News & Analysis as of

Electronic Communications Policies and Procedures Settlement

Seward & Kissel LLP

SEC Settles Charges with Adviser for Recordkeeping Violations and Staff Lays Out Factors Considered in Determining What Penalties...

Seward & Kissel LLP on

Who may be interested: Investment Advisers, Broker-Dealers - Quick Take: The SEC settled charges against an investment adviser for widespread recordkeeping deficiencies related to the adviser’s failure to obtain, maintain...more

K&L Gates LLP

The SEC Fines Stand-Alone Adviser for Off-Channel Communications

K&L Gates LLP on

Overview - On 3 April 2024, the US Securities and Exchange Commission (the SEC) announced the first settlement with a stand-alone registered investment adviser for, among other things, failures to maintain and preserve...more

Lowenstein Sandler LLP

SEC Settlement Highlights Continued Scrutiny of Off-Channel Communications

Lowenstein Sandler LLP on

On April 3, 2024, the U.S. Securities and Exchange Commission (SEC) announced yet another settlement regarding “off-channel communications.” As we have previously written about, settlements of this type have become...more

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