Conflicts of Interest

Respondents collected nearly $1 million in investor funds by charging the Fund for ACM’s expenses. These expenses, which under the investment documentation provided to investors were ...

The recipe’s as simple as baking Christmas cookies: do what you’ve promised investors in writing that you’ll do.   Violating this simple rule cost private ...

As a result of NSR’s failure to disclose the Co-investments before they were made and to obtain the requisite consent for the Co-investments from the ...

Talk about compounding your problems. When an investment adviser principal was confronted by a client who noticed a lower account balance than they anticipated, the ...

When the president of Valentine Capital Asset Management ($367 in AUM) lost his ability to earn commissions from a managed futures fund, he simply created ...

Initially signaled back in January in its 2016 exam priorities letter, the SEC’s Office of Compliance Inspections and Examinations confirmed Sept.12 that it will examine ...

SEC Enforcement director Andrew Ceresney was quick to point out “a common theme” in the Commission’s recent enforcement actions against private equity firms:  a failure ...

An enforcement action brought Aug. 2 against a Eugene, Oregon-based investment adviser has further driven home the SEC’s focus on share class issues. Placing a ...

A CFTC staff advisory released July 25 clarifies that additional supervisory reporting and consultative relationships for CCOs of swap dealers, major swap participants, and futures ...

Investment advisers failing to disclose loans from broker-dealers to their clients are squarely in the crosshairs of the SEC’s exam and enforcement staffs. This message ...