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Dual-Hatted CEO and CCO Named Individually in SEC Settlement for Compliance Violations

On December 5, 2022, the SEC filed a settled action against investment advisory firm Two Point Capital Management Inc. (the Firm) and its chief executive officer, who also served as the Firm’s chief compliance officer until...more

The SEC’s Latest CCO Case and the Ongoing Need for a Framework

On June 30, 2022, the SEC filed a settled action against Hamilton Investment Counsel, LLC (the “Firm”) and its chief compliance officer (“HIC CCO”). Notably, the SEC charged the HIC CCO with willfully aiding and abetting the...more

Lessons Learned From OCIE’s Inspections of Investment Adviser Compliance Programs

The Office of Compliance Inspections and Examinations (OCIE) issued a risk alert on November 19, 2020 related to the Advisers Act compliance rule, Rule 206(4)-7. Some key takeaways for Chief Compliance Officers (CCOs) are as...more

Foley Governance and Regulatory Alert: Dangers of Chief Compliance Officer Backdating Documents

The Securities and Exchange Commission (“Commission” or “SEC”) recently instituted settled administrative and cease-and-desist proceedings against a chief compliance officer of a registered investment adviser for record...more

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