9/20/2018 | Content area:
If your firm pays a radio station to run an ad, you better tune in.
That’s one lesson from the SEC enforcement action against Creative Planning ($36...
9/18/2018 | Content area:
This matter involves violations of the Advisers Act and certain rules thereunder by CPI, a registered investment adviser, that: (i) distributed hundre...
5/18/2018 | Content area:
Perhaps you can gain ideas for your P&Ps from this example.
2/08/2018 | Content area:
The credentials heralded by the hedge fund adviser principal were certainly impressive—an MBA in finance from Dartmouth, a prior portfolio manager wit...
1/21/2018 | Content area:
A peer shares a one-page primer aimed at helping staff understand their responsibilities under the firm's personal trading section of its code of ethi...
12/07/2017 | Content area:
Multiple compliance backstops were in place at hedge fund adviser Brahman Capital Corp. to safeguard confidential information. Despite the firm’s writ...
6/26/2017 | Content area:
These proceedings arise out of the failure of WSC, a registered broker-dealer, to establish, maintain, and enforce written policies and procedures rea...
5/10/2017 | Content area:
The Advisers Act expects that access persons will report their securities transactions and that you’ll review them. A former SEC staffer found there’s...
5/09/2017 | Content area:
The SEC's complaint alleges that David R. Humphrey, who worked at the SEC from 1998 to 2014, concealed his personal trading from the SEC's ethics offi...
4/07/2017 | Content area:
Besides the compliance rule, only one other Advisers Act rule mentions the “chief compliance officer”: Rule 204A-1 (code of ethics) – and all but one ...
1/26/2017 | Content area:
The SEC Jan. 25 charged a Massachusetts-registered investment adviser and its managing partner, CCO and sole employee Michael Breton with cherry-picki...
5/27/2016 | Content area:
FGIMC did not establish or maintain written policies or procedures for identifying outside consultants who – based on their functional roles and wheth...
2/17/2016 | Content area:
You’re well aware that Advisers Act rule 204A-1 (codes of ethics) requires you to review access persons’ transactions. You may not know that SEC exami...
11/25/2015 | Content area:
Hardly a week goes by now without the SEC bringing another enforcement action against a private fund adviser for issues tied to fees and expenses allo...
8/25/2015 | Content area:
A peer shares her firm's code of ethics and personal trading policy.
6/26/2015 | Content area:
You may wish to do more before deciding an access person’s personal trades don’t need to be reviewed because they supposedly fall under the code of et...
6/26/2015 | Content area:
This release from June 2015 recommends compliance staff dig deeper when determining that an access person's trading doesn't need review because it qua...
4/02/2015 | Content area:
Nearly all advisers don’t place a limit on the number of personal trades staff can make annually. The typical holding period – for firms that have one...
1/01/2015 | Content area:
Investment Adviser | Broker-Dealer | CPO/CTA | Private Fund
(a) Definitions. For purposes of this section:
(1) Access person means:
(i) Any Advisory Person of a Fund or of a Fund's investment adviser. If an in...
12/09/2014 | Content area:
Investment Adviser | Private Fund
As a compliance officer, your role must include examining the personal securities trading of your firm’s employees. The SEC’s Office of Inspector Gene...