Developments in SEC and FINRA Enforcement and Exams for Investment Advisers and Broker-Dealers: 2024–2025

The US Securities and Exchange Commission (SEC) brought a number of significant enforcement proceedings against investment advisers and broker-dealers in FY 2024 and during the first quarter of FY 2025. If history serves as a guide, we do not expect the new administration to pay less attention to these firms in the coming year. We do, however, anticipate that the SEC, under new leadership, will recommit its focus on fraudulent conduct and trading abuses, especially as it relates to retail investors. This emphasis will have specific implications for investment advisers and broker-dealers. For example, we expect the SEC to expand the use of its data analytics program, which has already resulted in numerous insider trading, cherry-picking, and trade allocation cases involving financial advisors and registered representatives, as discussed below.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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