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...

2023 Compliance Roundup Shows RIAs How to Steer Clear of Problems

It has been a busy year for the SEC from a compliance perspective. You should think about these compliance events as you conduct your annual review of your firm’s policies and procedures. An adviser’s policies and procedures should reflect the firm’s business model,...

SEC’s Division of Examinations Risk Alert Regarding Observations from Examinations of Newly-Registered Advisers

On March 27, 2023, the SEC’s Division of Examinations (Division) published a Risk Alert that will be of great interest to newly-registered investment advisers. The observations will also be invaluable to investment advisers that have been in business for some years....

SEC’s Division of Examinations Announces Its 2023 Priorities

On February 7, 2023, the SEC’s Division of Examinations announced its 2023 examination priorities. These examination priorities are published annually to provide insights into the SEC’s risk-based approach. The publication also identifies areas that present potential...