Tag: procedures

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 December 16, 2016)

The Commission filed four actions last week. One action centered on a cherry picking scheme; a second focused on an adviser that failed to follow its own procedures regarding conflicts; a third involved an investment adviser who made repeated misrepresentations

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