David S. Petron

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.

Oct 5, 2023 | datamatters.sidley.com | Stephen Cohen |Ranah Esmaili |Lara Shalov Mehraban |David S. Petron

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...

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...