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Policies and Procedures Investment Adviser Electronically Stored Information

BCLP

Regulators Impose Extraordinary Fine Amounts in Recent Off-Channel Communications Enforcement Actions

BCLP on

The Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) have, in two separate recent settled enforcement actions involving off-channel communications (“OCC”), imposed fine...more

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

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On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

Proskauer - The Capital Commitment

Five Things to Think About Before a Surprise SEC Exam

If a team from the SEC arrives at your office and says, “We are conducting an on-site examination and would like to talk to the CCO right now,” are you prepared? A handful of registered investment advisers have faced surprise...more

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