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Compliance Policies & Procedures

A peer shares her firm's code of ethics and personal trading policy
A failure to deliver final prospectuses in shelf offerings triggers enforcement action
New, accredited investor definition triggers issues Private funds should take a new look at their subscription agreements after the SEC’s decision to widen the definition ...
Take some ideas from one of your peer's gifts and entertainment policies
A peer shares the firm's policies and procedures for maintaining records
By the time you finish reading this story, three more of your fellow humans will have developed Alzheimer’s disease. More than 50 million people around ...
Here's another P&P for returning to work during the pandemic
Another adviser’s return-to-work P&Ps note restrictions on unnecessary travel, virus testing when traveling staff return, frequent wiping down of “door handles, counters, kitchen tables,” staggered breaks ...
It has become possible that some type of pandemic like SARS or Ebola would require employees to abandon one or more of our offices and ...
A Miami private fund adviser incorrectly billed real estate funds it advised $3 million in expense reimbursement, costs that should’ve been billed to its co-investment ...
Proxy Voting
A peer has shared a copy of the firm's proxy voting guidelines
Failures stemmed from allocations tied to day trade and buy-and-hold clients
First Western will pay $200K penalty under settlement
A policy for a fundamental compliance duty
The SEC’s recent private funds risk alert points to structural problems in the industry—problems that the Commission itself is in a unique position to help ...
The compliance burden of the newly relaxed Volcker Rule will fall heaviest on banks but no one on either side of the reopened ledgers will ...
Private fund advisers struggle with conflicts of interest, fees and expenses and putting together the right P&Ps to mitigate the risk of material, non-public information ...
To all outward appearances, Richard Diver stood as a pillar of rectitude. The co-founder of Manhattan-based M&R Capital Management ($487M in AUM), Diver, 63, ran ...
Failures resulted in $1M penalty for Ares Management
"Anyone that has shown symptoms must get tested"
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