Tag Archives: Advisers

D.C. Circuit Vacates SEC Sanctions, Says Negligent Omissions Are Not ‘Willful’ Under Advisers Act

On April 30, the U.S. Circuit Court of Appeals for the District of Columbia Circuit vacated a Securities and Exchange Commission order imposing sanctions. The court held that an investment advisory firm and its owners did not violate Section 207 of the … Continue reading

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Broker-dealers can continue to rely on investment advisers for customer KYC requirements

In a December 12, 2018, letter to a US trade association with members that include broker-dealers in securities (“broker-dealers”), the US Securities and Exchange Commission (“SEC”) extended its no-action relief to broker-dealers who wish to rely on investment advisers to … Continue reading

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Overview of State-Registered Investment Advisers and Current Regulatory Issues, Part 2

In our previous post regarding state-registered investment advisers, we examined the landscape and discussed common deficiencies found in state adviser examinations.  In this post, we will discuss enforcement actions typically aimed at state-registered investment advisers, as well as current enforcement … Continue reading

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OCIE announces risk-based exam initiatives focused on funds and advisers

By Amy Leisinger, J.D. The SEC’s Office of Compliance Inspections and Examinations has issued a risk alert announcing its intention to conduct a series of examination initiatives focused on issues affecting certain registered investment companies and investment advisers. According to … Continue reading

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