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SEC Advisory Fees Focus Continues as Reflected in Division of Examinations Risk Alert and Chair Gensler Comments

USA - November 15 2021 Recent comments from U.S. Securities and Exchange Commission (SEC) Chair Gensler at the Institutional Limited Partners Association Summit and an SEC…

Emily P. Gordy, Cheryl L. Haas, Aline McCullough

Pitfalls to Avoid in Investment Adviser Compliance Programs: SEC OCIE Risk Alert

USA - November 24 2020 On November 19, 2020, the SEC’s Office of Compliance Inspections and Examinations (“OCIE”) issued a risk alert, OCIE Observations: Investment Adviser…

Emily P. Gordy, Cheryl L. Haas

FINRA 2.0: FINRA Releases Its 2020 Risk Monitoring and Examination Priorities

USA - January 14 2020 FINRA’s examination program has undergone its most significant reorganization in decades. As stated in a press release, Oct. 1, 2018, FINRA’s goal…

Emily P. Gordy, Cheryl L. Haas, Piper A. Waldron, Molly M. White

SEC Continues Compensation Disclosure Focus With FAQs and Enforcement

USA - November 20 2019 On Oct. 18, 2019, the Securities and Exchange Commission (SEC) Division of Investment Management staff published Frequently Asked Questions Regarding…

Emily P. Gordy, Cheryl L. Haas, Aline McCullough

D.C. Circuit Vacates SEC Sanctions, Says Negligent Omissions Are Not ‘Willful’ Under Advisers Act

USA - May 14 2019 On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing…

Amanda J. Goldstein, Emily P. Gordy, Cheryl L. Haas