Barry W. Rashkover

Oct 4, 2023 | lexology.com | Stephen Cohen |Ranah Esmaili |Lara Shalov Mehraban |Barry W. Rashkover |John I. Sakhleh |Lara C. Thyagarajan | +2 more

On September 29, 2023 — the last business day of its fiscal year — the U.S. Securities and Exchange Commission (SEC) issued the latest in a series of actions charging 10 firms with recordkeeping failures in connection with employees’ use of unapproved applications on personal devices to engage in communications relating to the firms’ business (known as “off-channel communications”).1 The firms charged included broker-dealers, investment advisers, and dually registered broker-dealers and...

Sep 13, 2023 | lexology.com | W. Hardy Callcott |Stephen Cohen |Ranah Esmaili |Elizabeth Shea Fries |Lara Shalov Mehraban |Barry W. Rashkover | +2 more

On September 11, 2023, the U.S. Securities and Exchange Commission (SEC) announced settled charges against nine registered investment advisers arising out of violations of the investment adviser marketing rule (the Marketing Rule).1 Under the Marketing Rule, which was amended in December 2020, registered investment advisers are prohibited from including any hypothetical performance in their advertisements unless they have adopted and implemented policies and procedures reasonably designed to...

Feb 16, 2023 | lexology.com | Ike Adams |Sonia Gupta Barros |Stephen Cohen |John P. Kelsh |Barry W. Rashkover |Andrea Reed | +1 more

On February 3, 2023, the U.S. Securities and Exchange Commission (SEC or Commission) settled an enforcement action against Activision Blizzard Inc. (Activision), a publicly traded video game development and publishing company.