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On January 13, 2025 the U.S. Securities and Exchange Commission (SEC) announced settled Administrative Proceedings against three broker/dealers and nine investment advisers related to electronic communications recordkeeping...more
On January 13, 2025, the U.S. Securities and Exchange Commission announced settled enforcement actions with five registered investment advisers for failing to maintain and preserve internal electronic communications. These...more
The SEC's wave of enforcement actions concerning "off-channel" communications did not abate in 2024. In total, the SEC announced more than 70 firms agreed to pay more than a half-billion dollars combined to settle charges for...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of additional enforcement actions relating to recordkeeping...more
Who may be interested: Registered Investment Advisers, Registered Investment Companies, Compliance Staff - Quick Take: The SEC recently announced a number of enforcement actions relating to recordkeeping failures,...more
On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled...more
On August 14, the U.S. Securities and Exchange Commission (“SEC”) announced yet another wave of enforcement actions related to widespread “off-channel communications,” charging an additional 26 firms with failing to maintain...more
The Securities and Exchange Commission (SEC) announced charges against 26 broker-dealers, investment advisers, and dually-registered firms for widespread and longstanding failures to maintain and preserve electronic...more
Washington D.C., April 3, 2024, the SEC announced charges against registered investment adviser Senvest Management LLC for widespread and longstanding failures to maintain and preserve certain electronic communications, as...more
The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more
The SEC recently announced charges against Senvest Management, LLC (“Senvest”), a registered investment adviser with approximately $3 billion in regulatory assets under management, for failures to maintain and preserve...more
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
On July 26, 2023, the Securities and Exchange Commission (SEC or Commission) narrowly approved (3-2) a proposed rulemaking under the Securities Exchange Act of 1934 (Exchange Act) and the Investment Advisers Act of 1940...more
The Marketing Rule seeks to address evolving changes in advertising and referral practices in the industry – particularly with respect to the use of the Internet, mobile applications, and social media – by providing an...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
• On December 14, the SEC’s OCIE issued a Risk Alert summarizing the findings of its limited-scope examination initiative relating to electronic messaging. • Noting a “pervasive use” of electronic messaging by adviser...more