On April 17, 2024 the Securities and Exchange Commission (“SEC”) Division of Examinations (the “Division”) issued a Risk Alert regarding investment advisers’ compliance with amended Investment Advisers Act Rule 206(4)-1 (the “Marketing Rule”). The observations contained in the Risk Alert focus on
Observations from Internet Adviser Registration Reforms
On March 27, 2024 the Securities and Exchange Commission (“SEC”) adopted amendments to Rule 203A-2(e) under the Investment Advisers Act of 1940 (the “Advisers Act”). Rule 203A-2(e) provides an exemption from the prohibition on registration with the SEC that may otherwise affect
SEC Enforcement: Senvest Management Enforcement Action – Electronic Communications
The Securities and Exchanges Commission (SEC) has announced a settled Administrative Proceeding with Senvest Management LLC (“Senvest”). Pursuant to the SEC issued Order, Senvest failed to maintain and preserve certain electronic communications and failed to enforce its code of ethics. The code
Division of Examinations: 2024 Examination Priorities for Investment Advisers
On October 16, 2023, the Division of Examinations of the United States Securities and Exchange Commission (the “Division”) published the 2024 Examination Priorities. Historically, the Examination Priorities have been published in the 1st quarter of the applicable calendar year. For 2024, the Division
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