SEC 2024 Enforcement Results Demonstrate the Importance of Compliance

On November 22, 2024, the SEC announced its enforcement results for fiscal year 2024. The results show that the SEC’s Division of Enforcement (Division) vigorously enforced the federal securities laws by recommending high-impact enforcement actions to address...

SEC Sanctions RIA and its CEO for Failing to Supervise and Unreasonably Delegating Supervisory Responsibilities

A recent enforcement action has significant implications for Registered Investment Advisers (RIAs), especially for those with multiple Investment Adviser Representatives (IARs) and offices. The case illustrates the SEC’s expectations of firms related to their...

The SEC Disciplines RIAs for Undisclosed Conflicts of Interest, Recordkeeping Violations, and Pay to Play Rule Violations

On August 12, 2024, the SEC announced that it had settled charges against a New York-based Registered Investment Adviser (RIA). The SEC ordered the RIA to pay over $6 million and to return funds to clients who were harmed by the firm’s undisclosed conflicts of...

SEC Risk Alert Provides Long-Awaited Guidance on Marketing Rule Compliance

On April 17, 2024, the SEC provided Registered Investment Advisers (RIAs) with its observations regarding firms’ compliance with the Marketing Rule. It is imperative for RIAs to take note of those observations and to be observant as they implement their compliance...

SEC Charges RIA for Failure to Ensure Fair and Equitable Trade Allocations

SEC Renders Judgment on RIA with Compliance Problems On February 16, 2024, the SEC obtained a final judgment against a Registered Investment Adviser (RIA) based in Dallas, Texas. The RIA was previously charged with making false and misleading statements in its Form...

SEC Nails 16 Firms for Widespread Recordkeeping Failures Involving Off-Channel Communications

On February 9, 2024, the SEC ordered sixteen firms to pay more than a combined $81 million in civil penalties to settle charges for widespread and long-term recordkeeping failures. The SEC’s investigations identified pervasive and long-term use of unapproved...