The SEC Division of Examinations (the “Division”) issued a Risk Alert on March 27, 2023 detailing observations from examinations of newly-registered investment advisers. The Risk Alert provides information about the typical focus areas reviewed during examinations of newly-registered investment advisers. It also
Division of Examinations: 2023 Examination Priorities
On February 7, 2023, the Division of Examinations of the United States Securities & Exchange Commission (“EXAMS”) published the 2023 Examination Priorities. Like previous years, the 2023 Examination Priorities provides certain data regarding the scope of the examination program and the growth
SEC Enforcement Action Related to Conflicts of Interest
On January 5, 2023 the SEC announced a settled Administrative Proceeding with Randy Robertson. Mr. Robertson previously served as the co-portfolio manager for the BlackRock Multi-Sector Income Trust (“BIT”). While serving as the co-portfolio manager for BIT, Mr. Robertson explored the possibility
DCS Alert: Division of Investment Management Marketing Rule FAQ
On January 11, 2023 the SEC Division of Investment Management issued an additional Marketing Rule FAQ. The newly issued FAQ addresses gross and net performance requirements applicable to private fund case studies, single investments and/or groups of investments, i.e. extracted performance. Specifically,
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