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Nov 13, 2024 | 
datamatters.sidley.com | W. Hardy Callcott |Stephen Cohen |Chuck Daly |Ranah Esmaili
In its 2024 fiscal year, the U.S. Securities and Exchange Commission brought over 130 enforcement actions against investment advisers and their representatives. This Sidley Update highlights the key areas of focus and notable actions and litigation from the past fiscal year. Please click here to view the full Sidley Update. This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.
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Jul 9, 2024 | 
lexology.com | W. Hardy Callcott |Stephen Cohen |Ranah Esmaili |John I. Sakhleh |Charles Sommers |Daniel P. Atchue
On May 23, 2024, Gurbir S.
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Jun 5, 2024 | 
datamatters.sidley.com | Andrew Blake |Colleen Brown |W. Hardy Callcott |Stephen Cohen
On May 16, 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to its Regulation S-P. These final amendments impose significant cybersecurity requirements for several SEC-registered entities and transfer agents registered with another appropriate regulatory agency, including with respect to these entities’ policies and procedures, incident response and notification procedures, and cybersecurity risk management. Read the full update here.
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Jun 4, 2024 | 
lexology.com | Andrew Blake |Colleen Brown |W. Hardy Callcott |Stephen Cohen |David Lashway |Charles Sommers | +2 more
To view this article you need a PDF viewer such as Adobe Reader. If you can't read this PDF, you can view its text here. Go back to the PDF. USAJune 4 2024On May 16, 2024, the U.S. Securities and Exchange Commission (SEC) adopted amendments to its Regulation S-P.
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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.
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Feb 14, 2024 | 
lexology.com | Paul Tyrrell |Jay G. Baris |Elizabeth Shea Fries |Stephen Cohen |Timothy J. Treanor |Stanley J. Boris | +1 more
On February 13, 2024, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) withdrew its 2015 notice of proposed rulemaking (NPRM) related to registered investment advisers (RIAs) and released a new notice of proposed rulemaking seeking to impose anti-money-laundering/counter-terrorist financing (AML/CTF) program requirements for the U.S. Securities and Exchange Commission (SEC) RIAs along with SEC exempt reporting advisers (ERAs).1 The addition of ERA as a covered investment...
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Dec 23, 2023 | 
montrealgazette.com | Stephen Cohen
Over the course of this year, the harm imposed by new Quebec policies has permeated many important facets of my life. Here are three. Author of the article: • Special to Montreal Gazette • • Article contentMy wife suggested I take a walk. I decided that writing would be more cathartic. We apologize, but this video has failed to load. Try refreshing your browser, ortap here to see other videos from our team. We apologize, but this video has failed to load.
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Oct 27, 2023 | 
datamatters.sidley.com | W. Hardy Callcott |Kevin J. Campion |Stephen Cohen |Ranah Esmaili
On October 16, 2023, the U.S. Securities and Exchange Commission (SEC) Division of Examinations (EXAMS or Division) issued its annual examination priorities, which, for the first time, was published at the start of the SEC’s fiscal year to “better inform investors and registrants of key risks, trends, and examination topics” the Division intends to focus on in the coming year.1 Our Take The October 16 publication of the priorities represents the earliest publication to date in the 10-year...
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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...
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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...
