Jimmy Kang

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.

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.

Jun 28, 2024 | law360.com | Scott Moss |Jimmy Kang

By Scott Moss and Jimmy Kang (June 28, 2024, 12:17 PM EDT) -- The U.S. Securities and Exchange Commission's marketing rule, or Rule 206(4)-1 as amended, continues to be an area of focus for the agency.... Law360 is on it, so you are, too. A Law360 subscription puts you at the center of fast-moving legal issues, trends and developments so you can act with speed and confidence.

May 24, 2024 | mondaq.com | Jeremy Cantor |Jimmy Kang |Scott Moss

On May 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (Adviser) that found the Adviser had (a) failed to adequately disclose conflicts pertaining to compensation linked to fund investments that were received by the Adviser's principal (Principal) and (b) improperly provided preferential treatment related to withdrawals.1 The Fund's and the SMA's Film Investments The Adviser advised several separately managed accounts...

May 21, 2024 | jdsupra.com | Jeremy Cantor |Jimmy Kang |Scott Moss

On May 14, 2024, the U.S. Securities and Exchange Commission (SEC) announced a settlement with a registered investment adviser (Adviser) that found the Adviser had (a) failed to adequately disclose conflicts pertaining to compensation linked to fund investments that were received by the Adviser’s principal (Principal) and (b) improperly provided preferential treatment related to withdrawals.1 Background The Fund’s and the SMA’s Film Investments The Adviser advised several separately managed...