News & Analysis as of

Investment Advisers Act of 1940 Enforcement Enforcement Actions

Woodruff Sawyer

Looking Into the SEC Future for Financial Services Companies

Woodruff Sawyer on

As new Chair Paul Atkins begins to make his mark on the Securities and Exchange Commission, the news cycle has been heavily focused on crypto regulation. The SEC, however, is more than just a crypto regulator....more

WilmerHale

Recent Pay-to-Play Settlement: Notwithstanding a Strong Dissent Over 206(4)-5 Overbreadth, the Need for Strong Compliance Policies...

WilmerHale on

With political campaign activity ramping up as the fall elections approach, the Securities and Exchange Commission (SEC) has indicated it will continue stringent enforcement of Investment Advisers Act Rule 206(4)-5 (the...more

WilmerHale

Pay-to-Play Update: A Quartet of Recent Settlements Underscores the Breadth of Risk Posed by Rule 206(4)-5

WilmerHale on

With the midterm elections less than a month away and political campaign activity in full swing, the Securities and Exchange Commission (SEC) has demonstrated a renewed interest in “pay-to-play” enforcement after a long...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Proskauer Rose LLP

Repeated Violations of the Custody Rule Result in SEC Administrative Action

Proskauer Rose LLP on

On October 29, 2014, the Securities and Exchange Commission (SEC) announced an administrative proceeding against a registered investment adviser, its principals and its chief compliance and operating officer for violating...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

Foley & Lardner LLP on

SEC Proposes Extension of Principal Trade Rule for Registered Advisers/Broker-Dealers - The SEC has proposed extending to December 31, 2016, the sunset date for the expiration of Rule 206(3)-3T (the “Rule”) under the...more

Goodwin

SEC Settles with Exempt Reporting Adviser over Pay-to-Play Violations

Goodwin on

The SEC settled public administrative proceedings against TL Ventures Inc., a venture capital fund adviser (the “Adviser”), over violations of Rule 206(4)-5 (the “Rule”) under the Investment Advisers Act of 1940 (the...more

Dorsey & Whitney LLP

SEC’s First Advisers Act Pay-To-Play Action

Dorsey & Whitney LLP on

The Commission brought its first pay-to-play action involving political campaign contributions under the Investment Advisers Act. The proceeding is predicated on the integration of two firms which claimed to be exempt from...more

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