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DCS Alert SEC Division of Examinations - 2025 Examination Priorities

Division of Examinations: SEC Fiscal Year 2025 Examination Priorities for Investment Advisers

On October 21, 2024, the Division of Examinations of the United States Securities and Exchange Commission (the “Division”) published the Fiscal Year 2025 Examination Priorities.  In addition to investment advisers, the Division has examination responsibility for broker-dealers, investment companies, self-regulatory organizations, clearing

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DCS Alert - SEC Enforcement Actions Related to the Marketing Rule

SEC Enforcement Actions Related to the Marketing Rule

On September 9, 2024, the SEC announced it had settled Administrative Proceedings with nine investment advisers for violating the Marketing Rule. The violations involved distributing advertisements that included untrue or unsubstantiated statements of material fact or testimonials, endorsements or third-party ratings that

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SEC Division of Examinations Risk Alert - Initial Observations Regarding Advisers Act Marketing Rule Compliance

SEC Division of Examinations Risk Alert: Initial Observations Regarding Advisers Act Marketing Rule Compliance

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

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Observations from Internet Adviser Registration Reforms

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

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