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Investment Advisers Act of 1940 MNPI Insider Trading

Lowenstein Sandler LLP

Key Considerations for Alternative Data and AI Vendors to Investment Firms: Demonstrating Compliance in the Face of an Evolving...

The Securities and Exchange Commission (SEC) has previously provided guidance through risk alerts, proposed rules, and enforcement actions that outline expectations for registered investment advisers and other financial firms...more

Seward & Kissel LLP

SEC Charges Investment Adviser with Compliance Policy Failures Regarding its Handling of Material Nonpublic Information

Seward & Kissel LLP on

Who may be interested: Registered Investment Companies; Registered Investment Advisers; Compliance Officers - Quick Take: The SEC charged a hedge fund manager registered as an investment adviser (Adviser) with failing to...more

Cozen O'Connor

SEC Asserts Enforcement Authority for Inadequate 204A Policies and Procedures Despite No MNPI Misuse

Cozen O'Connor on

On August 26, 2024, it was not the first time the SEC settled charges with a Registered Investment Adviser (RIA) for willfully violating Section 204A of the Investment Advisers Act (204A) by failing to establish, maintain and...more

Foley & Lardner LLP

SEC Enforcement Actions Impacting Private Fund Advisers for Fiscal Year 2020

Foley & Lardner LLP on

On November 2, 2020, the SEC’s Division of Enforcement issued its 2020 Annual Report for the fiscal year ending September 30, 2020. While the Enforcement Division filed 405 standalone enforcement actions – the lowest total in...more

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