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,
Division of Examinations Risk Alert: Observations From Broker-Dealer and Investment Adviser Compliance Examinations Related to Prevention of Identity Theft Under Regulation S-ID
The SEC Division of Examinations issued a Risk Alert on December 5, 2022 detailing observations from examinations of investment advisers and broker-dealers related to compliance with Regulation S-ID. Summary of Regulation S-ID Investment advisers that maintain “covered accounts” are required under Regulation
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