The Tennessee Securities Division, Department of Commerce and Insurance (Julie Mix McPeak, Comm’r) recently confirmed its launch of a comprehensive three-year cycle examination program covering all Tennessee-based...more
SEC Commissioners Piwowar and Gallagher dissented from a recent Commission Opinion sanctioning an investment adviser’s use of misleading historical data purporting to validate an asset-allocation model. Agreeing there was a...more
A week after OCIE announced it would conduct a second round of cyber-security exams, the Commission emphasized the issue by bringing an enforcement action against a non-custodial investment-adviser over a remediated data...more
9/25/2015
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The District of Columbia Circuit Court of Appeals Tuesday rejected a challenge to the SEC’s investment-adviser pay-to-play rule, holding that two state Republican Party organizations filed it almost four years too late....more
The District of Columbia Circuit Court of Appeals Tuesday rejected a challenge to the SEC’s investment-adviser pay-to-play rule, holding that New York and Tennessee Republican-Party organizations filed it almost four years...more
In mid-June, SEC Commissioner Gallagher issued a strongly-worded public dissent from two enforcement actions against investment-adviser CCOs, accusing the Commission of “cutting off its nose to spite its face” by punishing...more
SEC Administrative Law Judge Grimes dismissed administrative charges against an investment adviser and its principals for allegedly failing to disclose material conflicts of interest in its Form ADV and willfully filing false...more
In a strongly-worded public statement last week, SEC Commissioner Gallagher chided the Commission for “cutting off the noses of CCO’s to spite its face.” Explaining his dissent in two recent enforcement actions imposing...more
The SEC’s Office of Compliance Inspections and Examinations (“OCIE”) released its 2015 Exam Priorities January 13. Director Andrew Bowden’s annual list details OCIE’s subject of focus for the coming year....more
On September 30, the D.C. District Court rejected two GOP state committees’ challenge to the SEC’s regulation prohibiting pay-to-play among investment advisors. Bowing to “curious” precedent in which words don’t mean what...more