Christopher Mills

Apr 10, 2024 | lexology.com | Stephen Cohen |Chuck Daly |Ranah Esmaili |Lara Shalov Mehraban |Christopher Mills |David S. Petron | +2 more

On April 3, 2024, the U.S. Securities and Exchange Commission (SEC or Commission) announced an off-channel communications enforcement action that was the first such action against a private fund adviser and the first off-channel case against a standalone investment adviser since the SEC launched investigative sweeps focused on off-channel communications in 2022.1 The matter marks the latest in a series of enforcement actions for communications-related recordkeeping failures.