My first post discussed the SEC’s Office of Compliance Inspections and Examination’s (“OCIE’s”) recent Risk Alert (the “Alert”) and specific fund categories in its crosshairs. This post will cover the three remaining fund categories and general examination issues identified by OCIE in the Alert.… Continue Reading
Apparently lost in the news of the impending departure of SEC Chair Mary Jo White is her recent suggestion to expand liability of corporate executives. In a speech on November 18, 2016, Chair White suggested a potential change in federal securities law that would hold executives accountable even if they are not involved in the … Continue Reading
On June 26th, the Securities and Exchange Commission’s Division of Investment Management issued IM Guidance Update No. 2015-03 titled, “Personal Securities Transactions Reports by Registered Investment Advisers: Securities Held In Accounts Over Which Reporting Persons Had No Information or Control.” As its name suggests, the update deals with the reporting exception in subsection (b)(3)(i) of … Continue Reading
