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Investment Advisers Act of 1940 Regulatory Requirements Regulatory Oversight

Proskauer Rose LLP

SEC Cites Falsified Compliance Records in Two Recent SEC Settlements with CCOs

Proskauer Rose LLP on

Two SEC enforcement actions from earlier this month, each including charges against a firm’s Chief Compliance Officer in their personal capacity, underscore the importance of maintaining accurate records and upholding...more

Cadwalader, Wickersham & Taft LLP

SEC Proposes Rule Amendments Designed to Expand Access to Private Investment Opportunities

By a 3-2 vote, the Securities and Exchange Commission (the “SEC”) approved the publication of a release on December 18, 2019, generally expanding the scope of the definitions of “accredited investor” in Rule 501(a) of...more

WilmerHale

OCIE Issues Risk Alert Regarding Advisers and Principal and Agency Cross Trading

WilmerHale on

On September 4, 2019, the Securities and Exchange Commission’s (SEC) Office of Compliance Inspections and Examinations (OCIE) released a new Risk Alert regarding principal trading and agency cross transactions under Section...more

Proskauer Rose LLP

Regulation of Custodial Practices Under the Investment Advisers Act of 1940 Rule 206(4)-2: October 2019

Proskauer Rose LLP on

Adoption in 1962 - The SEC has regulated custodial practices of investment advisers since 1962, when it first adopted rule 206(4)-2 (the “Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”) under...more

Herbert Smith Freehills Kramer

OCIE Notifies Investment Advisers of Principal and Agency Cross Trading Compliance Deficiencies

Failures by a number of investment advisers to comply with certain rules governing principal and agency cross trades has prompted the compliance inspections staff of the Securities and Exchange Commission (SEC) to issue a...more

Herbert Smith Freehills Kramer

OCIE Warns Advisers Regarding Best Execution Obligations

On July 11, 2018, the Securities and Exchange Commission (SEC) issued a risk alert outlining certain compliance issues identified by its Office of Compliance Inspections and Examinations (OCIE) related to the obligation to...more

Stinson - Corporate & Securities Law Blog

SEC Charges 13 Private Fund Advisers for Failure to File Form PF

The SEC announced settlements with 13 registered private fund investment advisers who repeatedly failed to provide required information that the agency uses to monitor risk. ...more

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