Carl Ayers
CCO liability framework announced, smart steps for fund advisers, scathing report critical of SEC IG and much more
This is a DOE document request letter directed at a robo adviser
"We made good progress in 2021, finalizing a handful of rules and proposing many others. We have much more to come on the SEC’s Agency ...
The topic of soft dollars has lost some of its luster among examiners but enforcement actions continue to emerge from the agency. Expenses, however, remain ...
One of the first SEC enforcement cases of 2022 fines a firm for lacking compliance P&Ps around the IA’s use of hypothetical advertising—in a year ...
CMG prepared hypothetical, backtested performance results and the backtest was not adequately correlated with the securities they replaced in the live strategy
A peer passes along a policy and procedure for the use of e-mails as well as for the retention of e-mails
Tips to prevent insider trading, SEC ALJ system being challenged anew, eyeing private funds and ESG and much more
The adviser takes additional precautions. After the 10-day period passes, its analysts can see only a 'high-level summary' of the networking firm’s interview with a ...
'Do not make it more difficult for investment advisers to engage in proxy voting or to use' proxy advisory firms, wrote one commenter