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
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
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
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