Tag: investment adviser

SEC Sanctions Adviser For Failing To Follow Its Procedures

It is axiomatic that investment advisers are required to the follow dictates of firm operating documents, internal procedures and disclosed policies and procedures. OCIE, when conducting inspections, focuses on such issues. The SEC has brought a series of cases centered

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This Week In Securities Litigation (Week ending Feb. 10, 2017)

Three of the six actions filed this week by the Commission were against registered investment advisers. One involved the misappropriation of funds, another centered on the failure to disclose a related party transaction and a third was based on the

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