Month: October 2015

The SEC brought another enforcement action predicated on the failure of the firm to comply with its operating documents. In this instance the advisers to a fund failed to inform investors that it effectively changed the investment strategy by altering …

SEC Sanctions Advisers For Not Disclosing Shift In Investment Strategy Read More »

The Commission accepted a settlement offer from one of three Respondents in an offering fraud action. It was based in part on cooperation and an undertaking to appear and testify for the staff in the future. In resolving the proceeding …

Undefined Cooperation is Basis For SEC Settlement Read More »

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