On September 25, 2024, the Securities and Exchange Commission (SEC) announced settlements with 23 entities and individuals for untimely reporting related to their respective holdings and transactions in public company stock....more
In a significant enforcement action, the SEC sanctioned a private fund manager for failing to establish and maintain adequate policies and procedures to prevent the misuse of material nonpublic information (MNPI) while...more
On May 15, 2024, the Securities and Exchange Commission (the “SEC”) issued final amendments (the “Amendments”) to Regulation S-P (originally adopted in 2000), which governs the treatment of a customer’s nonpublic personal...more
The Securities and Exchange Commission (SEC) has sent clear signals that it will pursue companies for “AI washing” — touting the use of artificial intelligence in ways that are false or misleading. The SEC has imposed fines...more
Starting May 28, 2024, the settlement cycle for most transactions in U.S. securities will shorten from T+2 to T+1 as a result of rule amendments adopted by the Securities and Exchange Commission (SEC).1 The SEC also adopted a...more
Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more
...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more
The Securities and Exchange Commission on October 13, 2023, adopted two new rules under the Securities Exchange Act of 1934 expanding reporting requirements for securities lending and short sales and amending rules regarding...more
We have often written about the SEC’s whistleblower program and, in particular, the success of the program with respect to detecting and preventing violations of the federal securities laws. The success of the program...more
Key Points - Last week, the SEC announced settlements with 10 broker-dealers and affiliated investment advisers in connection with their failures to maintain and preserve electronic “off-channel” communications....more
The SEC has proposed new rules designed to regulate potential conflicts of interest associated with broker-dealers’ and investment advisers’ use of certain AI-related technologies in their interactions with investors. The...more
Last month, the SEC took a big step toward strengthening the cybersecurity of financial systems by proposing regulations that, taken together, will require registered investments advisers, broker‑dealers, and all national...more
This Memorandum is intended to remind you of certain U.S. annual requirements that may be applicable to your business and is divided into five sections. All investment advisers (whether or not registered with the Securities...more
On December 14, 2022, the Securities and Exchange Commission adopted final rules amending Rule 10b5-1 under the Securities Exchange Act of 1934, as amended, to impose new conditions to the availability of the Rule 10b5-1...more
On September 27, 2022, the Securities and Exchange Commission (“Commission”) entered into a series of settled orders (“Orders”) against 15 broker-dealers and one affiliated investment adviser for widespread failures by the...more
On September 27, 2022, the SEC announced that it had sanctioned 15 Broker-Dealers and one affiliated RIA for widespread recordkeeping violations of Section 17(a)(1) of the Exchange Act and Rule 17a-4(b)(4) thereunder...more
Department of Justice announces criminal and civil cryptocurrency initiatives as Securities and Exchange Commission Chair Gensler continues to develop the agency’s regulatory and enforcement agenda. Despite an unsettled...more
Last week, the U.S. Securities and Exchange Commission (“SEC”) brought enforcement actions against a company and its former CEO for failure to adequately disclose certain compensation and related party transactions. The move...more