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Policies and Procedures Investment Adviser Corporate Governance

K&L Gates LLP

What a Relief! Co-Investments Get Easier for Interval Funds, Tender Offer Funds, and Business Development Companies

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The US Securities and Exchange Commission (SEC) has approved a streamlined framework for co-investments involving certain closed-end funds and business development companies (together, Regulated Funds)....more

SEC Compliance Consultants, Inc. (SEC³)

7 Ugly Truths About Compliance: A Primer for New Chief Compliance Officers

Many compliance officers live in hope that if they ramp up their persuasive skills, engage employees with spectacular training presentations, and provide succinct and prompt advice, they will receive the respect and...more

K2 Integrity

[Webinar] Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now? - January 15th,...

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Investment advisers and others involved in the implementation of the new IA AML mandate have been alert to potential ramifications to the rule due to the upcoming change in administration. Upon review, K2 Integrity and...more

Vinson & Elkins LLP

SEC Charges Invesco Advisers for Making Misleading ESG Claims

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On November 8, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced a settled enforcement action (the “SEC Order”) against Invesco Advisers, Inc. (“Invesco”), an investment advisory firm, for making misleading...more

SEC Compliance Consultants, Inc. (SEC³)

How Much Testing is Enough?

Most compliance officers struggle to determine whether they are conducting enough testing to satisfy their obligations under the Advisers Act. In its release adopting Advisers Act Rule 206(4)-7, the SEC stated that an...more

Seward & Kissel LLP

SEC Wins First “Shadow Trading” Trial

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On April 5, 2024, after an eight-day trial, a jury in the U.S. District Court for the Northern District of California returned a verdict for the Securities and Exchange Commission in its first “shadow trading” case after...more

BakerHostetler

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

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The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

Bass, Berry & Sims PLC

A Summary of Certain Proxy Advisory Firm and Institutional Investor Board Diversity Policies

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Institutional investors and proxy advisory firms continue to develop and refine their policies regarding board diversity. While gender diversity on public company boards has been in focus for some time now, institutional...more

Foley Hoag LLP

SEC Brings First Enforcement Action Against Issuer for Disclosures About Financial Effects of COVID-19

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On December 4, 2020, the SEC brought its first case charging a public company, The Cheesecake Factory, with making misleading disclosures about the effects of COVID-19 on its business operations and financial condition. The...more

Carlton Fields

OCIE Risk Alert Highlights Compliance Program Catch-22

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A risk alert issued on November 7, 2019, by the SEC’s Office of Compliance Inspections and Examinations underscores a continuing dilemma faced by SEC-regulated entities....more

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