, Item 17 in light of...more

SEC Compliance Consultants, Inc. (SEC³)

The Most Wonderful Time of the Year: Form ADV Season

SEC Compliance Consultants, Inc. (SEC³) on

For most investment advisers, March signals the beginning of Form ADV season, where compliance officers gather all kinds of firm data to update a document fraught with potential regulatory liability. For the uninitiated, Form...more

Royer Cooper Cohen Braunfeld LLC

The New Marketing Rule: Notes from the Field

Royer Cooper Cohen Braunfeld LLC on

On April 17th, the SEC issued a Risk Alert titled “Initial Observations Regarding Advisers Act Marketing Rule Compliance.” Perusing the list of failures, a sense of familiarity arose, given that one of our clients had been...more

BCLP

SEC Risk Alert on Compliance with the Marketing Rule-Examination Observations

BCLP on

On April 17, 2024, the Division of Examinations (the “Division”) of the Securities and Exchange Commission (the “SEC”) published a Risk Alert entitled: “Initial Observations Regarding Advisers Act Marketing Rule Compliance”...more

Tannenbaum Helpern Syracuse & Hirschtritt LLP

SEC’s Recent Enforcement Sweeps Targeting Off-Channel Communications of Fund Advisers

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In this time of continuing digital transformation, the use of smartphones and messaging apps, such as WhatsApp, Signal, iMessage, Facebook Messenger, WeChat, and Telegram, has become increasingly popular in business practice....more

WilmerHale

SEC’s Final Rules and Guidance on the Standards of Conduct for Broker-Dealers and Investment Advisers

WilmerHale on

On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) in a divided 3-1 vote, approved a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’...more

Katten Muchin Rosenman LLP

DC Circuit Decision Against Investment Adviser Leaves Many Unanswered Questions

Katten Muchin Rosenman LLP on

On April 30, 2019, US Court of Appeals for the DC Circuit decided an important case involving the disclosure obligations of investment advisers. The case decided that an adviser’s disclosure that it “may” have a conflict of...more

Carlton Fields

SEC Proposes New Standards Of Conduct For Broker-Dealers And Investment Advisers

Carlton Fields on

On April 18, the SEC voted four to one to propose new standards of conduct for broker-dealers (BDs) and investment advisers (IAs)....more

Herbert Smith Freehills Kramer

Funds Talk: March 2017

Herbert Smith Freehills Kramer on

OCIE Highlights Frequent Topics for Compliance Deficiencies for Investment Advisers - On Feb. 7, 2017, the Securities and Exchange Commission’s (SEC’s) Office of Compliance Inspections and Examinations (“OCIE”) published...more

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