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Oct 30, 2024 | 
mondaq.com | Alex Lipton |Jeremy Cantor |Scott Moss
On September 20, 2024, the U.S. Securities and Exchange
Commission (SEC) announced a settlement with an investment adviser
for, among other things, failure to register with the SEC as an
investment adviser. The SEC found that the unregistered investment
adviser was "operationally integrated" with its
SEC-registered affiliate such that the two entities should have
been treated as one for purposes of determining registration
requirements.
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Oct 29, 2024 | 
jdsupra.com | Jeremy Cantor |Alex Lipton |Scott Moss
On September 20, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with an investment adviser for, among other things, failure to register with the SEC as an investment adviser. The SEC found that the unregistered investment adviser was “operationally integrated” with its SEC-registered affiliate such that the two entities should have been treated as one for purposes of determining registration requirements.
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Sep 9, 2024 | 
mondaq.com | Jeremy Cantor |Scott Moss |Sara Lazarevic
On August 14, 2024, the U.S. Securities and Exchange Commission
(SEC) announced another series of settlements regarding
"off-channel communications."1 As part of its
Off-Channel Communications Initiative,2 the SEC settled
with 11 broker-dealers, three investment advisers, and 11
dual-registered broker-dealers and investment advisers
(collectively, the Firms) for a combined $392.75 million in fees
related to widespread recordkeeping failures by such firms.
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Sep 9, 2024 | 
mondaq.com | Jeremy Cantor |Scott Moss |Sara Lazarevic
On August 21, 2024, the U.S. Securities and Exchange Commission
(SEC) adopted a rule (Final Rule) that will increase the threshold
for what is considered a "qualifying venture capital
fund" from $10,000,000 to $12,000,000.1 The Final
Rule will take effect on September 30, 2024.
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Sep 9, 2024 | 
jdsupra.com | Jeremy Cantor |Sara Lazarevic |Scott Moss
On August 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced another series of settlements regarding “off-channel communications.”1 As part of its Off-Channel Communications Initiative,2 the SEC settled with 11 broker-dealers, three investment advisers, and 11 dual-registered broker-dealers and investment advisers (collectively, the Firms) for a combined $392.75 million in fees related to widespread recordkeeping failures by such firms.
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Sep 6, 2024 | 
jdsupra.com | Jeremy Cantor |Sara Lazarevic |Scott Moss
On August 21, 2024, the U.S. Securities and Exchange Commission (SEC) adopted a rule (Final Rule) that will increase the threshold for what is considered a “qualifying venture capital fund” from $10,000,000 to $12,000,000.1 The Final Rule will take effect on September 30, 2024.
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Sep 5, 2024 | 
mondaq.com | Scott Moss |Jimmy Kang |Jeremy Cantor |Sara Lazarevic
On August 19, 2024, the U.S. Securities and Exchange Commission
(SEC) settled with a registered investment adviser
(Adviser),1 whereby the Adviser paid a $95,000 civil
money penalty in addition to being censured for violations of Rule
206(4)-5, the SEC's "pay-to-play" rule for investment
advisers (Pay-to-Play Rule).2 As we have previously
written,3 the SEC continues to take a vigorous approach
with respect to Pay-to-Play Rule-related enforcement actions.
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Sep 5, 2024 | 
mondaq.com | Scott Moss |Jeremy Cantor
On August 26, 2024, the Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (RIA)1 for failing to establish, maintain and enforce adequate written policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) as it relates to the trading of collateralized loan obligations (CLOs).2 More specifically, this settlement related to trading a CLO while in possession of MNPI of a company whose loans were...
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Sep 5, 2024 | 
jdsupra.com | Jeremy Cantor |Scott Moss |Maddie Loewenguth
On August 26, 2024, the Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (RIA)1 for failing to establish, maintain and enforce adequate written policies and procedures reasonably designed to prevent the misuse of material nonpublic information (MNPI) as it relates to the trading of collateralized loan obligations (CLOs).2 More specifically, this settlement related to trading a CLO while in possession of MNPI of a company whose loans were...
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Sep 5, 2024 | 
jdsupra.com | Jeremy Cantor |Jimmy Kang |Sara Lazarevic
On August 19, 2024, the U.S. Securities and Exchange Commission (SEC) settled with a registered investment adviser (Adviser),1 whereby the Adviser paid a $95,000 civil money penalty in addition to being censured for violations of Rule 206(4)-5, the SEC’s “pay-to-play” rule for investment advisers (Pay-to-Play Rule).2 As we have previously written,3 the SEC continues to take a vigorous approach with respect to Pay-to-Play Rule-related enforcement actions.
