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SEC: Enforcement
A staffer at the adviser "made a campaign contribution to a candidate for elected office in Minnesota, which office had influence over selecting investment advisers ...
"This case is yet another illustration of the overbreadth of the pay-to-play rule and another reminder of the way the rule hampers legitimate political participation"
The resounding message is don't advertise hypothetical performance on your public websites
Heed the lessons of the SEC’s latest off-channel communications enforcement action against an adviser and you may well sidestep a similar fate
The Commission alleged that in 2013, as CCO, Ronald Heineman ignored red flags and engaged in a scheme to manipulate the price of a stock ...
"As with the recordkeeping cases and, frankly, all our cases, we consider whether a firm self-reported and cooperated with our investigation"
"As we speak, there are investigative teams across the division poring through voluminous records to, for example, seek emergency relief to stop ongoing frauds"
This is a fundamental violation of an investment advisers’ fiduciary duty to act in the best interest of its clients, according to the judge
Senvest failed to implement procedures to monitor whether its employees were following the firm’s policies concerning work-related communications .... At least three senior Senvest officers ...
Cases 'should serve notice to the investment industry,' Enforcement Division Director Grewal says in video.