Robert Sutton

1 week ago | jdsupra.com | John Mahon |Nathan Schuur |Robert Sutton

On June 12, 2025 the Securities and Exchange Commission (“SEC”) formally withdrew fourteen outstanding rule proposals issued by the prior administration.

Sep 9, 2024 | jdsupra.com | Joshua M. Newville |Robert Pommer |Robert Sutton

In a significant enforcement action, the SEC sanctioned a private fund manager for failing to establish and maintain adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while trading in securities issued by collateralized loan obligation vehicles (CLOs).

Jun 25, 2024 | jdsupra.com | Joshua M. Newville |Robert Pommer |Robert Sutton

On June 14, 2024, the SEC announced an enforcement action settlement with a Pennsylvania-based hedge fund manager for violating the Marketing Rule under the Investment Advisers Act. The SEC found that the adviser had misled investors by advertising a hedge fund’s investment performance based on the investment performance of a single investor in the fund.

May 28, 2024 | jdsupra.com | Leslie Shanklin |Robert Sutton

On May 16, 2024, the U.S. Securities and Exchange Commission (“SEC”) announced the adoption of amendments to Regulation S-P that were proposed last year (“Final Amendments”).[1] The Final Amendments impose enhanced requirements on registered investment advisers, investment companies, broker dealers and transfer agents (“covered firms”) with respect to handling of consumer financial information.

Nov 29, 2023 | jdsupra.com | Benjamin J. Catalano |Robert Sutton

On November 13, 2023, FINRA filed with the SEC a proposal to amendment to Rule 2210 that would create a tailored exception from the general prohibition on projections in marketing materials and other communications with institutional investors, including marketing decks and pitch books for private placements in investment funds and other securities. FINRA Rule 2210(d)(1)(F) currently prohibits any member from including a projected performance in a written communication — retail or institutional.