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Cady Bar the Door Insight & Commentary on SEC Enforcement Actions and Related Issues

Tag Archives: Rule 204-2

SEC’s Asset Management Unit Focuses on Compliance Failures, Vol. 2

Posted in Compliance, Investment Advisers, Non-scienter-based Violations

As we discussed last month, the SEC’s Asset Management Unit has developed a likeness for not just big, headline-grabbing cases, but relatively small compliance-based cases that are designed to prevent minor problems from growing into large ones.  People like to say that the damage is done before the SEC ever gets involved, and that is… Continue Reading

SEC’s Asset Management Unit Focuses on Compliance Failures, Vol. 1

Posted in Compliance, Investment Advisers, Non-scienter-based Violations

The SEC Enforcement Division’s Asset Management Unit has brought some substantial cases over the last year, including a number arising out of its Aberrational Performance Inquiry.  Another focus for the unit has been compliance failures at registered investment advisers.  On November 20th, the unit filed a pair of administrative cases addressing some of those failures. … Continue Reading